Care Quality Commission - Enforcement re Non-Compliance

The Care Quality Commission may take action against practices that do not comply with CQC registration and regulatory requirements.


These registration requirements, for example registration of location(s) or details of partners and any changes or changes in regulated activities, were put in place when GP practices were first registered with the CQC.


Prior to December 2015 General Practice had largely been immune to any type of financially based behaviour modification and had simply had to pay an annual registration fee and submit to the CQC inspection programme.  Other regulated sectors had seen fines imposed for non-compliance with registration requirements, and those fines could be substantial.


The CQC does have a corporate ethos under which it commits to act in a proportionate way and only after a due process has been followed  it has a detailed enforcement policy which sets out the principles and approaches adopted by the CQC when using its enforcement powers.


The main risk areas under which penalty fines might be imposed on practices are within the registration process and particularly when changes to registration details are required.


The CQC has received steady criticism that its registration processes are complex and time-consuming and have sought to improve these.


The CQC website has details of the processes that practices need to follow to notify changes to location, partnership details or regulated activity.


The LMC recommends that practices should ensure that all contacts with the CQC, particularly any enquiries about, or attempts to make any changes to, their practice registration details or regulated activities are noted, and practices should keep a record of such contacts in a form that can be evidenced, if necessary, in the future.  This approach will enable the LMC to better support any practice should the CQC prior to, during or post inspection, have cause to query what, if any, actions have been taken to resolve any outstanding issues relating to registration.


The LMC does have a positive liaison relationship with the CQC locally and CQC regulators are well aware of the significant workload pressures currently affecting General Practice.  However, CQC inspectors and managers are obliged to follow central policy approaches and documenting evidence of practice contacts with CQC assists in ensuring a proportionate approach to CQC decisions.


Practices should check to ensure that they are appropriately registered and, if not, try to resolve the situation as soon as possible and be seen to be taking such action.

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Updated on Wednesday, 20 September 2017


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