Who should register as an

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A quick guide to

CQC registration

May 2012

Key concepts

This quick overview of key concepts will help you decide what registration means for you:

 What is your provider type?

 How many locations do you need to register?

 Which service types do you offer?

 Which regulated activities do you provide?

 Who should be your registered manager(s) and nominated individual(s)?

 Do you comply with the essential standards?

What is your provider type?

 It’s your provider – or legal entity – that needs to register, not individual locations, each GP working in a practice or each contract you hold.

 Every provider must tell CQC their ‘legal entity’ or

‘provider type’:

• Partnership

• Individual

• Other organisation (e.g. company, charity or LLP)

 Find out which entity you should register as on the following slides…

What is your provider type?

– Partnership

For example…

 Four GPs have formed a partnership agreement and share liability for three surgeries and multiple contracts. They include details for each surgery on a single application and register as a partnership .

What is your provider type?

– Partnership

About partnerships:

• It is the partnership that must register, not each individual partner.

• All partners have made an agreement to accept joint and several liabilities.

• Each partner is responsible for meeting the essential standards and accepts joint and several liabilities.

• Limited liability partnerships (LLP) should not register as a partnership but as an other organisation .

What is your provider type?

– Individual

For example…

 Three GPs are based in the same clinic at the same address. They share expenses but don’t share liability so they are separate legal entities.

They each register as an individual .

What is your provider type?

– Individual

Who should register as an individual?

 Sole-traders or single-handed GPs should register as an individual.

 Individuals register in their own name and are directly responsible for meeting the essential standards.

What is your provider type?

– Other organisation

For example…

 A social enterprise has a number of GP practices in a locality. It registers as an other organisation and includes details of all its locations, activities and contracts in one application

What is your provider type?

– Other organisation

Who should register as an ‘Other organisation’?

 A limited company that provides a range of primary care services across a county, including a GP practice, a walk-in centre and a GP-led health centre.

 A social enterprise that provides a number of GP practices within a locality.

 A limited liability partnership (LLP).

What is your provider type?

– Different models

• There are many other models of service delivery that may affect how you should register, including:

• Joint ventures

• Franchises

• Hosting arrangements

• Renting arrangements.

• More guidance and information about these arrangements are available on our website: http://www.cqc.org.uk/node/445774#legal .

Which regulated activities do you provide?

 You can think of regulated activities as the services you provide.

 The 15 regulated activities are related to care and treatment that require registration with CQC and are set out in the legislation.

 Some have very specific definitions so you should check the guidance carefully before you decide which activities to register: http://www.cqc.org.uk/node/445774#regact

Which regulated activities do you provide?

For example…

 You may assume you should register the activity

‘Family planning services’ if you provide the

‘contraceptive services additional service’.

However, this service excludes intrauterine contraceptive devices and the regulated activity is specific to intrauterine devices. So in this case you wouldn’t need to register ‘Family planning services’.

Which regulated activities do you provide?

The following regulated activities are most relevant to general practice:

All GPs should register for:

 Treatment of disease, disorder and injury.

Most GPs should register for:

 Diagnostic and screening procedures

 Surgical procedures

 Maternity and midwifery services.

Many GPs should register for:

 Family planning services.

How many locations do you need to register?

 In the registration process the term location is used differently from common usage:

• Locations are the places where you provide or manage regulated activities.

• We count any place where people may be treated as a location if the regulated activities provided there are managed independently, for example if there is a separate patient list.

How many locations do you need to register?

 When you register you need to specify which regulated activities you carry on at each of your locations.

 If you have more than one location, you only need to submit one registration application form, which should include details about all your locations.

 You are responsible for ensuring your compliance across all regulated activities provided both in your main surgery and in any branch surgeries.

Check our examples of locations to register…

How many locations do you need to register?

For example…

 A practice and branch surgery that share the same patient list are classed as one location - even though they are based in separate premises. You only need to register the main location (i.e. the location from where the service is managed, staff are recruited, main records held, etc.). If the branch surgery has a separate patient list, you should register it as a location in its own right.

