31st August 2017

In or out?

Top tips for health and social care providers getting your head around CQC scope!

Game of Thrones

I’ve stayed up way later than my bedtime trying to find out the answers to complex questions left unravelled on Game of Thrones. (If you aren’t watching it, bear with me – I need to unburden.

Whether it is how White Walkers have procured chains in the icy north to hall a dragon from the water, or why the eyes on Mr Snow’s sword hilt changed colour. I surf the net to try and find definitive answers, because I just really need to know.

Going digging with trembling hands

Some of you will find that the same level of mining into information is just as necessary when trying to figure out if you should be registering with CQC.  Plus, the nerves are kicking in, because you feel if you don’t register and you should you could be prosecuted and if you try and register and you get it wrong, you could be refused and your service could be delayed with cost to you and those you wish to provide a service to.

Now I have painted a picture that may worry you – let’s unpick it and face the fear!

The Scope of Registration

This should be your first port of call.  I am not saying it is easy – but it has some important information in it. Make sure you take a look at information for providers in completing an application and adjoining information on regulated activities.

Top Tips:

  • Start from the beginning of the scope document, don’t skip to what you think you provide – the opening pages alone could mean you don’t need to register if – you are not actually a provider, you are not a provider in England or you do not carry out a regulated activity
  • Regulated activities have a lot of explanatory notes with them. Make sure you read them to assess whether the things you do within your service are classed as a regulated activity. Your service could be undertaking more than one – and each will need to be applied for
  • Use the flow charts provided in the relevant regulated activity section to you and answer the questions, for instance on whether you provide personal care which is in scope of CQC registration – following the path can give a clear ‘yes’ or ‘no’ for being in scope for that particular regulated activity

Speak to CQC

Yes – contact them. I am afraid they won’t answer – ‘do I need to register’, and, they will refer you to their guidance if you have not looked at it, however, you may have a complex question a member of their policy team can help you with, if it is an irregular question that cannot be answered in their guidance (believe me it happens!)

Top Tips

  • Emailing CQC will ensure you get a written response you can take your time over, and even get some help understanding it. Quoting the scope in your response will help them see you are trying to work it out yourself. CQC have committed to work with providers with new models of care

Check out other providers you know are doing the same thing

This one comes with a bit of a health warning – you really need to be sure it is the same.

Top Tips

  • Reading a report on another provider will help you know if they really are doing a similar thing. Check out the grey box on the right-hand side of the page to see what they are registered for
  • Make sure you also check regulated activities for yourself. They may be registered incorrectly so it is best to double check if it rings true with what you provide – you may do additional things that also need to be registered

Regulation is born out of law, and because of that, it’s language at times, reflects the complexity of law.

BIGGEST TIP

  • Don’t think everyone else understands this stuff easily! It can be complex getting to the heart of who does what
  • Use Ask Sheila and contact QCS if you need additional support. Check if it has come up as a topic before

So why can’t you just ask CQC whether you need to register?

If CQC told you, you didn’t need to register, or in fact that you did and this was incorrect, it would be on their heads - and you have the small matter of all of the providers that may also feel they wanted to ask how they should set up. The money just isn’t there for that, and CQC is there to assess your ability to understand your responsibilities as a registered provider and manager, not as a support agency. It’s tough – but there we are.

Still waiting…

I am waiting for at least a year to find out the answers to my questions on Game of Thrones – hopefully, this blog helps you get your answers a bit quicker!

*All information is correct at the time of publishing

Abi Spence

Registration and Inspection Specialist

Abi has worked for and with Government agencies relevant to social care for the past 12+ years. Primarily with the Department of Health, Social Services Inspectorate, Commission for Social Care Inspection (CSCI) and since its inception the Care Quality Commission (CQC). As part of this long involvement Abi has developed a wide and detailed understanding of relevant issues and has worked closely with stakeholders such as people that use services, carers, providers, local government, the Department of Health, Ofsted and the Audit Commission. Read more

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