CQC Registration and the Transforming Community Services Programme

With the introduction of the Transforming Community Services (TCS) Programme, some healthcare organisations are confused about their responsibilities in relation to the Care Quality Commission (CQC). The Care Quality Commission is the body charged with regulating all Health and Social Care organisations in England, ensuring that they are achieving and maintaining suitable standards to allow them to deliver safe and high quality care. The TCS programme means that all PCTs are now dividing their provider and commissioning functions; most have achieved this by moving their community services to other 'receiving providers', some are forming new community Trusts, whilst others are merging with existing acute Trusts. Whichever way the PCTS are conforming to the new requirements, they will also have to conform to the requirements of the CQC, which means registering receiving providers and cancelling PCT registrations.

If you are operating as a receiving provider, then by law you must make an application to either vary your existing CQC registration or you must apply for new registration for the regulated activities that your service will be providing. Any individual, partnership or organisation that carries out a regulated activity without gaining CQC registration will be doing so unlawfully so it is vital that the correct and adequate registration is sought immediately.

There are specific registration requirements depending on the way in which the community services are provided, for example if your organisation has merged with a Mental Health Trust the considerations for registration may be slightly different than if you are a Social Enterprise or Community Interest Company.

Thankfully the Care Quality Commission provides full guidance on their website to ensure that all providers are getting it right. However, in brief there are four key points that organisations need to consider when deciding whether they need to apply for new registration or vary conditions of registration.

1. What regulated activities are being provided within the community service framework?
2. Is the organisation already registered to deliver these regulated activities?
3. What locations are these regulated activities being carried out within and are these locations already registered?
4. Is there a need for a registered manager, and is there already one in place?

Answering each of these questions in turn will help services define exactly how to approach their CQC registration.

All PCTS that will no longer be providing regulated activities as a result of the shift to TCS will be required to cancel their CQC registration, formally notifying the CQC once the service transfer date has been confirmed.

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