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16th June 2017

Who is who?

Proposed changes to CQC Registration: Making it clearer who should be registered in Consultation 2

Murder Mystery

“It’s definitely her. She definitely did it!” I peer over my glass of wine at the Agatha Christie film on TV. There is a pause in my thinking “Actually I think it was him”.  “Anyone else?” Matt mutters with annoyance. “Yes it might actually be the boy” I say.

Pointing it out

I have a catch-all to TV drama. I like to mark everyone as having committed the crime, or being the heroine or hero before there are any clues at all (usually as soon as we have seen them). To my knowledge there is no prize in this, …and come to think of it I don’t know why I do it. Although it is satisfying in the 1 in 10 chance I am right to say I am.

CQC have had this problem as previous regulators before them. Currently, there are sometimes organisations who are involved in the quality and safety of care without being the company that directly delivers the care. It can be muddy waters and not always easy to see who is doing what.

Why is this important?

For a number of reasons

  • If another organisation looks to register and it is part of a wider provider who is/is not performing well, it would help with assessing the new provider
  • It helps the general public know more about their care
  • It brings greater accountability if things go wrong and drive improvement across organisations – CQC could prosecute both entities under consultation 2

CQC propose to move towards registering all legal entities that are accountable for the quality of services. This would mean ‘clarifying’ who should be on the register, CQC would define ‘accountability’ as;

Clarification in definition

‘Accountability (either directly or through other legal entities or contractual arrangements) for the carrying on of regulated activities, where that direction or control has the effect of rendering the organisation accountable for the quality and safety of those activities, even where responsibility for delivering care sits with others.’

For example: You may have an entity above a care home provider, such as a parent company, who has input or control of how the provider delivers the quality and safety of care within the provider’s care homes. The consultation has some great visuals to help you understand this on page 9-13.

This does not include overseas Entities – but CQC would want to know about them.

Adapt the information to show how care is being delivered.

CQC would look to change the way information on their register is shown so that the public would be able to have greater information on ownership of providers showing;

  • What services are provided
  • To whom
  • What type of service
  • Where to find these services
  • How much care is provided

There would also be history displayed helping the public know where a service had been taken over by another provider.

Statement of purpose

CQC propose to use the information that providers record in their statement of purpose so that the register will include what type of services are provided, who the service is for, what type of setting it is provided in, where the service can be found and, where relevant, how much care is provided.

QCS Tip: This emphasises the importance of the Statement of Purpose and the need to complete one accurately.

What about Fees?

Indeed! Fees are a charge for entering and remaining in regulation, it also costs by type and size of the service.

CQC will not change their approach, however, the level at which CQC would register providers and the structure of the register would change. That would mean the overall cost of regulation won’t go up according to CQC, but reading between the lines inevitably as more entities are registered that would cost. Any changes to the fees scheme, and any proposals to charge a fee for registration applications would have to be consulted on, however...

The end

We get to the end of the film. ”I told you!”  I say. My husband gets up to make a cup of tea. Without looking back. “Actually Abi that was the one person you didn’t mention….”

The Consultation Step 2 closes on Tuesday 8 August 2017

*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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