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Q&A Guide: Successful registration with the Care Quality Commission

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Introduction

Care Quality Commission (CQC) registration is a mandatory pre-requisite for every provider of adult social care.

Submitting to the registration process not only enables the CQC to examine the ability of your organisation to provide high quality adult social care services, but also to scrutinise the professional status and personal qualities of the key individuals that lead the organisation.

Together, the registered provider and the registered manager have joint legal liability for the quality and safety of the services provided. This applies to the specific regulated activities at the specific locations given in the application. Providing care is a serious business and the thoroughness of the registration process reflects this.

The ageing population and the cost of services make adult social care an important topic, and not just for those eligible for Saga membership! Predictably, every scandal precipitates a media feeding frenzy that fuels public outrage. What could be described as 'squeaky bum' political reaction knocks on to the regulatory body, the CQC. Ultimately this results in an increased burden of compliance on existing adult social care providers

Start-up health and social care organisations need to complete registration before they are able to gain access to the market. Coupled with the need to raise standards and verify credentials, registration is designed by the CQC to be detailed and lengthy; it is also widely held to be a frustrating process. This is an obstacle for many start-up care businesses as the need to generate cash flow means they need to open their doors without delay.

This Q&A guide helps provide those planning new adult social care businesses or those about to undertake registration on how to successfully complete CQC registration as quickly and easily as possible.

What is the best way to approach registered provider and manager applications?

Registered provider

Before attempting to complete your application it is essential to prepare thoroughly. Although CQC provide a lot of tools in the shape of information there is an awful lot it does not explicitly tell you. Thorough preparation should include the following points:

Commercial structure

Be clear about the commercial structure of your organisation. Partnership, Sole Trader and Limited Company all have different legal implications, especially when it comes to liability, so get professional advice. Ensure you make full disclosure of all partners and directors as failing to do so could result in immediate suspension of registration – a commercially disastrous situation for start-ups that need to open their doors and generate revenue.

Service offer and regulated activities

Be clear in your strategic plan on the exact specification of the care you offer. The obligations placed on you as the service provider vary significantly between care services. Before you can fully understand your responsibilities it is essential to know the services you offer.

Carefully decide on the regulated activity for which you wish to register, however, bear in mind you are likely to need to register for more than one. Read the type descriptions carefully because they usually have a wider meaning than is immediately evident from the words on the page, and may apply to your proposed service.

Read guidance and legislation

It is important to read the Guide (below), and the Health and Social Care Act 2008 (updated 2012), including the regulations. Do not fall into the trap of thinking that understanding compliance requirements is a 'detail' that should be left to the registered manager.

Registered providers are unable to properly manage registered managers without at least an overview of the legislation, regardless of how well you manage the business. And one day, probably very soon, a CQC Inspector will ask you “Have you actually read the Regulations?”  Read the Essential standards in the same way, for the same reasons.

A job application

Treat it as a job application, for the job you have always wanted!

Read the CQC Guide to the application process to find out what is needed of you. Adopt a structured approach to providing the evidence required. Make a list of the evidence, about your past, skills and attributes. Split them into 'easy – evidence solid and to hand' and 'difficult – evidence will take time to generate, or non-existent'. Make an immediate start on working out how to generate the evidence classed as 'difficult'.

How compliance management helps

Where you need specialist information and skills, consider using external resources such as a health and social care compliance management system. It is extremely difficult – some would say impossible - for small and medium care businesses to successfully manage compliance without the assistance of a management system. The Statement of Purpose required for the application is an example of where the best systems offer unbeatable advantages. There is more on this in the section below.

Further information

The CQC have some specific guidance that is useful. Go to the CQC page linked below for an explicit list of the steps and work through them.

