Completing the CQC Registration Forms
This blog is the final one in a six-part miniseries considering the issues a prospective domiciliary care provider should consider before they decide to register with the CQC as well as how to undertake the application. In this series we have explored what is needed to make a successful application for registration as well as how Bettal can help.
In the previous blog in this miniseries, https://bettal.co.uk/domiciliary-care-agency-policies/, we took a look at the policies you need to include in the application and considered the detail you need to add to a Bettal policy before submitting it. We considered some of the content of the policies and therefore why it is important to use a provider with a track record of successful registrations to supply these.
We identified that you would need some policies to be ready for the initial application stage of the process and some additional policies once your application makes to through to the inspector stage.
As well as policies and your statement of purpose, https://bettal.co.uk/business-plan-and-statement-of-purpose/, the application requires you to complete a statement of financial viability (which your accountant needs to sign), complete an Information Commissioner’s Office registration, https://ico.org.uk/for-organisations/data-protection-fee/register/new-registration/, and fill in both a provider application and one for the registered manager, https://www.cqc.org.uk/guidance-regulation/providers/registration/register-provider.
In this blog we will look at some tips for completing the provider and registered manager application. Much of what you need to know can be found on the Care Quality Commission’s (CQC’s) website, https://www.cqc.org.uk/guidance-regulation/providers/registration/register-provider, so in this blog we are covering top tips for issues which in our experience people frequently struggle with or get wrong with their applications.
Overview
As a general rule you need to understand the CQC use language in ways which relates to how things are referred to in legislation. You should also be aware how the CQC will check for inconsistencies and inaccuracies in all applications, so you need to ensure you:
· Understand the terminology.
· Complete the correct elements of the form.
· Are accurate in your responses.
· Are consistent with your answers.
A good example of the use of terminology and being accurate is the way the CQC refer to the location. The location is where the regulated activity is carried out from. This does not mean the home of the Service User; it means the place from where care is coordinated. In the case of both supported living and domiciliary care this is the office form where care is coordinated. There are nine rules relating to what a location is, they can be viewed on the CQC website: https://www.cqc.org.uk/guidance-providers/registration/what-location.
It is usual for the name of the location to be the name of the business as it appears on Companies House, https://www.gov.uk/government/organisations/companies-house. The registered office address can be the same as the location, but does not have to be; the registered office address must however be the same as that which appears on the Companies House registration page.
You must also complete the correct elements of the forms. For example, most domiciliary care providers are limited companies and so they do not need to complete any of section 2 (for a business which is an individual) or section 3 (for a partnership – which has a distinct legal definition which is distinct from a limited company).
An important example of consistency is ensuring that the age groups and service user bands of the people you are registering to care for are the same in the application, the business plan and the statement of purpose. If you do it differently on one document the CQC may return your application and require you to resubmit.
We also advise keeping the applications neat and tidy, for example using the same font throughout. This sets a good impression and shows you take the process seriously. Ensure all dated documents are dated within, at the very most, one month of the day you submit the paperwork.
The Provider Application
The provider application is the main application and refers to the company making the application for registration. Most domiciliary care providers are limited companies and so must complete:
· Section 1: Organisation. Top tips: make sure your registered office address is as named on Companies House. Also if you are called The Best Care Agency Limited on Companies House, the CQC may not accept The Best Care Agency Ltd. All directors listed on Companies House must be included in the directors details section.
· Section 4: Financial information. Top tip: ensure this is completed in full and, as a rule, use the business address as the point of contact.
· Section 5: The regulated activities you want to provide. Top tip: Unless you have a registered healthcare professional, like a nurse, in the team you can only realistically apply for personal care which covers domiciliary care provision.
