Registering a Domiciliary Care Agency – Service User Bands

This blog is the third in a six-part miniseries looking at the issues a prospective domiciliary care provider should consider before they decide to register with the Care Quality Commission (CQC). In this series we explore what is needed to make a successful application for registration as well as how Bettal can help.

In the previous blog in this miniseries, we took a look at the role of the Registered Manager (RM) and the Nominated Individual (NI) and what the CQC requires in order to be able to register these roles. We identified how the RM runs the business day to day, while the NI oversees the running of the domiciliary care agency and both need a working understanding of the applicable legislation.

As well as choosing the right people to be the RM and NI, anyone registering a domiciliary care agency needs to understand what:

• Regulated activities they are registering for.
• Age group(s) they are registering to care for.
• Which service user bands, specialisms, they are applying to work with.

In this blog we will consider what you need to consider with regard to these questions when seeking to register a domiciliary care agency.

Which regulated activity?

The CQC identify various regulated activities within the scope of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. These activities define in broad terms the services any provider can offer once registered.

For example the regulated activity “Treatment of Disease Disorder or Injury” can only be undertaken by registrants where the care is provided by healthcare professionals, while the activity “Nursing Care” may only be provided by registered nurses.

For domiciliary care providers, remembering domiciliary care is a form of social care, the regulated activity one registers for is almost always “Personal Care” which is defined by the CQC as:

Physical assistance given to a person in connection with:
• Eating or drinking (including the administration of parenteral nutrition)
• Toileting (including in relation to menstruation)
• Washing or bathing
• Dressing
• Oral care
• Care of skin, hair and nails (except for nail care provided by a chiropodist or podiatrist)

Prompting and supervising a person to do any of the types of personal care listed above, where that person is unable to make a decision for themselves about performing such an activity without being prompted and supervised.

If it not the intention of the agency to provide these services, or if you are planning to provide more than these services, you may need to look at registering more than one regulated activity.

Applications for registration for personal care can be made by individuals with experience in care as well as health or social care professionals – so for example many domiciliary care providers have experience of social care and hold NVQ (and equivalent) qualifications.

What service user bands should I apply for – age groups?

The first service user band decision a new provider must make is about the age groups they will serve. Most domiciliary care providers select 18-65 and 65+. This is because these are the age groups to which most people in need of personal care belong and with who most care providers have experience.

There are other age groups: 0-3, 4-12 and 13-17, which providers may select in their registration application. It is important that the prospective registered manager has experience with the age group(s) of service users selected so as to reassure the CQC that they can provide safe and effective care.

It is also important that the planned training of staff reflects the needs of the service users and that the policies of the agency are age appropriate. For example if you choose to work with people under the age of 18, you will need child safeguarding policies and training for staff which reflects the needs of children and young people as opposed to policies and training which primarily focusses on adults.

What service user bands should I apply for – specialisms?

There is great confusion about specialisms among potential providers and in our experience from some CQC inspectors. Not every domiciliary care provider will seek to register a specialism in any of the categories identified by the CQC, which are:

• Dementia
• Mental health
• People with an eating disorder
• Learning difficulties or autistic spectrum disorder
• People detained under the Mental Health Act
• People who misuse drugs or alcohol
• Sensory impairment
• Physical disability

Not ticking one of these does not mean that a provider cannot provide personal care for people whose primary need relates to one of these specialisms (except learning difficulties or autistic spectrum disorder).

Not selecting a specialism, or specialisms, for domiciliary care providers is OK if you intend providing a service to older people who have become frail.

If you are likely to provide services for other reasons, such as mental health issues or physical disability which might not be the result of frailty, then it is best to select these as specialisms.

As a general rule, most domiciliary care providers register for:

• Dementia
• Mental health
• Sensory impairment
• Physical disability

Because all of these are common reasons for needing care. CQC do caution however that if you do choose dementia, for example, then:

You must have the skills and experience to understand and respond to each person’s experience of dementia and its progression.

This means having the knowledge, skills and ability providing care for the service user as their disease progresses and not only caring for people with dementia in its early stages.

Providers cannot provide care for people living with learning difficulties or autistic spectrum disorder whose primary need arises because of the learning difficulties or autistic spectrum disorder unless they are registered to do so. This does not mean a provider without a learning difficulties or autistic spectrum disorder registration cannot care for these service users, merely that the learning difficulties or autistic spectrum disorder cannot be the primary reason the person needs care.

If you are uncertain about your service user bands, it is best to take some advice from the CQC, see: https://www.cqc.org.uk/guidance-providers/registration/service-user-bands.

If you intend providing personal care for people living with learning difficulties or autistic spectrum disorder, then you should complete a preapplication form and discuss your plans with the CQC. This is because they will require some additional assurances which relate to the way in which the service will be run, staff training and the training and experience of the registered manager:

https://www.cqc.org.uk/guidance-providers/autistic-people-learning-disability/right-support-right-care-right-culture

Summary

In this blog we have considered the nature of the activity and service user bands prospective registrants need to consider before applying to the CQC. We have seen how the activity must reflect the type of service the registrant intends providing, while the service user bands reflect the specialisms the service will offer.

Top tip: ensure that the regulated activity(ies) and service user band(s) selected are the same in all registration documents, e.g. the business plan, statement of purpose, application and RM application or the application will be returned.

In subsequent blogs in this mini-series we will explore how to write a business plan and statement of purpose, what policies you will need and how to prepare them for registration and how to prepare the prospective RM and NI for the registration interviews.

In these later blogs we will also explore some tips for successful registration and examine how Bettal can help make the whole process easier for health and social care entrepreneurs.

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, https://www.bettal.co.uk, or get in touch:

Email: info@bettal.co.uk
Telephone: 08085020539

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

Call on 01697 741411 or fill out the form below:

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