Abi Spence, a Registration and Inspection specialist for Quality Compliance Systems (QCS), offers guidance for new provides on the registration process.
For new providers seeking to open a service, registration is a mandatory first step. Providers cannot open without it. But often it is not an easy hurdle to negotiate. It can be a long process. Due to the pandemic, the average registration takes 16 weeks to complete rather than 12 weeks. But, if you were to ask first-time providers who use the QCS system, most will tell you it is not the time element that bothers them, but exactly what needs to be submitted to get the green light.
So, how do providers – best navigate the registration process? Abi says “the registration process can be divided into three separate stages (application, validation and interview), to understand how to get it right”.
Firstly, Abi says that “it’s vital that providers spend time laying the foundations before starting an application”. She explains: “Whatever the service type, providers need to put a lot of time and effort into the pre-application stage because the CQC will expect providers to comply with the regulations at the point of registration.
“What the CQC is looking for is a service and a building that is ready to go. It wants to see that competent and qualified staff have been recruited. It will also check that the correct finances, insurance and valid building documentation are in place. Finally, the CQC will want to be sure that there are sound policies that indicate a service will operate well for people who will use the service.”
Before providers can proceed with submitting an application, they will need a countersigned DBS from the CQC. According to the CQC website, providers should factor in a number of weeks to compile and organise this information.
Abi adds: “This can take up to six weeks if providers are registering as an individual, or they are applying as a Registered Manager or Partner. But the most important point to reiterate is that they cannot make it past the first page of the application without it.”
Putting the right people in place
According to Abi: “It’s exceptionally important that providers have the right manager in place, as this is crucial for success”. She says: “The CQC will be assessing the manager application along with the provider, and if providers haven’t completed due diligence, they are sure to fail.”
As part of pre application, the provider should have appointed a manager with the right qualifications, competence, skills and experience to be the Registered Manager. Registered Managers should also be of good character to carry on the role.
Abi adds: “Providers should ask questions of the manager’s CV, checking their employment history is complete and any gaps are accounted for.”
CQC Online System (OLS): Completing the application form
When providers are confident that their documentation and policies are right, they can move on to starting the application form, which can be accessed through the CQC Online System (OLS).
Says Abi: “In the application CQC will need to see supporting information, including a business plan, a statement of purpose and evidence that staff working for the service have the right training and qualifications. CQC has issued a comprehensive list of all of the information that is required for each service type as there are many other supporting documents required such as Safeguarding and Mental Capacity Act Policies.”
Validation and assessment
From there, the application will be validated by the CQC. In addition to the above, providers need to show in their applications that they are not just aware of the CQC’s key questions and the KLOEs that underpin them, but are also able to evidence how they meet the fundamental standards within their policies.
Abi says: “For providers, validation means checking that everything is in place. The CQC will pick up on key information in policies which reflect how a service will be run. For first-time applicants, this can be incredibly challenging as they have the skills and knowledge, but are not quite sure how they fit that together within their policies. Numerous applications will be rejected at this point as they do not contain what CQC are asking for.”
What is most important is that providers and managers prove that they personally supervise and manage the service and understand their obligations. To support them, QCS has produced registration packs, which are designed to help providers navigate the registration process more easily.
Once the validation process has been completed, the assessment process begins. It is a qualitative deep dive into an application and the related policies and documents that are attached.
Abi comments: “Inspectors will make sure the policies and documents reflect the service. They will also review any information they hold (or can obtain) in order to gain a picture of the applicant. From an inspector’s perspective, they are looking at gaps, and queries they can raise with the Manager or Provider regarding the application – within the scope and limits of the regulatory requirements.”
Interview and site visit
The third and final stage of the registration process is the interview and site visit. So what does an interview and site visit entail and how should providers best prepare for it?
Abi, who worked for the CQC and predecessor organisations for nearly 20 years in policy and registration, says that “the inspector will want to assure themselves that the manager understands what their obligations are to CQC. This means demonstrating to the CQC that they understand what exactly they should notify the CQC about, and also they understand their responsibilities to the service”.
Abi also says that managers should be clear about “what their policies say, who the service is for and what it will provide”.
“The provider should also understand their responsibilities, policies and procedures and demonstrate their suitability to provide the service,” says Abi.
Regarding the success of an interview, she says: “It really reflects of how much preparatory work a provider and manager has carried out at in the preliminary stages of an application.”
When an inspector carries out a site visit, they will not only be looking for evidence that the premises meets the regulations, but also that a robust set of policies and procedures are tailored to it. Most crucially, the service must meet the needs of service users.
Providers must approach a site visit from the point of view that “the service is ready to open and that it’s comfortable with the CQC checking and assessing it in a registration inspection”.
Abi says: “As an inspector you do not want to turn up to a site visit and find you need a hard hat because the building is not ready, or discover that a fire hazard is full of empty boxes.”
To ensure that nothing goes wrong on the day, Abi says that “the provider’s representative should be knowledgeable about the premises” as they show the inspector round and “be prepared to show any documentation the inspector may want to see”.
Abi is following the CQC new strategy with interest, in which the CQC wants to see tangible evidence of integration, co-production and co-design. She says that “those registering should show the CQC that they have a good knowledge of the demography of the local area and how services will work in a joined up way where possible. Policies should reflect any joint protocols and reference other agencies they will work with”.
While the CQC mentions ‘registration’ very little in its new strategy, it does focus on ‘safety’ in assessments. This new strategy, says Abi, could, in the future, “lead to changes as to how safety is defined, throw more light on what is expected in provider policies, and affect change in the way that providers consider psychological and physical safety in the service environment”.