ASK ANNE: CQC - as easy as 1, 2, 3?
CQC – as easy as 123? It can be if you’re prepared and get expert advice!
One of the key aspects of buying a practice is dealing with and satisfying the Care Quality Commission (CQC), the independent regulator of health and social care in England, whose job it is to make sure health and social care services and dental providers give people with safe, effective, compassionate and high-quality care and ensure that people get the standard of services they are entitled to expect.
When a practice changes hands, both buyer and seller have to satisfy the CQC in a number of ways, and the complexity of the application process and the detail required can easily trip applicants up. Here’s a checklist of the most important things you need to do with regard to CQC.
1. Apply for a countersigned DBS check immediately
As soon as a sale is agreed, it’s important to start the CQC process by applying for a countersigned DBS (Disclosure & Barring Service) check. Both the buyer and the seller must apply for their own DBS check and it must be countersigned by the CQC in order to be valid; don’t apply for a DBS check with your local authority, as it will not be accepted by the CQC later in the process. The application can be filled in online and the process can take between 3 and 10 weeks. Your DBS check is then valid for 12 months.
2. Start gathering all your information for the CQC new provider application
Whilst you’re waiting for your DBS check to be approved, it’s important to start gathering all the information that will be required for your new provider application. The new provider application form is long and detailed and requires a lot of information from the buyer, including the last 15 years of job history, explanations of any gaps in employment and most importantly, section 5 which is entitled “How”. This section requires details of how you are going to provide the regulated activities to prove that you can satisfy the Key Lines of Enquiry (KLOE) which confirm whether your service is safe, effective, caring, responsive and well-led. Answering this properly will take time.
3. Make sure you are applying for the right registration
It’s very easy to get your CQC application wrong. Firstly, the CQC portal is set up in such a way that it’s easy to select the wrong application form without realising. Depending on your circumstances and the agreement you have with the vendor, you may be applying to go into partnership, or as a company or sole trader. Often, a new buyer will need to apply to go into partnership with the vendor for a period of time and in that case, both sides must apply for a partnership, the vendor simultaneously cancelling their existing provider registration.
4. Check your form meticulously – or even better, get an expert to check it for you
The CQC is very strict on what is acceptable and can reject a whole painstakingly-filled-out application for the most minor of errors, including grammatical mistakes. Part of the CQC Consultancy Service which MediEstates provides, is to guide buyers through the whole process – selecting the correct application form, completing the required detail and doing a final check. The onus is on the applicant to check and finally submit the form, but we take most of the headaches out of the process.
5. Prepare yourself for the CQC interview
Once the application has been submitted, you will be invited for interview, at which your suitability to be registered for the provision of regulated activities is assessed. It’s important to be prepared for all the questions that will be asked in order to prove you are the fit and proper person to perform duties to a high standard.
6. Make sure CQC application mirrors your NHS contract
If the practice holds an NHS contract, it is important for the CQC that your registration with them mirrors what is on the contract. So, if a buyer and seller go into partnership, their two names must be on the NHS contract, if the seller then subsequently exits later, the NHS contract must be altered too.
MediEstates CQC Consultancy Service is there to hold the hand of buyers and sellers throughout the CQC application process. We provide this service as a complimentary, but crucial addition to our service as a broker for our practices and it involves explaining the requirements of the CQC and taking on much of the time-consuming work that is involved. We guide customers through the process and prompt them regarding what action is required at each stage, we provide templates and examples to follow for different sections of the application form and perform a final check before submission. We also help our clients prepare for the interview by providing a list of questions that should be considered and hints as to how responses might be formulated.
And finally, as the only party who talks to both buyer and seller, we are in a unique position to help the seller fulfil their part of the CQC process, by informing them of what they need to do and when, and getting them prepared for the information the CQC will require.
There’s a lot involved in satisfying the CQC when purchasing a practice but being prepared and getting expert help will definitely smooth the way.
Posted by: Anne Barker on 25 Jun 2018