The CQC registered manager for a private GP service: who, when and how

A CQC registered manager is the person registered with the Care Quality Commission to manage a regulated activity day to day, and who shares legal responsibility with the provider for meeting the regulations. A private GP service in England needs one if it is run by a company or a partnership, or by an individual GP who is not fit to manage it or not in full-time day-to-day charge. A sole-trader GP who runs the service themselves does not.

What is a CQC registered manager?

Under the Health and Social Care Act 2008, the CQC can register a provider subject to a “registered manager condition”: the regulated activity must be managed by an individual registered with the CQC as its manager. The CQC describes the registered manager as the person in charge of the day-to-day running of regulated activities at a location. They share legal responsibility with the provider for meeting the regulations, and the CQC often uses them as its main contact for the service.

The registered manager is named for each regulated activity at each location. One person can manage more than one activity and location, and more than one person can manage the same activity, for example in a job share.

The legal duties

Regulation 7 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 says a person must not manage a regulated activity as a registered manager unless they are fit to do so. They must:

• be of good character
• have the qualifications, competence, skills and experience to manage the activity
• be able, because of their health and after reasonable adjustments, to do it
• be able to supply the information listed in Schedule 3 of the regulations

The CQC’s guidance adds that a registered manager should know the regulations and the consequences of failing to meet them. In a small private GP service, that means the manager owns governance in practice: policies, audits, incidents, complaints, recruitment checks and statutory notifications.

When does a private GP service need a registered manager?

Regulation 5 of the Care Quality Commission (Registration) Regulations 2009 decides this. A registered manager condition applies when the provider is:

• a company or other body, including a limited liability partnership (the CQC registers an LLP as an organisation)
• a partnership. The CQC says organisations and partnerships must have a registered manager for each regulated activity, unless the organisation is an NHS trust
• an individual who is not a fit person to manage the activity, or who is not, or does not intend to be, in full-time day-to-day charge of it

How you set up	Registered manager?	Nominated individual?
Sole trader GP who runs the service	No, if you are fit and in full-time day-to-day charge	No
Sole trader GP who will not run it day to day	Yes	No
Partnership of GPs	Yes, for each regulated activity	No
Limited company or LLP	Yes, for each regulated activity	Yes

If you are still choosing a structure, see should I set up a company?

Can a solo GP be the provider and the registered manager?

As a sole trader, you don’t need to. If you are fit to manage and in full-time day-to-day charge, the regulations do not impose a registered manager condition. You describe your own qualifications, skills and experience in the provider application instead. “Full-time day-to-day charge” is not defined further, so if you will also hold NHS sessions or another job, explain how the service is run when you are not there and check with the CQC how it will treat your application.

As a one-doctor company, yes. The company is the provider and must have a registered manager, and the GP director can apply for the role. The same GP can usually also be the nominated individual: the CQC’s application guidance says registered managers can act as nominated individuals, normally where the organisation is small.

In a partnership, a partner can sometimes be the registered manager. The CQC’s partnership guidance says partners who take the role need the experience, skills, qualifications and time to do it.

Nominated individual vs registered manager

• Nominated individual: required only when the provider is a body other than a partnership, such as a company (regulation 6). They must be a director, manager or secretary, and they supervise the management of the regulated activity on the organisation’s behalf. They are named in the provider’s application. A change of nominated individual must be notified to the CQC.
• Registered manager: manages the activity day to day, is personally registered with the CQC, and shares legal responsibility with the provider.

CQC manager registration: how to apply

CQC manager registration is a separate application made by the manager, using the CQC’s new registered manager application form. For a new service, it must go in at the same time as the provider application, emailed with everything else to the address on the CQC’s forms page. The CQC returns a provider application that arrives without the required manager forms. For the provider side, see how to register your private service with the CQC.

