As most practice managers across England will no doubt be aware, all providers of health and social care across the country will need to register with the Care Quality Commission (CQC). Most providers are now registered but the Department of Health has agreed that registration of providers of primary medical services, including GP practices, will be postponed until April 2013. Providers of out-of-hours services however, are still required to register by April this year.
Having led on the registration process for a large London primary care trust (the community function has now merged with an acute trust) in April 2010, I can confirm that the process is not as onerous as it first seems: the evidence required to demonstrate compliance with the regulations is not new and all well-run organisations and practices should already have the evidence, systems and processes in place to confirm compliance.
However, the process will no doubt involve planning and preparation to avoid stress in the run-up to the deadline, especially as practices will be involved in other major changes in April 2013 – not least the emergence of authorised clinical commissioning groups (CCGs) as primary care trusts (PCTs) are abolished.
One of the main obstacles practices are likely to encounter is engaging the whole team, who will undoubtedly see the additional workload as yet another bureaucratic process. Communication both about the requirements for registration and ongoing monitoring is vital to avoid problems later on.
Registration is a legal requirement but most practices will already have processes in place for the Quality and Outcomes Framework (QOF) indicators putting them in a good position to demonstrate compliance with the regulations/standards.
I have outlined below how we successfully planned for registration – and survived!
We first set up a steering group to oversee the registration process. This consisted of the director of nursing (chair), the medical director, service managers, heads of clinical services, the head of clinical standards and the clinical audit manager. The remit of the group was to develop an action plan outlining key activities, who was responsible for completing those activities and the timescale of their completion. The steering group monitored the action plan.
Such an arrangement could be adapted by a large practice or a group of practices joining together to oversee the registration process, with representatives from each practice responsible for completing the key activities at local level.
The steering group's specific actions included:
The requirement to register with the CQC was not an option and there was little flexibility in the timescale for registration. The registration process itself was cumbersome, and while the CQC Relationship Managers were helpful it was difficult at times to get the relevant information. However, this should not be such a problem for practices, as the registration process has now been simplified in response to feedback from providers already registered.
While we were confident that we had the evidence to confirm compliance with the outcomes, it was collated and stored in a variety of formats and not all in the same place. The challenge for us was to ensure that each service had the evidence readily available in the event the CQC should ask for additional information.
The time taken to prepare for registration cannot be overestimated. We started in August 2009 and the registration deadline was March 2010. This put additional pressure on service managers who had recently undergone a reorganisation. The challenge for us was to bring together all reporting requirements to avoid fragmentation, duplication and the risk of staff seeing the registration process as yet another bureaucratic process.
Suggested actions for registration preparation
The CQC has indicated that it will produce tools and guidance to help practices prepare for registration at a later date.
Meanwhile, it might be worth considering groups of practices working together to share ideas and review evidence to reduce the burden on individual practices. After all, why produce several versions of a policy when one could be produced with each practice adapting it to their own specific requirements?
To influence developments and shape the CQC processes, practice managers may want to consider joining the Provider Reference Group (see Resources). This is an online community that gives you the opportunity to get involved and test out key process as they are developed. The CQC will use the feedback to help shape the way they work with primary medical services before changes are implemented.
An introduction to registration with the CQC was published in October 2011 and provides useful information on the implementation process for practices.(1)
Develop a strategy early. This will reduce the stress in the run-up to registration in April 2013. This should include the following actions:
A full description of each of the regulated activities is set out in the Scope of Registration document on the CQC website.(2) You will need to read each of these descriptions before deciding which activities to apply for.
It will not be necessary to submit the evidence of compliance on registration but practices will be required to confirm against each outcome whether they are compliant (or not). Where gaps in compliance have been identified an action plan will need to be submitted at the same time, demonstrating how the gaps will be addressed and to what timescale.
Practices will only need to register once – it is not an annual process. However, the CQC recently indicated it is anticipating that as many as 10% of GP practices are at "significant risk of non-compliance" and could be inspected. This assumption is based on pilots run last year.(3)
The CQC has also indicated that it will investigate practices if they have differing evidence from the General Medical Council, local involvement network (LINk) groups or primary care commissioners.(3)
Practices must therefore ensure that the evidence they rely on for registration is readily available should the CQC ask to see it or visit, consistent with that held by other organisations, and that they are compliant with the regulations at all times.
Siobhain O'Donnell has led on clinical governance for several PCTs, setting up systems and processes across a range of service areas, including independent contractors. She now works as a self-employed project manager and was commissioned to lead on the successful CQC registration of a large London PCT in 2010.
1. Care Quality Commission. An introduction to registration with the CQC for providers of NHS general practice. London: CQC; 2011. Available from: http://www.cqc.org.uk/organisations-we-regulate/gps-and-primary-medical-...
2. Care Quality Commission. Scope of Registration. London: CQC; 2011.
3. House of Commons. Public Accounts Committee hearing, 25 January 2012. Available from: http://www.publications.parliament.uk/pa/cm201012/cmselect/cmpubacc/c177...
CQC – GPs and primary medical services
CQC – Provider Reference Group