Source: Care Quality Commission

Title: Step-by-step guide to applying as a new provider

http://www.cqc.org.uk/organisations-we-regulate/registering-first-time/how-register/step-step-guide-applying-new-provider

Registered manager

As for the role of registered provider, before attempting to complete your application as a registered manager it is essential to prepare thoroughly. Although CQC provide a lot of tools in the shape of information there is an awful lot it does not explicitly tell you. Thorough preparation should include the following points:

Service offer and regulated activities

Develop a clear view of the Service you are proposing to manage; your client types, their likely needs and aspirations, how many staff, what types and skills, and in particular the attitudes and personal standards you will be looking for. Be realistic about recruitment targets and sources of candidates. A realistic view is best informed by good research and/or personal experience.

Read guidance and legislation

Read the CQC Guide for Registration of Registered Managers, the Health and Social Care Act 2008 (updated 2012), including the regulations, and the Essential Standards. Avoid the urge to skip this until a later date; as registered manager you accept responsibility for the day to day delivery of care services that need to be legally compliant.

You need to be completely immersed in the detailed requirements, or at least know enough to understand where to find such information. You need to be able to design the staffing model for each Service, and talk knowledgeably about the documentation you will be using to support them.

A job application

Once again, treat it as a job application for the job you have always wanted!

Read the CQC Guide to the application process to find out what is required of you. As for registered provider, adopt a structured approach to providing the evidence required. Make a list of the evidence, about your past, skills and attributes. Split them into 'easy – evidence solid and to hand' and 'difficult – evidence will take time to generate, or non-existent'. Make an immediate start on working out how to generate the evidence classed as 'difficult'.

How compliance management helps

For specialist information and skills consider using external resources. For example, you are required to indicate and describe to the CQC the management system you intend to use for day to day operations.  To develop a management system from scratch before registration is a very long and detailed task. The best health and social care compliance management systems simplify registration and once up and running, provide a foundation for compliant operation for every aspect of the business.

Further information

The CQC have some specific guidance that is useful. Go to the CQC page linked below for an explicit list of the steps and work through them.

Source: Care Quality Commission

Title: Step-by-step guide to applying as a new registered manager

http://www.cqc.org.uk/content/step-step-guide-applying-new-registered-manager

What is the best way to write a Statement of Purpose?

Templates may offer an easy way to produce a standard piece to get you through registration.

However, a 'vanilla flavoured' Statement of Purpose is likely to be somewhat frowned upon. Although the use of a template here may not quite equate to plagiarism in an exam, using one may attract deeper scrutiny if the CQC somehow believes the Statement of Purpose to be inadequate.

Judgement here is highly subjective; at best the use of a clumsy template may project the impression that the author couldn't be bothered. At worst it could make you seem insincere or disingenuous.

How compliance management helps

The best compliance management service providers implement templates in an intelligent way. It is better to think of this approach as a 'tool' rather than a 'template'.

This approach provides a strong structural framework to the Statement of Purpose and embeds cues and pointers to let the applicant answer the brief in their own words. This prevents the submission of 'parrot-fashion' Statements of Purpose which reflect poorly on your organisation.

What is the best way to complete registration as quickly as possible?

The information required to submit your registration is substantive. DBS checks, application forms, Statement of Purpose and references mean there is a lot to be co-ordinated. Omissions are commonplace and create troublesome delays to the process.

How compliance management helps

The best compliance management service providers utilise online systems that lets you work through your application quickly. The system is designed to prevent incomplete submissions for CQC registration.

Anecdotal evidence suggests that preparing all the documentation for registration using an offline, manual process may take up to two weeks. Users of the best online compliance management systems report they have been able to submit all necessary registration documentation, verified omission free, in less than 2 days.

What is the best way to get expert advice?

CQC registration can seem a daunting proposition, especially if you are transferring into the adult social are sector from another commercial environment. There are a number of sources of information on the internet and we’ve linked to some of them in this guide. The CQC's own website is rich with downloadable content to help.

Too much information?

