Is CQC registration in your business plan?
35-37 AM APRIL22 CQC registration edit.indd
Launching a new business can leave you feeling swamped with both excitement and fear. However, having a firm business plan from the offset will serve to highlight potential opportunities and, conversely, prepare for any issues. A business plan serves as a road map, helping direct a clear set of goals, and can be a useful tool at the start of a new venture.
When writing a business plan to open an aesthetic clinic, there are many factors to consider: the building, the décor, portfolio of services to offer and recruiting the team. Registering with the healthcare regulator may not be high on the agenda, but why not?
Let’s explore why some practitioners do not view registration with the Care Quality Commission (CQC) as a priority, in a bid to better understand how approaching registration with a firm strategy and tackling it in small stages avoids the feeling of being overwhelmed.
BENEFITS OF CQC REGISTRATION
CQC registration is often depicted as a challenging and complex process. However, once completed, it can offer the opportunity to add further medical services to the business portfolio and give the team added assurance of safety.
The CQC describes its function as ensuring that “the care provided by any healthcare provider is safe”. Once registration has been achieved with the healthcare regulator, a medical establishment can offer a wider portfolio of treatments and services. This can also make the business a more desirable environment to work in by providing the opportunity to recruit further medical and nursing professionals to the team, specifically those who require registration to practice.
Registration for intent to offer regulated services is not an overnight process, and embedded into the business plan should be realistic timelines. It takes on average three to four months to achieve registration.
AN INSPECTOR CALLS
An important point to highlight is that registration is only the first part of the process. Once registration for the intent to offer regulated services has been granted to the business, within six to 18 months, the healthcare regulator will inspect the service. This is a more thorough inspection as it is at this point the business will need to offer the regulator assurance that it meets the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.
Following this inspection, a rating is awarded to the business. This is an important part of the journey, as the ratings can vary from “Inadequate” to “Outstanding”, and in our experience, all businesses want to aim for the highest rating. To achieve “Good” in a private aesthetic clinic is extremely commendable as to achieve “Outstanding” is almost impossible due to the complex nature of the inspection framework in which assessment is made.
The CQC sets out what patients can expect from healthcare providers registered with the CQC, which is examined during a rating inspection. These include being treated with respect, being involved in decision making, and being told what is happening at every stage of a treatment plan.
It is important that the registered manager understands this, and there is an expectation that they will have oversight of the activity and performance of their business. The inspector will want to see evidence of how the registered manager monitors the quality of their service, whether funded through the NHS or privately.
MY OWN EXPERIENCE
When I opened my own medical aesthetic clinic in 2020, becoming CQC registered was an important part of my business plan. The reasons for this were twofold; I wanted to distinguish my business as a medical facility, and I also wanted to have the opportunity to offer a range of medical services that are deemed within the scope of registration.
Registration for the clinic was successfully obtained within two months of opening the doors. This meant that we were not only able to offer the medical services planned, but more importantly, the clinic team embraced all of the governance rules and regulations required from the outset. These include daily checks to evidence good practice, such as monitoring medical fridge temperatures, room temperatures, and emergency drug expiry dates, all of which have become part of our daily routine. These are important and not to be seen as task exercises as they not only evidence safe practice but also ensure that the medication on site is stored in the most appropriate and safest manner.
Some practitioners enter the world of aesthetic medicine from previous junior roles within the National Health Service (NHS), whereby they may never have had clinical governance responsibility. Understanding what happens to daily checklists and how this is then transferred to audit data to evidence positive practice or areas for improvement is vital.
An audit is integral to safe practice and is a process used by health professionals to assess, evaluate and improve the care of patients in a systematic way. The audit measures current practice against a defined (desired) standard. This is a skill we teach our clients to embed into their business infrastructure.
The team has embraced a culture of incident reporting, which is prevalent in the NHS but not always evident in private practice. It is important to encourage an open and learning culture, so staff feel supported when things go wrong.
Incident reporting is an ideal opportunity to learn from any experience to improve the service. It typically involves completing an incident report form when an incident occurrence has happened and following it up with an investigation. This aims to ensure that the incident causes are investigated to potentially mitigate against them with the aim to prevent the same type of incident from happening in the future. This is an important area that will have to be evidenced during a CQC inspection.
No service should present itself as perfect. In any area where a number of patients attend for treatment, there is the opportunity to learn from errors, omissions or minor environmental issues, all of which should be documented and shared at team meetings with evidence that learning has taken place. Incident reporting is important as it supports clinicians to learn about why patient safety incidents happen within their own service and organisation and what they can do to keep their patients safe from avoidable harm.
Being an NMC-registered nurse alongside a regulation consultant has placed me in an ideal position to help others understand the regulation process. However, during my own experience, this did not reduce the nerves prior to the registration interview, which took three hours.
We have worked with a variety of medical and nursing professionals who are at varying stages in their careers, but the interview is always viewed with trepidation. Examples of interview questions will include “how does the registered manager ensure that safeguarding all patients will be a priority?”. This includes articulating how assurance can be given that the team understands how to escalate and report a concern. This aligns with the key line of enquiry of being safe.
At the point of the registered manager interview, part of our service includes carrying out a mock interview and full facility inspection, thereby ensuring that our clients are briefed on what will be required and have had time to ensure the environment is fully prepared.
There have been cases of aesthetic business owners prosecuted for offering regulated services to the public without healthcare registration in place. There have been cases where clinic managers have been prosecuted by the regulators and reported to their governing bodies.
This highlights that it should be a high priority for anyone who owns an aesthetic business to review their service against the scope of registration to be assured that they do not require CQC registration. The CQC calls unregistered professionals to account if they are found to be offering regulated services.
It is now 16 months down the line, and I am preparing for an upcoming rating inspection. This has required dedication and an in-depth review of the service. A key point that has become a focus is how we evidence wider engagement with both our local community and local charities. Charitable engagement can allow the business to take active interests in your own community and can also lead to respect within the area. This is important for the regulator as it demonstrates leadership and social responsibility, an area often overlooked. If you are considering registration with the healthcare regulator or preparing for an upcoming inspection, it might be worth considering the support of an external consultant. It can be a daunting process if there is not someone to offer support and assurance.
Care Quality Commission:
Key lines of enquiry, prompts and rating characteristics for healthcare services (2018) is available here.
Tracey Jones RN, BSC (Hons), MSc, SFHEA is a regulation consultant at Inspire to Outstand. Inspire to Outstand is a team from Cheshire that supports businesses moving forward with Care Quality Commission registration and inspection. Between them, they have more than 35 years’ career credentials in healthcare and regulation.
