CQC registration, and what it asks of your systems

The provider is a legal entity, and getting it wrong is expensive

CQC uses provider to mean the legal entity responsible for carrying on the regulated activity, and it can be one of three things. An individual, which is a sole trader registering in their own name and directly responsible. A partnership. Or an organisation.

CQC is explicit that the application must be made by the correct legal entity, meaning the one that will actually be carrying on the activity. A clinic that incorporates, restructures or sells part of the business is changing the registrant rather than updating a detail, and a change of legal status is handled as its own process.

Regulated activities, which come from Schedule 1

The activities that trigger registration are listed in Schedule 1 of the 2014 Regulations. The ones that most often apply to an independent clinic are treatment of disease, disorder or injury, diagnostic and screening procedures, and surgical procedures, with transport services, triage and medical advice provided remotely relevant to anybody delivering care at a distance.

Which of those a clinic carries on is the first question and the one everything else follows from, because registration is granted for named activities at named locations and varying them later requires a further application. CQC publishes a scope of registration document for working out whether a given service falls inside one.

Conditions, and why they are not paperwork

CQC states that when it registers a person it does so with conditions, for example about the locations at which the regulated activity may be provided. Changing or removing a condition, adding an activity or cancelling the registration all require a further application.

The practical reading is that a registration describes a specific shape of business. A clinic that adds a second site, starts offering a procedure it did not previously offer, or begins seeing patients remotely has changed that shape, and the registration is the thing that has to move with it.

Fitness, assessed before anything is assessed about quality

CQC states that registration is granted only when applicants show fitness and compliance with the relevant regulations, and that applicants failing to meet those standards will be refused. Fitness runs through several regulations rather than one. Regulation 5 covers fit and proper persons as directors, Regulation 7 covers requirements relating to registered managers, and Regulation 19 covers fit and proper persons employed.

A Disclosure and Barring Service check is required before applying rather than afterwards. The pattern across all of it is that fitness is evidenced about named people, which is why a clinic's record of who its people are and what they are registered to do matters from the first application rather than from the first assessment.

The systems questions a new registration reaches

Registration itself asks about the entity, the activities, the locations and the people. The regulations the registration binds you to are what reach your systems, and four of the fundamental standards are answered largely from them.

Regulation 12 on safe care and treatment, including the proper and safe management of medicines. Regulation 17 on good governance and the records inside it. Regulation 18 on staffing, where the question is who was deployed rather than who was rostered. Regulation 19 on fit and proper persons employed, where the question is when a registration was last checked. Each has its own page, linked from software and CQC, what is actually being assessed.

A clinic choosing systems at the point of registration has an advantage worth using. The evidence those four regulations ask for accumulates from the first patient, and a clinic that starts with the joins in the right place never has to go back and reconstruct a year of them.

What we are not claiming

This page describes what registration attaches to and which regulations it binds a provider to. It is not legal advice, it is not a registration guide, and it is not a substitute for CQC's own guidance on scope of registration and on how to apply, which is linked below and which governs. Nothing here should be relied on to decide whether a particular service requires registration.

wai is not CQC registered, cannot be, and makes no claim to be. CQC registers providers of regulated activities rather than software suppliers. The registration and the duty stay with the clinic.

Where wai sits

wai is the system a registered provider runs on. It holds the diary, the clinicians, the record, the correspondence and the actions taken in one place, and a clinician authorises every patient-affecting action. Every read of a patient record is logged against a named role.

What that is worth at registration is narrow and real. It is not a shortcut through the application, and anybody offering one is selling something that does not exist. It is that the evidence the fundamental standards ask for is produced by the clinic running normally rather than assembled when somebody asks for it.

Request our answers to the evidence questions in writing before a demo. A supplier who will not put them in writing early, including us, has told you where they are. Clinicians still decide what enters the record.

Frequently asked questions