How many locations do you need to register?

More examples:

 If you visit patients elsewhere – be it at home, in prison or in a care home – you don’t need to register these addresses as locations. You can cover these activities and your compliance with the essential standards when you register the main practice where you manage the services.

How many locations do you need to register?

More examples:

 A GP-led health centre will generally be classed as a location as it will manage its own patient list.

 As a rule a walk-in centre is a separate a location as it does not share a patient list with a main surgery.

Which locations do you need to register?

Which service types do you offer?

 In your application you have to tell us which service types you provide at each of your locations.

 Of the 28 service types, the following are most relevant to general practice:

• Doctors’ treatment services

• Doctors’ consultation services

 Most other service types – e.g. ‘Diagnostic or screening services’ – are only relevant if this is your sole or main purpose . Otherwise you don’t need to register for it.

Who should be your registered manager(s)?

 Registered manager(s) have day-to-day responsibility for certain regulated activities in one or more locations.

 They share responsibility with the provider for ensuring that the essential standards are met.

 A provider will need to have registered managers for its regulated activities if it is:

• A partnership

• An other organisation

• An individual who is not in day-today charge of carrying on the regulated activities or is not fit to do so.

Who should be your registered manager(s)?

 Your registered manager(s) is not necessarily the practice manager.

For example…

A GP partnership with one surgery run by three GP partners and a practice manager discuss who should be registered manager…

Who should be your registered manager(s)?

The practice manager felt uncomfortable with the level of responsibility and accountability of the role, and after reading the guidance on www.cqc.org.uk/register , they decided one of the partners was more suitable.

He was in a good position to both influence the quality of the service provided by the practice and enable compliance with the essential standards of quality and safety. He also had experience in quality assurance at the practice.

Have you chosen your registered managers?

Who should be your nominated individual(s)?

 You'll only need a nominated individual if you register as an other organisation ; partnerships or individuals do not need one.

 This person will act as the main point of contact with

CQC.

 It should be someone who has responsibility for supervising the management of one or more regulated activities.

 It can be the registered managers’ supervisor but your registered manager(s) can also be a nominated individual.

Who should be your nominated individual(s)?

For example…

A limited company that runs three GP surgeries and two walk-in centres needs to assign both one or more registered managers and a nominated individual.

They decide that their Clinical Director should take both these roles for all locations. This is because he's already responsible for monitoring the quality of the services and ensuring their compliance with existing legislation and best practice guidance.

Compliance with the essential standards

 CQC monitor compliance against the 16 essential standards.

 Compliance with the standards is measured in terms of outcomes for patients.

 When you register with us you must declare whether you’re compliant with the essentials standards in each of your locations.

 You can still register if you’re not compliant with a standard , as long as you manage risks to patients and staff. You’ll also need to submit an action plan of how you’re going to change this.

Do you comply with the essential standards?

For example..

Three GPs in a partnership that runs a main surgery and a walk-in centre discuss in a practice meeting whether they meet the standards.

They check their existing evidence for quality assurance and find that their main surgery is compliant with all the standards. Their walk-in centre is compliant with all but 'Safety and suitability of premises‘ because their landlord has not allowed them to build a wheelchair ramp.

Do you comply with the essential standards?

(Example continued)

The partners have already arranged that patients with mobility issues are visited in their homes. They check that both existing and new patients are satisfied with this service.

They consult the guidance on www.cqc.org.uk/register .

They find that, as they have done everything within their control to comply with the standard and are already managing the risks and inconveniences to patients and staff, they can declare that they’re compliant with this essential standard.

Further guidance

To find out more about these concepts and to see further examples:

 Visit the GP area of the CQC website: www.cqc.org.uk/register

 Read The essential standards: Guidance about compliance : http://www.cqc.org.uk/sites/default/files/media/documen ts/gac_-_dec_2011_update.pdf

 Sign up to the monthly e-bulletin on our website: www.cqc.org.uk/register .

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