GP practices will be legally required to register with the Care Quality Commission by April 2013. It's going to require a lot of planning and preparation ahead of the deadline to prevent a last-minute rush, and of course it's all happening against a backdrop of other changes such as the emergence of authorised CCGs.
Having led the CQC registration process for NHS Lambeth in April 2010, I have seen the process at first hand – and it is not as onerous as it seems. The evidence required to demonstrate compliance with the regulations is not new and well-run practices should already have it, and systems in place to confirm compliance.
Practices will only need to register once – it is not an annual process. However, the CQC indicated earlier this month that it will be visiting all practices once every two years. It has also said it will investigate practices if the evidence they submit differs from that provided by the GMC, local involvement network (LINk) groups or GP commissioners.
Practices must therefore ensure the evidence they rely on is readily available should the CQC ask to see it or visit, and is consistent with that held by other organisations. And, of course, the practice must be compliant with the regulations at all times.
This article sets out the steps practices should take to ensure they are ready for the registration deadline based on our experiences in Lambeth. The CQC published an introduction to registration in October 2011 that would also be a useful resource for any planning you do in your practice.1
1 Start early
The time taken to prepare for registration cannot be overestimated – we started in August 2009 and our registration deadline was March 2010.
Looking back, we should have started the preparation even earlier. This would have given us more time to work with staff and prepare them for the additional work and stress.
2 Familiarise yourself with the process
Research the stages of registration and the online application date, and ensure you can plan for sign-off by all your partners.
Read each of the descriptions for regulated activities before deciding which ones apply to you. A full description of each is set out in the Scope of registration document on the CQC website.2 Make sure that everyone in the practice, including patients, knows about the CQC – if staff from the CQC visit they are likely to see and speak to the receptionist and patients first. Involve the whole practice team early on – you might want to delegate the collection of each area of evidence to different members of the team.
To influence developments and shape the CQC processes, practice managers may want to consider joining the Provider Reference Group.3
This is an online community that gives you the opportunity to get involved and test out key processes as they are developed. The CQC will use the feedback to help shape the way they work with primary medical services before changes are implemented.
3 Set up a steering group
Within our PCT, we first set up a steering group to oversee the registration process. This consisted of the director of nursing, the medical director, service managers, heads of clinical services, the head of clinical standards and the clinical audit manager. The remit of the group was to develop an action plan outlining key activities, who was responsible for completing those activities and the timescale of their completion, and to monitor the action plan. Specific actions included:
• identifying evidence to support compliance for CQC outcomes
• explaining the process to staff
• developing templates to support staff, including a risk assessment for each outcome with prompts to help teams identify gaps in compliance, and an action plan template highlighting the additional evidence needed, how this would be identified and who was responsible for overseeing implementation
• carrying out mock CQC inspections of services and preparing them for an actual CQC visit.
Such an arrangement could be adapted by a large practice or a group of practices joining together to oversee the registration process. Small neighbouring practices could also create a joint working group to share ideas for how to support themselves during CQC registration.
The local LMC might also be able to put these groups in touch with other practices that have already gone through registration. Why produce several versions of a policy, for instance, when one could be produced in each area and adapted to the specific needs of each practice?
4 Collate and organise evidence
I recommend you keep information tidy and accessible. During our registration process, we had the evidence to confirm compliance with the required outcomes, but it was collated and stored in a variety of formats and was not all in the same place. The challenge for us was to bring together all current reporting requirements to avoid fragmentation, duplication and frustration.
Practices will appreciate the opportunity to use information already collected for a variety of other purposes as evidence of compliance. The CQC recognises that the range of information already collected for QOF indicators, quality initiatives and other performance-related purposes can be used as evidence to demonstrate compliance with the 16 core standards of quality and safety.
Identify a lead person to collate the information required to confirm registration, to complete the process before the deadline and be the main point of contact for the CQC.
Set up a system to store all your evidence to confirm your compliance. Collate the evidence you have now against each of the outcomes you have to meet for your regulated activities. For example, if you have evidence that you gather patients' views and use them to improve practice – and QOF information will be vital here – get it ready now. Other examples of sources of evidence include:
• risk management
• safeguarding systems
• outcomes or guidelines supporting practice
• staff support systems including education, training, supervision and appraisals
• facilities management
• health and safety surveys
• infection control
• management of complaints or incidents and lessons learned
• clinical audits
• changes to practice.
5 Draw up a plan and make it available to staff
Develop a statement of purpose – a description of the services you provide.
For all the regulated activities you provide, review your related policies and ensure they're fit for purpose. Once policies have been assessed, check they are implemented and that staff know how to access them and how they are used in practice. Compliance is not just about documentation – it is about ensuring the right policies are implemented and used to improve patient care.2
Review your action plan regularly and provide feedback to staff. Check the primary medical services section of the CQC website regularly for updates so you stay on top of changes to the process.4
6 Assess your practice yourself
The assessment criteria for each of the regulated activities and outcomes are available online. Set aside a few sessions or a full day for someone like a practice manager, for example, to use the CQC's Judgement framework to evaluate your practice.5
Assess your services against each of the regulated activities or core outcomes and develop an action plan to address any gaps. Bear in mind that after registration you will need to develop a system to ensure ongoing compliance with the outcomes and notify the CQC of any changes to services, including staff changes, services opening or closing, and changes to service premises.
Ensure that monitoring and evaluation systems are built in and that lessons learned from complaints, patient feedback and audits are used to improve practice.
Siobhain O'Donnell is a freelance management consultant and a former head of clinical governance at NHS Lambeth
1 Care Quality Commission. An introduction to registration with the CQC for providers of NHS general practice. 2011. tinyurl.com/7dq67gf
2 Care Quality Commission. Scope of registration. 2011. tinyurl.com/7ra8ka8
3 Care Quality Commission. Provider reference group. cqc.org.uk/prg
4 Care Quality Commission. Registering with the CQC: information for GPs. 2012. cqc.org.uk/register
5 Care Quality Commission. Judgement framework. cqc.org.uk/judgement