Registering a Domiciliary Care Agency; the Policies.

This blog is the fifth in a six-part miniseries looking at what a prospective domiciliary care provider needs to do in order to undertake a Care Quality Commission (CQC) registration. In this series we explore what is required to undertake a successful application for CQC registration as well as how Bettal can help.

In the previous blogs in this miniseries, https://bettal.co.uk/starting-a-domiciliary-care-agency/,we took a look at some of the reasons you might want to register a domiciliary care agency as well as some of the pros and cons of doing so. We also considered the roles of the Registered Manager (RM) and Nominated Individual (NI), who you might choose as your service users and the contents of the Statement of Purpose and the Business plan and what details you need to include in the CQC registration application relating to these.

One of the other core requirements of any CQC registration application are the policies required to run the service. These policies must meet set criteria to be fit for CQC registration and are not therefore something most potential providers can create for themselves.

What Policies do I need for the initial application?

The CQC provide a list of policies which all providers must include with their CQC registration application, https://www.cqc.org.uk/guidance-regulation/providers/registration/supporting-documents-provider, these are:

· Consent Policy and Procedure.

· Equality, Diversity and Human Rights Policy.

· Governance Policy.

· Infection Control Policy.

· Medicines Management Policy.

· Recruitment Policy.

· Safeguarding Policy and Procedures.

· Statement of Purpose.

As we said before, the CQC identify what they want in each policy and procedure, so it is important when making a CQC registration application that you include policies which meet these requirements, such as those provided by Bettal.

By looking at the requirements for a couple of policies, we can get a better understanding of what it is the CQC are looking for in policies. With regard to the Governance Policy, the CQC require that the policy must include how you will:

· Manage and govern your organisation.

· Continually assess and improve your governance practice.

· Seek and act on feedback from people using the service.

· Assess, monitor and improve the quality and safety of the services you provide.

· Securely maintain accurate, complete and detailed records of each person using the service and records relating to staff employment

· Meet statutory requirements such as the General Data Protection Regulation (GDPR). See the Information Commissioner’s Office (ICO) guide to data protection.

You must also make sure your document contains:

· The name of your organisation.

· The name of your policy lead.

· The date your governance policy was created, and the date when it will be reviewed.

· A structure chart that shows the hierarchy of your organisation.

With regard to the Safeguarding Policy and Procedures, the CQC require that the policy must include:

· Specific procedures for the types of services and age groups you propose to care for.

· Guidance about how people can raise concerns about abuse.

· The process for reporting and raising safeguarding concerns. Who the safeguarding lead is and what will happen once it has been reported.

· The different types of abuse, preventative measures and what constitutes abuse.

· Information about your local authority safeguarding team and how they can be contacted. The LA safeguarding team must be in the same geographic region in which you are providing services.

Evidence how this information will be accessible to:

· People who use your service.

· Their advocates, those lawfully acting on their behalf and those close to them.

· Your staff.

You must also make sure:

· Contains the name of your organisation.

· Contains the name of your policy lead.

· Contains the date your document was created, and the date when it will be reviewed.

· Refers only to current legislation, it should not contain any references to out-of-date legislation.

As can be seen from the safeguarding policy and procedure requirements there is a need to ensure the policy is personalised to the specific agency. For example, the local authority safeguarding team details need to be added as the policy used in the CQC registration process will need to be made available to Service Users, Staff and other stakeholders who may need these details if raising a concern.

Similarly the policy requirements identify that the name of the organisation is clear in the policy and that the policy lead is identified. In many cases the policy lead will be the RM, although the safeguarding and infection control leads within an organisation may be someone else who should be identified in the text of the policy. In part this is again so people accessing your service in the future know who to direct an enquiry to.

Bettal monitors the requirements for policy content, which can change, and ensure that out policies are fit for CQC registration purposes. This means you don’t have to, but it does require you to ensure that any customisable elements of the policy / procedure are completed prior to submission of the CQC registration application.

What policies do I need when I get to the inspector stage?

Once the CQC registration application has passed initial screening, the inspector allocated to oversee the remaining processes will ask you for some other documents which include the following policies:

· Duty of Candour Policy.

· Person Centred Care Planning Policy.

· Quality Assurance Policy.

· Risk Management Policy.

There are no criteria on the CQC webpages about what are required from these policies, but we can assume that they also need to:

· Contain the name of your organisation.

· Contain the name of your policy lead.

· Contain the date your document was created, and the date when it will be reviewed.

Again the policies need to be fit for the service you intend running in the locality in which you are registering. Bettal has all of these policies ready for customisation and inclusion in your domiciliary care agency CQC registration application.

Summary

In this blog we have seen that the CQC registration process requires the prospective provider to supply a variety of policies as part of the process. We have identified how some policies go in with the initial application while others need to be ready for the phase following screening when the CQC registration application is passed on to an inspector.

We have identified that policies need to contain defined levels of detail and that all policies and procedures need to be customised for the particular agency before being submitted.

In the final blog in this mini-series we will consider what you need to do to successfully fill in the various forms you need to complete as part of a CQC registration application, focussing on the general provider application and the RM application. In a later blog, we will explore what you need to do to prepare for the RM and NI interviews.

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

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