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​Healthcare Federations: Who has to Be Registered with the CQC?

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There is some confusion about which bodies, people, or healthcare providers (collectively known as ‘entities’) need to be registered with the CQC in order to remain compliant and continue to act within the law. Of particular concern to many is registration of those acting within a healthcare federation (a group of providers that are working together under a single umbrella). These concerns are hardly surprising, especially when the RCGP believes that the future of primary care will be best served by GP practices forming such federations.

However, not all federations need to be legal entities, and if not formed as such won’t need to register with the CQC. In this case, the requirement to register depends upon how the federation’s activities are conducted.

Why form a federation?

The basis for forming a federation is to provide better quality and more rounded care and treatment to patients. When regulated activities are provided by other members of such a federation, they are usually provided by someone who is already registered. However, a grey area exists when treatment is provided by a healthcare worker (for example, a GP) at a premises that is not their own. In such circumstances, it might be assumed that the provider would have to add the second location to its list of locations under its own registration. But there are ways in which this supposed requirement can be avoided.

How to organise a federation and streamline onerous CQC registration

There are two ways in which federation can be formed without becoming a legal entity and having to adhere to the onerous CQC registration requirements.

The first of these is as a ‘patient-led’ federation. This effectively means that any doctor that sees a patient does so under the direction and control of the GP practice with whom the patient is registered. This means that other locations do not need to be added to any of the federation’s participants, as each participant is responsible for the care and treatment given to its patients, irrespective of who administers that treatment.

The onus, therefore, falls on individual providers to ensure they are comfortable with the fitness of healthcare professionals from other providers within the federation.

The second way of organising the federation without forming a legal entity is as a ‘premises-led’ federation. In this type of arrangement, the provider that runs the practice in which the patient is seen is deemed to be responsible. In this type of arrangement, a healthcare professional might see patients in any premises, but must follow practices, processes, and procedures of the provider who owns that premises.

Make sure everyone knows under which arrangement the federation operates

Key to ensuring that you operate within these guidelines is to agree and document the arrangement between all providers within the federation. This will identify who the registered provider of the regulated activity is in all cases, and confirm on whom responsibility falls.

More information

In the current environment that encourages federation-based provision of healthcare, it is important to make certain that your practice, its employees, and the other healthcare providers within the federation are aware of their responsibilities and under which rules they are operating. The CQC has produced two case studies that further explain these options, and also invite questions and requests for further guidance from providers before they enter into any collaborative agreement with other providers. You can contact the CQC with any questions about models of care by emailing them at mailto:enquiries-newmodelsofcare@cqc.org.uk.

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