Moving forward with preparation for registration

The process of registering NHS General Practices with the Care Quality Commission has begun to gather speed. The registration process will begin late summer 2012 aiming to have all NHS general practices registered by April 2013.

Although there are still many subjects to be clarified or confirmed the CQC are setting out their stall as to what they expect from general practices once registered. In October the CQC published “An Introduction to Registration with CQC” for providers of NHS General Practice.

There are two key messages to remember:

Firstly, as a practice already providing clinical governance information and operating monitoring systems that measure performance, results and patient satisfaction to external bodies you should have much of the evidence already and will be able to use this data to demonstrate compliance with the CQC essential outcomes. There should be very little that you will have to create from new.

Secondly, remember the essential standards focus on the outcomes experienced by patients, not the policies and procedures your practice has.

Getting the building blocks in place

Preparing for registration should now be underway in your practice.

You and/or your practice manager should be registered with the CQC online community and be part of the Provider Reference Group. This will give your practice an opportunity to be involved in the development of the registration process. (

From the CQC website your practice manager should have downloaded:

  • the “Essential standards of quality and safety” March 2010 and have started considering registration and compliance requirements
  • the Provider Compliance Assessment (PCA) tool for each of the 16 essential outcomes
  • “For providers of NHS General Practice – An Introduction to Registration with CQC”

There should be a GP partner designated to working with the practice manager to understand how the process will unfold and what it entails and be able to share that with the rest of the partnership.

Within the practice your manager should be

  • introducing the nursing team to the “Essential standards of quality and safety” and thinking together about the best ways to gather clinical evidence to demonstrate compliance
  • starting to discuss the CQC registration with staff at team meetings – this is very important. There is much negative (and often inaccurate) publicity and information surrounding the CQC including practices being shut down if they fail to demonstrate compliance. It is important to bring staff on board from the start and get them to understand that CQC registration is an opportunity to publically show what an effective and caring practice they belong to.
  • reviewing current processes and creating a year plan if there isn’t already one to plot when various reviews, surveys and audits will take place

Outside the practice your manager should be talking to other managers in your area to see what collaborative work can be done, including:

  • arranging training workshops – although the CQC maintain that you don’t need extra staff or training to complete the registration forms, experience in the independent medical and dental sectors show that collaboration, training or support can be helpful to the practice in understanding interpretation of the requirements of the outcomes and how to manage achieving compliance where it isn’t currently happening
  • sharing policies
  • discussing joint activities and ideas such as audits and staff training (e.g. child protection and resuscitation)

Not everything is decided yet

Because the CQC hasn’t yet decided everything it is very important that practices take part in the consultation processes. By being part of the consultation process you can influence the way the forward.

  • Probably one of the key issues yet to be determined is that of fees. This will go out to consultation before the annual fee is announced. I imagine the fee structure will be one of the last decisions taken before April 2013.
  • Changes to the CRB checks are currently taking place, it is being proposed that if the provider or registered manager is a member of the GMC at time of registration they will not be required to have the CQC countersign the CRB application. CQC are about to go out to consultation with NHS General Practice providers on this subject through the Provider Reference Group
  • The exact time scale for registration application to commence is still to be determined – if it is the same or a similar system to that for dentists then you will only have a short window of time to submit your registration, which is another valid reason for starting to gather your evidence to demonstrate compliance now.
  • Take advantage of the road shows and exhibitions as well as online web chats that the CQC will be offering during the next eighteen months as they firm up on how and when they will want you to register your practice and the services you offer.

During 2012

By ensuring that you and your practice manager have the building blocks in place your practice will be ready to move forward confident in the knowledge that you know at every step of the way what the CQC are expecting from you and the services you provide.

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

Copyright © Martha Walker 2011