Getting ready for CQC in the NHS Primary Care Sector

Amidst all the changes and reflective processes within the NHS, the much talked about Care Quality Commission (CQC) registration plan for NHS GPs is also under going some changes.

Originally planned for April 2012, NHS GP registration has been pushed back to April 2013 following protests from GP leaders that resulted in the CQC acknowledging that they are looking at ways to “ensure registration is more closely aligned with accreditation schemes”. They are also using the extra year to give themselves more opportunity to embed compliance monitoring in the sectors they already regulate. The CQC may be buying themselves time to catch up but they will still register NHS GPs, it is just a question of when.

It is understandable that NHS GPs are unhappy about the forthcoming registration and what they quite rightly view as another tool from another external body to measure performance and compliance. Last year the country’s dentists felt exactly the same, and before them so did the NHS hospitals and back in early 2000s the clinics and hospitals in the independent healthcare sector were subject to complying with standards that changed on what seemed like a weekly basis. At that time the attitude of the then Healthcare Commission was “We are here to stay, so you had better accept it.” It is fair to say that the regulatory body has improved its relationship with the medical profession over the last decade and has moved towards a more positive liaison with providers. The information and guidance the CQC devised for the dental profession is a vast improvement on what it gives to the independent medical sector, hopefully the CQC will build on this move forward and streamline the information NHS G.P.s will be asked to deliver as part of their registration process.

CQC registration comes in two parts.

Part one: The registration of the provider

  • completion of the provider application
  • completion of the registered manager application
  • writing the Statement of Purpose
  • the declaration that you comply with the 16 essential standards of Care Quality Commission (Registration) Regulations 2009

The regulations describe the essential standards of quality and safety that people who use the services have a right to expect.

Part two: On going compliance

  • demonstrate that you continue compliance with the essential standards year on year

Registering with the CQC will cost time and money – the registration fee for NHS primary care providers is yet to be announced. So how can an NHS GP practice ensure that the registration process doesn’t consume everyone’s time at the expense of patient care and practice development and become a costly exercise?

Whilst there is a pause in the registration process use this time to prepare and gather evidence to demonstrate compliance. You can complete the application forms for registration at a later stage. By gradually introducing CQC into the practice calendar it won’t suddenly consume a vast amount of time when practices have to complete the registration process in the time frame allocated to them. Exactly how and when practices will be told when to submit their registration applications has yet to be confirmed.

Getting started

As with anything new, preparation is the key to successful registration and ongoing compliance.

Although your practice manager will undoubtedly over see and most probably undertake the lion’s share of the work involved it is important that the GPs at least have an overview of what is happening. Consider one of the GPs working with your manager to understand what is required. Later the GP partnership will have to designate one or more Nominated Individuals as part of the registration requirements. However initially if one GP and the manager work together to get a clearer understanding of the process, they can present to the rest of the GP partnership and the whole practice team how preparation for CQC registration will affect them and the part they will all play in it.

The doctors in the independent sector and more recently the dentists have discovered that by involving all members of the practice team, clinicians, nurses, administration and housekeeping staff the compliance process is not as much of a headache as originally perceived.

Make ongoing compliance part of the practice calendar and find ways to promote the practice positively with staff and patients through audit and survey results, such as clean building, patients recommending the practice, short waiting times, innovative suggestions from staff or patients.

But to start, both the manager and the GP need to familiarise themselves with the CQC information manuals including: –

  • Guidance about compliance:- Essential standards of quality and safety
  • Guidance about compliance: – Summary of regulations, outcomes and judgment frameworks

These are part of a wide range of guidelines that are available on the CQC website ( for professionals). The website is updated regularly, so make a point of visiting it at least once a fortnight and sign up for CQC e-newsletters.

A useful tool from the CQC

The emphasis now is much more on the provider, in this case the NHS GP practice, demonstrating compliance with the essential standards through the patient experience, rather than inspectors sitting in an establishment and spending most of the time reading through endless policies.

With this in mind the most valuable tool that the CQC has introduced is the Provider Compliance Assessment (PCA). Originally this online self-assessment tool was used very successfully by independent healthcare providers under the Healthcare Commission, it is likely that the CQC will follow in the footsteps of the Healthcare Commission and use the PCA as a tool to assess the ongoing compliance of all providers (including NHS GPs) once registered. The PCA goes through each Essential Standard and allows the provider to assess if they have the relevant evidence to demonstrate that they comply with the requirements of each standard and an action plan template to use if they need to do some work to improve a standard.

The PCA can be downloaded and started at any time. Once the practice manager is familiar with the Essential Standards and their intended outcomes, completing the PCA is the ideal way to record and consider the evidence the practice holds.

Completion of the PCA relies on the gathering and listing of compliance evidence. With this is mind the first thing to remember is all practices will have most if not all the information, processes, governance systems and data collection already in place to demonstrate compliance to the Essential Standards. It is mainly a case of knowing where it is, making sure it is up to date and above all keeping it relevant to the needs of the patients.

The most successful way to complete the PCA is for the manager to delegate different standards to each of the practice teams to assess and collate evidence for. With the PCA completed and action plans created to fill in any gaps, the whole practice will be in a strong position to complete the registration application whenever the time comes.

In conclusion, with timely planning and keeping in focus that as a practice you will have most, if not all the evidence already available, registration and demonstrating ongoing compliance should not be an all consuming event that detracts from patient care.

This article was written for the Association of Independent Specialist Medical Accountants’ and appeared in their web magazine Autumn 2011

Copyright © Martha Walker 2011