CQC notifications for private GPs: notifiable events, deadlines and how to report

CQC notifications are the statutory notifications every registered provider must send the Care Quality Commission when certain events happen. For a private GP that means telling CQC without delay about a patient death linked to your care, a serious injury, abuse or an allegation of abuse, an incident involving the police, or anything that stops you running the service safely, and giving notice of changes such as a new or absent registered manager. Failing to notify is a criminal offence, and Wales, Scotland and Northern Ireland have their own lists and fixed deadlines.

What are CQC notifications?

The Care Quality Commission (Registration) Regulations 2009 list the changes, events and incidents a provider must report, and the deadline for each. CQC uses notifications to know what is happening in a service, spot concerns, decide whether to take regulatory action and monitor trends.

The duty sits with the registered person: the provider (you as an individual, your partnership or your company) and any registered manager. You can delegate the task, for example to a practice manager, but CQC is clear that you stay responsible and accountable, so the delegation needs to be written down and work when you are on leave. See the CQC registered manager for a private GP service.

CQC notifiable events for a private GP service

Event	Regulation	Deadline
Death of a patient while you were providing care, or which has or may have resulted from your care	Regulation 16	Without delay
Serious injury to a patient (see the definition below)	Regulation 18(2)(a) and (b)	Without delay
Abuse or an allegation of abuse involving a patient	Regulation 18(2)(e)	Without delay
Any incident reported to, or investigated by, the police	Regulation 18(2)(f)	Without delay
An event that stops, or is likely to stop, you running the service safely: not enough suitably qualified staff, loss of electricity, gas, water or sewerage for more than 24 hours, premises damage that affects care, or fire alarms or other safety devices failing for more than 24 hours	Regulation 18(2)(g)	Without delay
The registered manager (or an individual provider in day-to-day charge) will be away for 28 days or more	Regulation 14	At least 28 days before; within 5 working days if it is an emergency; return to duty within 7 working days
Changes: someone else manages the service, a registered person stops, a name change, a change of partners, a company name or address change, a new director or nominated individual, or bankruptcy, receivership or liquidation	Regulation 15	As soon as reasonably practicable

Regulation 18 also covers Deprivation of Liberty applications and the placement of under-18s in adult psychiatric units, which will rarely apply in general practice.

Deaths: the private GP test is wider than the NHS one

NHS GP practices have a narrower test in regulation 16(2): they notify a death linked to primary medical services provided in the two weeks before it, and only where the death cannot reasonably be attributed to the natural course of the illness with appropriate care. That test is defined by reference to NHS contracts under the National Health Service Act 2006. A purely private service falls under regulation 16(1), which on its face requires you to notify any death that happened while you were providing care, or that has or may have resulted from it, with a description of the circumstances. In practice that means a death during a consultation or home visit, or one where your assessment, prescribing or follow-up may have played a part. If you also hold an NHS contract, check which test applies to which service.

What counts as a serious injury

Regulation 18 covers an injury which, in the reasonable opinion of a health care professional, has caused an impairment of sensory, motor or intellectual function that is not likely to be temporary, changes to the structure of the body, prolonged pain or psychological harm, or a shortened life expectancy. It also covers an injury that needs treatment to prevent death or one of those outcomes. "Prolonged" and "not temporary" mean 28 days or more. CQC's guidance lists examples including damage to sight or hearing, major organs, bones, muscles or tendons, and psychological harm such as post-traumatic stress disorder, clinical depression or anxiety.

Medicines errors and infections

CQC says to notify a medicines error only if it causes one of the notifiable events (abuse, death, a police incident or serious injury), and to say in the form that a medicines error was a known or possible cause. Outbreaks of infection go through the notifiable diseases reporting route on GOV.UK rather than a CQC form.

