CQC notifications: what private GPs must report, when and how

CQC notifications are statutory reports that every registered provider in England must send to the Care Quality Commission when certain events happen. These include a death or serious injury linked to your service, an allegation of abuse, a police incident, an event that stops you running safely, and changes to who runs the service. Most must be sent without delay on CQC's own forms, and failing to notify is a criminal offence.

For a small private GP service, few of these events will ever happen. But the ones that do tend to arrive at a bad moment, so it's worth deciding now who submits them and how. This guide covers England in detail. The rules in Wales, Scotland and Northern Ireland are summarised further down.

What are CQC notifications?

The duty to notify comes from the Care Quality Commission (Registration) Regulations 2009. Regulation 12 covers changes to your statement of purpose, 14 covers absences, 15 covers changes to the provider, 16 covers deaths and 18 covers other incidents. Regulation 22A says notifications under regulations 14 to 18 must use the forms CQC provides. CQC calls these statutory notifications. It uses them to keep track of what is happening in a service, spot concerns, decide whether to take regulatory action and monitor trends.

Who has to submit them

The duty falls on the registered person. That means the provider (an individual, partnership or organisation) and any registered manager. You can delegate the task, for example to a practice manager. CQC is clear that you remain responsible and accountable, so you need clear, effective delegation arrangements. If you are a sole GP who is both provider and registered manager, that responsibility is yours. See the CQC registered manager role.

CQC notifications list for private GPs: what to report and the deadlines

Death of a patient (regulation 16)

Regulation 16 has a narrower test for providers of primary medical services, but the regulation defines those as services under NHS contracts and arrangements. A private-only GP service falls under the general rule instead. You must notify CQC of the death of a patient that happened while you were providing the service, or that has or may have resulted from it. The notification must describe the circumstances. In practice, the death of a patient you saw months ago for something unrelated isn't notifiable. A death where your care may have played a part, such as a delayed diagnosis or a reaction to treatment you gave, is.

Serious injury (regulation 18)

An injury is notifiable if, in a health care professional's reasonable opinion, it has caused, or needs treatment to prevent:

• death
• impairment of sensory, motor or intellectual function that is not likely to be temporary
• changes to the structure of the body
• prolonged pain or prolonged psychological harm (expected to last at least 28 days)
• shortened life expectancy

In a GP setting, think of a patient who needs emergency treatment after a serious reaction in your clinic, or a fall on your premises that causes a fracture.

Abuse, police incidents and events that stop you running safely

You must notify CQC of any abuse or allegation of abuse involving a patient, including sexual abuse, physical or psychological ill-treatment, financial abuse and neglect. Notify it even if it is unproven. A CQC notification doesn't replace a safeguarding referral to the local authority. You must also notify any incident that is reported to, or investigated by, the police, such as an assault in the waiting room or stolen prescription pads.

Events that stop, or seem likely to stop, you running safely include:

• not having enough suitably qualified staff, for example when your only other GP leaves and you can't cover clinics
• loss of electricity, gas, water or sewerage for more than 24 hours in a row
• damage to the premises that affects care
• fire alarms or other safety devices failing for more than 24 hours

Absences and changes (regulations 14, 15 and 12)

If the registered manager, or a provider who runs the service day to day, will be away for 28 days or more, tell CQC at least 28 days before. The notice must say how long the absence will last, the reason, the cover arrangements and who will manage the service. For an emergency absence, the deadline is 5 working days. Tell CQC within 7 working days when the person returns. Notify changes to the partners, directors, nominated individual, name or address as soon as reasonably practicable. Send any revision of your statement of purpose within 28 days.

What you don't need to notify CQC about

• Medicine errors: only if the error leads to a notifiable event (abuse, death, a police incident or serious injury). Say in the notification that a medicine error was a known or possible cause.
• Infection outbreaks: CQC refers providers to the GOV.UK guidance on notifiable diseases instead.
• Routine complaints: not as such, unless the complaint describes something on the list, such as an allegation of abuse. See managing patient complaints.

The route that lets incidents reach CQC through the NHS patient safety reporting system applies only to NHS trusts and NHS Blood and Transplant. Private providers notify CQC directly.

How to submit a CQC notification

1. Use CQC's forms. Deaths, allegations of abuse, events that stop a service running safely and serious injuries can be submitted on the CQC provider portal. Other notifications go on a Word form that you download and email to CQC. Always download the latest version.
2. Set up portal access early. Nominated individuals, main partners and registered managers can create an account using an email address CQC holds on record. Nominated individuals and main partners can then give colleagues access to submit notifications.
3. Protect the patient's identity. Don't include the patient's name, date of birth, NHS number or other unique details. Use a code, and keep a secure record of who it refers to.
4. Describe what happened. Include the circumstances, any contributing factors and the action you have taken.
5. Keep the reference number. The portal gives one automatically. For an emailed form, CQC sends an acknowledgement with a reference. Quote it in any follow-up.

What happens if you don't notify CQC

Breaching regulation 12 or regulations 14 to 20 is an offence. On summary conviction, the fine can be up to level 4 on the standard scale. CQC can instead offer a fixed penalty notice: £1,250 for a provider and £625 for a registered manager for each notification you failed to make. For regulation 18, CQC says it can go straight to prosecution without first serving a warning notice. In one published case, a care provider paid three £1,250 penalties, £3,750 in total, after inspectors found two abuse allegations and a police incident in its records that had never been notified. Inspectors can compare your incident log with what CQC has received, so treat notifications as part of your inspection evidence.

Notifications in Wales, Scotland and Northern Ireland

If your service is registered in one of these nations, read that regulator's guidance in full. The lists and deadlines differ from CQC's.

Building a CQC notifications process

• Write a short notifications policy. Name who decides whether an event is notifiable, who submits it and who covers when they are away.
• Add a "notifiable to CQC?" field to your incident and significant event log, and record the reasoning behind each decision.
• Make sure at least two people have provider portal access and know where the Word forms are.
• File reference numbers, and any follow-up correspondence, with the incident.
• Review notifications in your governance meetings. See clinical governance in private practice.

Many practices keep this in a spreadsheet or a policy library such as QCS. Another option is Practice Control Tower, a CQC inspection-readiness register that is currently waitlist-only. It organises CQC requirements by the five key questions and records an accountable owner and evidence for each one. It also flags evidence as stale after about 12 months. It covers CQC only, not HIW, HIS or RQIA.