By April 1, 2011 all NHS, private and mixed dental practices are required to have register with the independent regulator, the Care Quality Commission. The registration period began in November with a four week window given to those practices who have already pre-registered. Registration isn’t voluntary and those dental practices that haven’t registered will be trading illegally. If you haven’t pre-registered online yet, you should do so immediately. If you do not have access to the internet, you can call CQC on 03000 616161 and arrange for postal registration.
The general consensus among members of the dental profession seems to be that CQC registration is another time consuming administrative procedure for an already over-regulated industry. Yes, we are ridiculously over-regulated, and yes, registration and subsequent compliance will require a large proportion of our time over the coming months. However, in the long term, CQC compliance could have a positive outcome. The truth is, it has been on the cards for a long time. First, care homes registered with the healthcare commission. Then came laser registration, last year NHS trusts registered with CQC, dentistry now and medics will have to register next year.
At present, dentists are subjected to compliance requirements which can vary depending upon where they practise. Primary care trusts up and down the country have different approaches and expectations of the practitioners that fall under their administration and this often results in much confusion. If you are a practice in Cornwall, you can expect a different set of PCT compliance standards to someone who works in Newcastle. What CQC proposes to do is to standardise the experiences patients receive at primary care dental practices, encourage consistency, enable comparison and improve overall standards of care for all. This will mean that when the system is fully established, practice owners and managers should have less red tape to deal with and any regional inconsistencies should be ironed out. In other words, everyone will be ‘reading from the same page’, aiding coherence and clarity.
It has to be said that the CQC inspectors will also have a steep learning curve. What this means is at first they are likely to be more prescriptive, saying ‘this is how I was taught you should do it so this is how you will do it’. But with experience as they learn our profession they should see how essential standards can be achieved in different ways. This was the experience in other regulated industries such as financial services.
What’s more, CQC has informed CODE it is certainly not in the business of closing practices down. Its inspectors acknowledge there may be some work to be done before practices fully achieve essential standards of quality and safety. So, as long as non-compliances are noted in the application, and there is a smart action plan to achieve compliance, it will not be a concern of the CQC. However if you state you are compliant and you are not, this is illegal.
You can expect once you submit your application that you may be asked for supporting documentation and you may not have much time to supply it, so make sure you are fully prepared.
There are likely to be some areas of compliance that need improving, no matter which areas of your business need work, so now is certainly the time to act.
Here are some action points:
- All practice staff must have an enhanced Criminal Records Bureau check. Providers, nominated individuals and registered managers must have one through CQC. Nurses, receptionists, practice managers and so on should choose an umbrella body from the CRB website.
- Providers and other staff can use a CRB check if it has been countersigned by the PCT although registered managers will need a new one through CQC (unless the provider is also the registered manager).
- Care Quality Commission is expected to release its fees for registration in February 2011. CODE estimates it will set practice owners back around £1,000 to £1,500 each year.
- NHS practices could wait up to two years before their first inspection.
- Private practices are likely to have their first inspection within three months of registration.
- If the PCT is concerned about a practice, they will receive an earlier visit from the CQC inspector.
- As well as visits, dental practices may be asked to supply pieces of evidence such as documentation. This will enable the commission to see which areas of practice management might need improving. You may not be given much time to supply it.
- Using this intelligence, along with information from other sources such as the GDC and patient complaints, CQC will compile a ‘risk profile’ for each practice.
- Obtaining reliable external accreditation such as the CODE Quality Mark will demonstrate to CQC that the practice is serious about maintaining standards, thus helping to improve the CQC risk profile.
Practice owners and managers are strongly advised to respond positively and quickly to any request they receive from CQC. The process will be ongoing and practice owners will be expected to ‘play ball’ with CQC, putting systems into place and improving standards as and when required. This attitude will stand the practice in good stead, but those practices that fail to respond will soon find themselves having to answer to the inspectors and can be closed down.
For this reason CODE has launched CODE Assure. The service uses CODE’s in-depth knowledge of clinical governance and management to help practice owners gain compliance through either a one-day consultancy visit or a complete three-day ‘hand-holding’ service. For those who would like ongoing support after registration to achieve continuing compliance, the CODE Assure Accreditation programme is also available which leads to the CODE Quality Mark.
To contact CODE call 01409 254 354 or email info@CODEuk.com You can follow Paul Mendlesohn on twitter at twitter.com/paulCODE and join him on Facebook at facebook.com/mendlesohn