· Section 6: The location(s) you want to provide regulated activities at or from. Top tips: Most domiciliary care locations will be someone’s home or an office already in existence. So in most cases you will not need planning consent, building regulations, and you do not need food safety certification as you do not prepare and serve food from the office. Most domiciliary care providers also do not keep or service equipment. You may need to seek permission from a landlord or mortgage lender if you use a dwelling as an office. For consistency ensure the regulated activity(ies) identified in 6.9 are the same as in Section 5. Read the conditions boxes carefully and only complete those which apply to you, usually 6.13 and 6.15 unless you intend being a specialist learning disability and autistic people care provider – which requires additional paperwork.
· Section 7: How you will provide your service. Top tips: consider the nature of the five key questions; is the service:
o Safe
o Effective
o Caring
o Responsive
o Well led
Bettal has some prompts which can be adapted to complete this section. The prompts refer to the elements of the quality statements which apply to each of these questions.
· Section 8: Checklist of information that must be available to CQC on request. Top tip: Ensure you have, and tick, for all of these.
· Section 9: Partnerships only – Agreement to conditions of registration. Top tip: unless you are a partnership as opposed to a limited company, leave this blank.
· Section 10: Supporting notes. Top tip: Usually leave this blank.
· Section 11: Application declaration. Top tips: This must be completed in full; the usual answers are:
Number of nominated individuals in the organisation 1
Number of additional nominated individual sections submitted with this application 0
Number of locations where we are applying to carry on regulated activities 1
Number of additional location sections submitted with this application 0
Number of locations in this application that will have a registered manager 1
Number of manager application forms of all types submitted with this application1
The Registered Manager Application
The RM for any care provider needs to be someone who has the knowledge and skills to provide care. Again it is important to ensure the business name and address(es) and regulated activities etc. are accurate and consistent across this and the provider applications.
You must have a relevant, in date, Disclosure and Barring Service (DBS) to complete the form, for most people this means getting a CQC DBS, https://www.cqc.org.uk/guidance-regulation/providers/registration/dbs-checks-cqc-registration.
Top tips: complete a list of your previous employment and what you were doing, such as being a student at school or university from the age of 16. We advise not leaving any unexplained gaps of more than two weeks. For example if you took a month out for a holiday between school and university, say so in the “reasons for gaps” section. Ensure all employment start dates are within two weeks of the previous employment end date or provide an explanation as to why not, e.g. I had a long holiday between jobs.
Some people are concerned about gaps, but you should not be, just be accurate and clear. It is alright to have gone travelling, to take maternity leave or to have cared for a family member for weeks, months or years if this is the reality of what happened.
Top tip: complete the “reasons for gaps” section in a separate document and then cut and paste it into the application.
Top tip: when providing your GP details, name a GP in the practice rather than leaving that blank, it is a required box. Choose the GP you see the most or have seen most recently.
1.13, qualification skills and experience, is your chance to shine. Top tip: write this section in another word document and cut and paste it in. You must:
· Identify your qualifications – usually this will mean a minimum of a level 3 qualification in health and social care and working towards the level 5 leadership qualification. You may have equivalent or higher qualifications, but these are generally the minimum acceptable.
· Identify your skills and experience in leadership and management, for example as a team leader, care co-ordinator or equivalent. This is about your experience in leadership and management of the regulated activity, not the delivery of care.
Top tip: as a general rule, unless you have some explanation to provide to something, we advise not completing any supporting notes.
Summary
In this blog we have seen what you need to do to successfully complete the provider and the registered manager applications for CQC registration. We have seen that providers and managers
need to understand the language which the CQC uses, be consistent and clear in their application and that there is a need to ensure all answers are completed accurately.
In this series we have reviewed all of the elements of applying for CQC registration as a domiciliary care provider as well as the help which Bettal can provide in the process. Potential providers should review all of these blogs as well as the advice form the CQC themselves before making an application.
Bettal has a well tried and tested suite of policies and procedures which are designed to support potential providers with the registration process as well as hints and tips for some elements of the paperwork.
If you would like to know more, browse our website, https://www.bettal.co.uk, or get in touch:
Email: info@bettal.co.uk
Telephone: 01697741411
Peter Ellis MA MSc BSc(Hons) RN
Consultant
Bettal Quality Consultancy
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