Preparing For CQC Homecare Registration.

In a previous blog, we identified how the Care Quality Commission (CQC) recently changed the criteria for registration of any new health or social care provider. We saw that this means some things which were previously required at registration are no longer required, some previous requirements have been refined and that there are some new requirements in terms of the paper work to be submitted.

The new criteria for registration, in common with the previous versions, require that prospective registrants undertake some preparation before starting the process. In this blog we will consider what some of these preparations are and how Bettal may be able to help you. As usual, we will be concentrating mainly on homecare / domiciliary care, registration.

Identifying local need

All providers of domiciliary care register to provide the regulated activity “personal care”. This in turn means all applications for CQC homecare registration have to be accompanied by a completed “Additional form for Providers of Personal Care”.

Prospective registrants who intend having clients from the local authority, which includes most applicants, must as part of this form ensure they establish the need for their proposed business in the area they propose to work. The form asks five specific questions about this:

• In which geographical area will you provide the regulated activity?
• Tell us how you have decided which groups of people you will provide personal care to. This means the service user bands and age bands you have selected in your application form.
• Tell us how you have identified a need for this type of service in the geographical area you have identified above. This must be specific to your area, not reliant upon generic national needs.
• If the service is funded by the local authority, please describe any contact you’ve had with them regarding the need for this service. You must complete this section if you intend to provide care to any local authority-funded service users.
• What evidence do you have of this? This means that prospective registrants must do some homework before applying for CQC registration which must include:
• Reviewing the local demography – this means looking at the office for national statistics and local authority data regarding whether the local population is, for example ageing and what the local prevalence of disability is locally. It is also important to consider future projections of the need for social care which might arise from these populations.
• Talking to other care providers in the area and identifying where there are gaps in the local provision.
• Reviewing any local authority plan for social care provision and identifying any immediate or longer-term goals and any areas of outstanding local need.
• Having a conversation with a local authority social care commissioner about whether they see a need for the type of provision you are proposing and either writing this up including their name, contact details and the date or saving the email exchange which shows there is a need.

It is the latter of these which prospective CQC registrants find difficult but which must be done.

While some commissioners are reluctant to have a conversation, many understand the CQC requirements and are ready to chat. Of course, the commissioners may say that there is no need for a further homecare provider in the locality the registrant is proposing, but may identify other areas within the local authority where there is or suggest alternative provisions, such as supported living, which is required. Prospective CQC homecare registrants must consider this carefully in the Additional form for Providers of Personal Care, as well as their Business Plan.

Identifying premises

Previously the CQC only required a new registrant to identify an address, called a location, from where they would run their business. Under the new registration regime, they require proof that of permission to run the business from the location provided in the form of Evidence of Legal Occupancy.

It is imperative therefore that before setting out on the CQC homecare registration journey, prospective registrant establish that they have permission to use the premises they propose. Such proof may take the form of a letter from a landlord or mortgage provider and so it is important to ensure this permission is secured and clear. Any letter, or email, of permission must state clearly:

• The name of the business and the director of the business as it appears on companies house records.
• The full address of the business.
• That the business is a homecare agency.
• The permission must be signed and dated.

A location cannot be a virtual office or PO box, so if permission cannot be gained to use a home address, prospective registrant may have to look to rent an office. Because the process of CQC homecare registration can be protracted and as homecare agencies usually start out small, it is advisable to rent a small office which must however be accessible, secure enough to hold records and have somewhere to hold meetings.

The CQC will also require one of the following when submitting the application:

• A copy of the title deeds (if the prospective registrant owns the premises).
• A tenancy agreement.
• A license agreement.

Training provision

Previously as part of the domiciliary care registration process, the CQC required prospective registrants to identify what training they would provide to care staff. Under the new requirements this has been extended to a requirement for details covering:

• Induction and mandatory training specifics.
• Role-specific training – that is for carers and managers etc.
• Specialist training – e.g. dementia or epilepsy awareness (depending on the registration type).
• Training providers – the name of the training providers for all training types.
• Refresher training – the frequency of refresher training.
• Support for overseas workers – including induction to the UK and language for example.

This means identifying the training providers before registration, but should not mean taking out a subscription which could cost a lot of money and not be used for several months.

Summary

In this blog we have taken a look at some of the initial work prospective homecare providers need to do before they start the CQC registration process. We have seen that the CQC have tightened up requirements to show there is a need for a homecare business in a locality, proof that premises may be used to home the business and that prospective homecare providers need to identify their training provision as part of the registration process.

Bettal has a well tried and tested suite of policies and procedures which are designed to support potential providers with the registration process.

If you would like to know more, browse our website or get in touch:

Email: info@bettal.co.uk
Telephone: 01697741411

Peter Ellis MA MSc BSc(Hons) RN
Consultant
Bettal Quality Consultancy