The deadline for CQC registration came and went last year with barely a ripple. Most practices were successfully registered, although some had a number of conditions – often related to the condition of the surgery.
A year on, are you sure that your registration is still up-to date?
A CQC registration is for a particular business entity, delivering an agreed service or services, from an agreed location or locations. If any of these things change, you will need to notify the CQC.
In our experience this is the most common mistake. New partners must not join the partnership or take an active role in it until the CQC has approved. Depending on how you are registered, this can either mean a completely new CQC registration, or a change to one of your CQC registration conditions.
Once the CQC has given its approval, the new partner must normally join within 28 days. This can give practical problems as 28 days is often not long enough to agree any changes to a Partnership Deed. Practices should ensure that they have agreed an updated Partnership Deed before receiving CQC approval, and make the new partnership contingent on the approval.
The CQC should also be notified of the departure of a partner: ideally beforehand but in any event within 28 days of the departure. Practices should not reduce in size to a single hander without prior CQC approval.
New Service contracts
In the current environment of GP Federations and tendering for new services, it is easy to forget the CQC implications. A new service contract may well be a CQC service type for which you are not currently registered (such as ‘Surgical Procedures’). Alternatively, you may be tendering through a separate Limited Company or other business vehicle which will require a completely new registration. You do not want to spend money on a tender process only to find you are rejected because you forgot to update your CQC Registration!
When merging practices you will also need to merge the CQC Registration. Remember to notify the CQC before merging as you will need their approval and this should not be sought retrospectively.
Opening and closing Surgeries
Closing a branch surgery, moving to a different building or opening a new surgery all require prior CQC consent.
Remember, it is illegal to carry on a regulated activity without being properly registered, and you are only registered when the CQC issue you with a Notice of Decision. We strongly recommend that your CQC Manager fully understands these requirements, and raises them as part of the practice decision making process.