At the point of registration, the Care Quality Commission will not require the vast majority of GP practices to submit any evidence with their application. The CQC will, however, require a declaration of compliance against its essential standards. Before submitting applications for registration, GPs should ensure that evidence demonstrating their compliance is available, should the CQC request copies.
The CQC's website states that GPs are able to use any evidence they already have to demonstrate compliance, including – but not limited to – evidence gathered by practices participating in the General Medical Services's Quality and Outcomes Framework (QOF) or RCGP Quality Programmes.
Below is our 10-step guide that practices may wish to consider in collating evidence to demonstrate compliance:
1. Prepare 16 folders, one in respect of each of the CQC's 16 core ‘essential standards'.
2. Refer to the CQC's essential standards guide in respect of each regulation or outcome, and familiarise yourself with the requirements (see references for the link).
3. Assess what evidence the practice requires to demonstrate compliance under each regulation or outcome.
4. Assess whether the practice already has documentation in place to satisfactorily show compliance under each regulation or outcome and, if so, file evidence in the relevant folders.
5. Assess the robustness of the evidence. Is it:
o current? This may vary, depending on the data source.
o reliable? Is the source credible?
o usable? Is it good-quality evidence?
o relevant? Is it specific to the regulations?
o sufficient? Is there an adequate amount of evidence to show compliance?
6. Assess whether the practice has a procedure to monitor evidence and keep it up to date.
7. Assess whether there are systems in place to regularly audit and review systems and practices.
8. Identify the steps needed to obtain any remaining evidence required to meet compliance.
9. Draft an action plan in relation to any outcomes with which the practice is not compliant.
10. Declare compliance in respect of all remaining outcomes.
While the CQC's requirements for registration may seem onerous, there have been indications that it will take a pragmatic approach to the registration of GPs. The CQC has stated that most good-quality practices will already be meeting the CQC's essential standards without the need to purchase external tools or consultancy services to demonstrate compliance. GPs should take a similarly pragmatic approach to this registration process and should not panic if they have concerns about their compliance.
If GPs do have any queries or concerns about the registration process, however, they should seek further advice from CQC.
Now read, ' What evidence do I need to provide to meet the CQC's essential standards?'.
Reference
1. Care Quality Commission. Essential standards. http://tinyurl.com/dye4sol
Jonny Landau is a partner at Ridouts LLP