The manager needs to show they are fit for the role, understand the regulations and can meet the needs of the patients the service will see. The CQC says applicants must have proven management experience, and evidence of managing the needs of every patient group and age range in the provider application. You will need:

• your full work history from age 16, with any gap over four weeks explained
• contact details for your GP and your last employer
• copies of your qualifications and training
• an enhanced DBS certificate with the right barred list check (adults, children, or both if you see all ages), issued in the last 12 months

A GMC-registered doctor does not need a CQC-countersigned DBS check, but must post the original paper certificate. The CQC does not accept the DBS Update Service. A manager who is not a registered health professional, such as a practice manager, needs a CQC-countersigned check, which the CQC says can take up to 60 working days. Giving false or misleading information can lead to a fine of up to £2,500.

The interview, timescales and fees

The CQC reviews the application, asks for more information if it needs it, then contacts the manager to arrange an interview, which can be by phone, online or face to face. It decides by email. The CQC says its assessment is thorough and can take a few months, and you cannot manage regulated activities until your registration is confirmed. See how long CQC registration takes for planning.

The CQC charges registered providers an annual fee, which it says covers initial registration and changes to registration. Its fees pages do not list a separate fee for a manager application.

When a registered manager leaves or is absent

A registered manager condition is a condition of your registration, and failing to comply with one without reasonable excuse is an offence under section 33 of the 2008 Act. So plan for a vacancy before it happens.

• Tell the CQC. Regulation 15 of the 2009 Registration Regulations requires written notice as soon as reasonably practicable when a registered person stops managing the activity, or someone else starts to. The provider uses the CQC’s “changes to registered details: registered manager” notification form.
• Cancel and replace. The outgoing manager applies to cancel their own registration, and the new manager makes a full new manager application. Update your statement of purpose, which must name each registered manager.
• Absences of 28 days or more. Under regulation 14, give written notice at least 28 days before a planned absence of the registered manager, or of a sole-trader provider in day-to-day charge. Include who will manage the service meanwhile. Notify an emergency absence within 5 working days, and the return within 7 working days.

Practical checklist

1. Decide your legal structure, and from it whether you need a registered manager and a nominated individual.
2. Choose the manager and check they can show management experience across every patient group you will see.
3. Get the enhanced DBS certificate with the right barred list checks, and keep it under 12 months old at submission.
4. Gather the work history, qualifications and referee details.
5. Complete part 4 of the statement of purpose for each registered manager.
6. Send the manager application with the provider application, in one submission.
7. Prepare for the interview: know the fundamental standards, your policies and how you will send notifications.
8. Write down who covers if the manager is away for 28 days or more, and how you will notify the CQC.

Once registered, the manager is the person the CQC will expect to explain your governance at your first assessment. See the first inspection evidence checklist. Many practices give each requirement an owner in a shared folder or a compliance platform such as QCS or GP TeamNet. A good example built around the inspection itself is Practice Control Tower, a CQC readiness register organised by the five key questions, which gives each requirement an accountable owner, your answers and the evidence. It is pre-launch with a waitlist open, and covers the CQC in England only.

Wales, Scotland and Northern Ireland

• Wales: Healthcare Inspectorate Wales registers independent clinics under the Care Standards Act 2000 and the Independent Health Care (Wales) Regulations 2011. Regulation 11 requires a manager where the provider is an organisation, is not fit to manage, or is not in full-time day-to-day charge. A new registered manager applies to HIW with references, a medical reference, an HIW-countersigned DBS check and a £100 fee. HIW says an outgoing manager must apply to cancel their own registration, or they remain legally liable for the service.
• Scotland: Healthcare Improvement Scotland regulates independent clinics. The provider tells HIS about a new registered service manager through its eForms notifications system at least 10 working days before the change, and gives at least 14 days’ notice of a planned manager absence of more than 28 days.
• Northern Ireland: under the Independent Health Care Regulations (Northern Ireland) 2005, a manager must be appointed where the provider is an organisation or partnership, is not fit to manage, or is not in full-time day-to-day charge. Managers register with RQIA, and applications go through the RQIA Web Portal.