How to notify CQC of an incident

1. Make the patient and service safe first, and escalate to the police, safeguarding team or emergency services where needed.
2. Decide whether it is notifiable against the table above, and record your reasoning either way.
3. Use CQC's form for that notification type. The most common ones can be sent through the CQC provider portal; others use a Word form that you download and email back. CQC updates the forms often, so download the current version each time.
4. Don't identify the patient. Use a unique code instead of their name, date of birth or NHS number, and keep the key to that code securely in your own records.
5. Keep the reference number. The portal issues one automatically; for Word forms CQC emails an acknowledgement with one. Quote it in any follow-up.
6. Close the loop internally: log the notification, the investigation and the learning in your significant event process.

CQC notification requirements for GPs: private versus NHS

If you have worked in NHS general practice, three differences catch people out:

• No reporting shortcut. NHS trusts can route some incidents through the NHS patient safety reporting system (LFPSE) instead of notifying CQC directly. As a private provider you send everything directly to CQC.
• Police incidents count. The exemption from notifying police incidents applies only to English NHS bodies, not to private providers.
• The death test is broader, as explained above.

Some changes, such as adding a regulated activity or a new location, need an application to vary your registration rather than a notification. See whether you need different CQC registration for different services.

What happens if you don't notify

CQC states that it is an offence not to notify a relevant change, event or incident. For regulations 15 and 18 it can prosecute directly, without first serving a warning notice, and can also take other regulatory action. It must refuse registration if a provider cannot show it can and will comply.

Notifications in Wales, Scotland and Northern Ireland

Wales (HIW)

Registered independent clinics and independent medical agencies notify Healthcare Inspectorate Wales under regulations 30 and 31 of the Independent Health Care (Wales) Regulations 2011. Deaths, serious injuries, infection outbreaks, allegations of misconduct and Deprivation of Liberty requests must be notified within 24 hours, and a verbal notification must be confirmed in writing within 72 hours. HIW reads "serious injury" broadly: any incident where a patient attends or is advised to attend hospital, needs treatment by a doctor or qualified nurse, or is a Never Event, plus medication errors that need further assessment or treatment. You send a Part A form, then a Part B on actions and learning, through Objective Connect. HIW accepts notifications only from the registered manager, the responsible individual and up to six authorised individuals you have named in advance.

Scotland (HIS)

Healthcare Improvement Scotland's June 2024 guidance lists 31 notification types, submitted through its online portal. Unexpected deaths, allegations of misconduct and public protection concerns must be notified within 24 hours. Serious injury or complication, drug errors, controlled drug incidents, police incidents, events threatening the service and outbreaks involving two or more people have two working days. Notice periods apply too: one month before you introduce controlled drugs (including private prescribing of Schedule 2 to 5 drugs dispensed at a community pharmacy), 14 days before a planned manager absence of more than 28 days, and three months before a change of address. A change of legal entity, such as moving from sole trader to limited company, needs a new registration application.

Northern Ireland (RQIA)

The Regulation and Quality Improvement Authority registers private doctors as a category of independent clinic and publishes guidance on statutory notification of incidents and deaths for registered providers, alongside provider guidance specific to private doctors. Read the current version before you open, and confirm the event list and deadlines with RQIA.

Build notifications into your governance

• A short notifications policy naming who submits, who deputises and which regulator's list applies
• An incident log with columns for "notifiable?", the regulation, the date sent and the reference number
• Regulator portal access set up for at least two people before you need it
• Notifications reviewed at your governance meetings, with themes fed into audit. See clinical governance in private practice.
• Planned absences of the registered manager diarised at least 28 days ahead

Your notification record is part of the governance evidence you will want ready for inspection; see the first CQC inspection evidence checklist. Many practices manage this with a spreadsheet or policy and compliance content from providers such as QCS. In England, another option is Practice Control Tower, currently waitlist only, which keeps a single register of CQC requirements organised by the five key questions, with an accountable owner and the evidence behind each, and flags evidence as stale after about 12 months. It covers CQC only, not HIW, HIS or RQIA.