How we navigated the CQC registration process
Dr Claire Shell and practice manager Verity Shelton explain the impact of CQC registration on their practice – and what you can learn from it.
The deadline for registration with the Care Quality Commission has recently been put back to April 2013 for GP practices. But in our case, our practice has already been through the process. We were one of 20 practices in Derbyshire that has been involved in a pilot of CQC registration, and I have good news – we survived.
There has been much controversy over the workload that CQC registration involves and it is (at times) a bewildering process. But overall it has also been a positive experience for us.
The whole practice team has been involved, and while the process has been a considerable burden on our team, it was not as challenging as we feared.
This article will detail our experience of registering with the CQC, what was expected and the workload involved. Of course, the registration process may change as a result of our pilots, but if I could give you one piece of advice it would be to start looking at existing advice and begin preparing for this now.
Why we got involved Completion of CQC registration for GP practices is planned for April 2012, with applications opening in October 2011 – but a national pilot registration project was launched in Derbyshire in January 2011.
All general practices in the county were asked to register interest, and 20 signed up for the pilot.
We became involved because of our concerns over the complexity and structure of the registration process and the monitoring of compliance.
It is costly to implement changes to meet requirements of regulators, so we also wanted to ensure that any changes we did implement were essential requirements of the CQC.
There was a considerable amount of work involved in the initial form-completing process for the pilot – and we are only a one-site practice. For those with other sites, some of the documentation has to be filled in again for each surgery.
This workload was compounded by trying to navigate around the paperwork and identify which parts needed to be completed.
The registration system is not straightforward and involves several stages, but the first is to register as a provider under three categories: individual, partnership and organisation.
Almost all general practices will register as a partnership with the partners taking ownership of the business, and therefore, legally, the provider status.
Next, your practice will need to appoint a ‘registered manager' who will have legal accountability for managing the activities of the practice.
It is possible to have more than one, and we would recommend that you do as the paperwork cannot be completed by one member of non-clinical staff alone. We had the practice manger and one of the GP partners involved, but you may wish to involve other clinicians for specific areas of care.
At this stage it is important to ensure that those responsible are aware of the potential workload and are happy to take on their roles in the registration process.
It is not a short process – these individuals should be aware that it may take several days to complete and there is legal liability for all information.
The providers then need to produce a ‘statement of purpose', which outlines the aims and objectives of the service.
A model document has been provided online to assist with this process1 and the BMA advises that this is taken from the materials in your practice leaflet and website, rather than trying to reinvent the wheel.2 This document has to be reviewed and revised as necessary, and any changes notified to the CQC within 28 days.
Providers must decide which regulated activities the practice is able to deliver. There are 15 regulated activities, but in general only four that relate to general practice – treatment of disease, surgical procedures, diagnostic and screening procedures, and family planning services.
Providers have to declare the sites at which their regulated activities are carried out and complete separate documentation for each site. Branch surgeries have to be registered separately, unless all the regulated activities are run from the main surgery.
The next process is supposed to examine the outcomes of your practice, rather than the processes and systems in place. There are 28 outcomes that the CQC has set, which have to be complied with for each declared regulated activity – 16 are core outcomes.
These core outcomes include management of medicines, co-operating with other providers and monitoring and assessing the quality of service provision (see right for full list).
The practice then needs to demonstrate how they achieved each outcome by declaring compliance or non-compliance against each outcome.
You do not have to provide any documentary evidence for whether you meet each outcome, but you are encouraged to include specific examples where your practice has improved patient care and how the feedback from patients has changed your practice.
Declaring compliance/non-compliance was not as straightforward as it initially seemed.
Unfortunately, the accompanying documentation was not always clear about what was required to obtain compliance. We found there were significant areas that could have been left blank, but this was not clear.
We have been assured that the whole process will be streamlined and made more user-friendly once registration goes live online.
It was easy to say that the service was compliant when this was not actually the case – and tempting to do so.
However, non-compliance is not deemed to be a failure and reason for non-registration of a service. It can be addressed by outlining plans of how compliance will be achieved on the registration form.
Once the documentation has been completed and processed, a short, unannounced site visit will be arranged with the emphasis on direct observation of care.
Inspectors will then make a judgment for each of the regulated activities – deeming each activity compliant or of minor, moderate or major concern. Again, it is not entirely clear what sort of action will ensue, but it will range from issuing a warning notice to cancelling registration.
Inspectors may ask to see a variety of supporting up-to-date protocols from child protection to cleaning procedures when they carry out an inspection at your practice, so it is worth having these indexed and to hand.
We did not experience a formal inspection ourselves, but it is meant to be similar to the OFSTED school inspection process, with short, focused, unannounced visits.
It is not clear how these will work, how disruptive they will be and whether they will be based around observations, rather than inspections, which would take a significant amount of preparation time.
Pilot registration was not as challenging as initially feared, but still was a considerable burden for our busy practice team.
The questions posed did make us think about the areas that we are compliant and do well in and those that we need to work on. We have started to develop strategies to address these. Since the pilot, we have worked with two other practices to share our experiences with the other practices in our consortium.
With the help of the PCT we are pulling together working spreadsheets of outcomes and using a traffic-light system to assess areas of potential weakness.
We are looking at all the outcomes and breaking them down into bite-size pieces. We then highlight green for areas achieved, amber for areas that we are all currently working towards and red for areas that require extra work to reach the required targets. We are due to present this at our next group workshop.
It remains to be seen whether CQC registration will improve the service for our patients. It is, however, certain that it is likely to cause most providers a significant amount of worry, stress and financial outlay at a time when monetary remuneration is constantly falling.
We would suggest that practices familiarise themselves with the CQC documentation at an early stage to break areas down into bite-size, manageable pieces.
Verity Shelton is a practice manager and Dr Claire Shell is a partner at Blue Dykes Surgery in Chesterfield, Derbyshire