However, in the eyes of some there is almost too much information. In its entirety, CQC guidance runs to several hundred pages. While we might accept that there is a need to be thorough in such matters, it can seem unnecessarily unwieldy and bureaucratic, even unreasonable, to expect applicants to read and understand all of it. Rather than re-read and decode hard to understand legislative and legal-esque guidance, sometimes we would just like to clarify a topic by asking somebody who knows the answer.

How a compliance management service provider helps

One of the best ways to get access to trusted advice is to select a good compliance management service provider. The best providers offer support to help adult social care providers manage their compliance obligations.

The best compliance management service providers have established comprehensive services to help a care provider through all aspects of the CQC compliance lifecycle – from registration, through meeting ongoing compliance requirements and annual inspection.

The very best compliance management service providers will have highly trained compliance advisers available to provide assistance on-demand with every aspect of CQC registration.

Registration and beyond with QCS

The QCS compliance management provides all necessary documentation in a solid framework. This includes the Statement of Purpose and Care Planning formats, as well as all required policies, procedures and reporting and recording formats.

The system delivers an effective balance between using templates, which saves time, while embedding the documentation with information specific to your organisation, as required by the CQC.

Flexible purchasing options

For many, cash flow may be an issue at the registration stage. QCS provides highly flexible purchasing options enabling start-ups to control expenditure. Those intending to provide services are able to purchase the QCS Registration Pack and then upgrade to the full system once registration is complete. Alternatively, subscription to the full system may be chosen at the outset.

Quality Assurance. Guaranteed

The QCS compliance management system embeds TQM (Total Quality Management) processes throughout, providing you with a seamless system fit for the purpose of guaranteeing Quality Assurance (QA). This is designed to develop organisational cultures and support operational practices which promote human rights.

QCS system reassures the CQC

In the light of recent scandals, the understanding of QA and human rights by adult care providers and managers is closely scrutinised by the CQC. It is noted by many service provider’s that the QCS system has proved pivotal in reassuring the CQC of the fundamental standards care observed by the organisation.

Comprehensive, online and at your fingertips

Beyond registration, in the operational environment, QCS compliance management offers outstanding ease of use by providing a searchable online resource of hundreds of policies and procedures across thousands of pages. QCS provides essential compliance management in all areas of the business including Health and Safety, HR and Housekeeping.

Developed and maintained by experts qualified through practice

The QCS system is developed and maintained by experienced Providers and Managers, and is continually updated and expanded by practitioners. Customer input and comments, including feedback from the CQC during inspections, are continually reviewed and appropriate changes are integrated within the system.

QCS dedicated customer care team

The QCS customer care team offers support and advice to registration applicants during the customisation stage. A highly trained and proficient team of compliance advisers provide dedicated support on every aspect of using the system to successfully complete registration and on day-to-day use to manage the ongoing requirement for compliance and inspections.

About QCS

Quality Compliance Systems (QCS) offers a unique approach to CQC Compliance with an online based service specifically tailored to the individual needs of your organisation.

Whether you are an established Care Provider, Dental Practice , GP Surgery or a start-up organisation, our service is provided with the aim of ensuring that all aspects of compliance are being attended to.

Our industry experts continually update existing policies and procedures, whilst introducing new ones in response to the latest changes issued by the Care Quality Commission (England) and the SCSWIS (Scotland).

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Try QCS with a FREE trial

Find out more or enjoy a FREE trial of our CQC management system to see how QCS can help you save time, stay compliant and improve standards:

  • Full Access to up to 2,300+ online pages of easy to use guidance with 300+ policies & procedures
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Or Call one of our Compliance Advisors now on 0333 405 33 33 or email: info@qcs.co.uk

Some suggested further reading & sources

Source: Care Quality Commission

Title: Legislation

http://www.cqc.org.uk/content/legislation

Source: Department of Health

Title: Strengthening corporate accountability in health and social care: A consultation

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/210734/Corporate_accountability.pdf

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