CQC Provider Group Registration
The LMC has been contacted on a number of occasions by local GP provider companies who are confused about the need to register with CQC.
The LMC has met with CQC to discuss this specific question and the following is a summary of those discussions:
If the Provider Company actually PROVIDES the regulated activity then it will need to register with CQC eg the Provider Company employs the staff directly and is a completely separate legal entity*.
If the Provider Company holds the contract for that regulated activity but sub-contracts all of the work to practices, then they do not have to register.
If a practice holds a sub-contract from the Provider Company to undertake regulated activity on its behalf then the practice statement of purpose would need to list this, particularly if the practice is providing the regulated activity from another ‘location’ rather than their own practice premises.
If a practice is providing the service to patients of another practice within its own premises and is already registered to provide that service for its own patients then there is no need to seek any further registration but the statement of purpose should show this.
If a Provider Company is planning to provide a service it cannot register with CQC until the contract has actually been awarded (the CQC regulations state the provider must be providing the service). CQC confirmed it cannot accept organisations onto its register who have made unsuccessful bids.
* It is also important to be clear if the place where the service is being provided is classed as a location and the rule set for this can be found at: http://www.cqc.org.uk/sites/default/files/documents/20120808_rp_poc2a_300900_v5_00_guidance_on_location_for_external_publication.pdf
The LMC has asked the CQC to comment on our article and the following is their response in respect of actual registration when submitting a bid but before being awarded a contract:
" The Health and Social Care Act 2008 only requires registration where regulated activity is provided. Companies bidding for contracts will often need to apply for registration before they know whether they have been successful. CQC may ask for confirmation from applicants that they WILL provide regulated activity (e.g. that they have been awarded a contract to do so) before they grant registration. CQC cannot register Companies that will not provide regulated activity (i.e. those that are unsuccessful). Companies can, in these circumstances, withdraw their applications. “
In summary, they have softened their stance and applications can be submitted and either followed through or withdrawn once the outcome of the bid is known.