Your first CQC inspection as a private GP: evidence checklist
What to have ready for your first assessment, organised by the five key questions, and how the other UK regulators differ.
- England
The short answer
A newly registered private GP service in England has no rating until the CQC’s first assessment, and you cannot choose when it happens. Be ready to produce evidence quickly for each of the five key questions: safe, effective, caring, responsive and well-led. That means a clear evidence index, current policies you actually follow, audits, significant events and complaints with the learning, staff and recruitment records, and clinical records that show safe prescribing, results handling and communication with NHS GPs.
Key points
- The CQC decides when to assess a new service, based on risk. Run the service as though an assessment could start any week.
- Keep one evidence index mapped to the five key questions, with an owner and review date for each item.
- Inspectors of private GP services focus on prescribing, identity checks, safeguarding, results, information sharing with NHS GPs, and learning from incidents.
- Policies must describe what you really do. Generic templates that mention staff or services you don’t have count against you.
- The CQC covers England only. Healthcare Inspectorate Wales, Healthcare Improvement Scotland and RQIA inspect against their own standards.
What to expect
The CQC assesses registered services against five key questions: are they safe, effective, caring, responsive and well-led? Private GP services come under its “independent doctors” group, which also covers private clinics and online primary care. There is no fixed cycle. Assessments are planned by risk, or triggered by information of concern such as a complaint.
When an assessment starts, the CQC contacts you and may ask for documents straight away. A site visit is usually announced, but it can be unannounced. You get feedback at the end of the visit, a draft report to check for factual accuracy, and then a published rating that you must display at your premises and on your website. For the full process, see will the CQC want to inspect me?
Don’t expect it quickly. In May 2026 the CQC listed services registered for a year or more without an assessment among its priorities for primary care, which shows how long some new services wait. Plan as though it could be any week.
The framework is also changing. The CQC consulted on four sector-specific frameworks, including one for primary care and community services, and piloted them between June and October 2026. It said it would start to implement them at the end of 2026. The five key questions remain, so the evidence below stays relevant, but check the CQC website for the current guidance before you organise it.
Start with an evidence index
Create one index, as a spreadsheet or in a compliance tool, with a row for each piece of evidence. Give each row:
- the key question it supports
- where it is kept
- who owns it
- when it was last reviewed, and when it is next due
Anything older than a year without a review is a warning sign. A tidy index also makes a short-notice document request easy to answer.
Documents the CQC already has, and may ask for
Your registration application included a statement of purpose and policies on complaints, consent, equality and human rights, governance, infection control, medicines and prescribing, recruitment and safeguarding. Inspectors will compare what you do now with what you told them. For GPs and independent consulting doctors, the CQC also lists documents it might ask for, including:
- a business continuity plan
- a freedom to speak up policy
- a health and safety risk assessment, and a list of your other risk assessments
- a medical emergency policy
- a significant events policy
- a staff training matrix and staffing structure
If any of these has changed since registration, update it, and update your statement of purpose if your services have changed.
Safe: checklist
- Safeguarding policy, a named lead, and training at the right level for everyone, with certificates
- How you confirm identity, especially for remote consultations and for children
- Chaperone policy, trained chaperones and a record of offers
- Prescribing policy covering remote prescribing, controlled drugs and high-risk medicines, with monitoring you can show. See the prescribing checklist.
- Results management: every result seen, acted on and communicated, with a log of outstanding tests
- Emergency medicines and equipment set by a documented risk assessment, with regular check logs and expiry dates
- Vaccine fridge temperature records, and what you do when readings go out of range
- Infection prevention and control: a policy, audit, cleaning schedules, sharps, and clinical waste contracts and transfer notes
- Fire and health and safety risk assessments, COSHH assessments and equipment servicing records
- Significant events and near misses, logged with analysis and the changes made
- A process for acting on medicines and device safety alerts, with a record of what you did
- Recruitment files for everyone: identity, right to work, DBS, registration, indemnity, references and immunisation status
Effective: checklist
- How you keep up with NICE and other guidance, and evidence that you use it
- At least one completed clinical audit cycle, with a re-audit planned. See running a clinical audit.
- A records audit showing notes are complete and contemporaneous
- Consent processes, including for children and for patients who may lack capacity
- Information sharing with NHS GPs: consent recorded, letters sent, and what you do when a patient declines. See sending notes to the NHS GP.
- Induction, training records, appraisal and revalidation for every clinician
- Referral pathways and how you follow them up
Caring: checklist
- Patient feedback you have collected, and what you changed as a result
- Privacy and dignity in the consulting room and at reception
- Access to interpreters, and information in accessible formats
- Clear information about fees before care starts
Responsive: checklist
- A complaints procedure that is easy to find, with response times and a route to independent review. The CQC does not require ISCAS membership, but it expects providers without an independent review stage to review their complaints process regularly and consider adding one. See managing complaints.
- A complaints log showing outcomes and learning
- Appointment availability, and what patients should do when you are closed
- Reasonable adjustments and premises accessibility. See accessibility requirements.
- How you signpost patients whose needs you cannot meet
Well-led: checklist
- A current statement of purpose that matches the services you provide
- A registered manager in post, if your registration needs one
- Governance meetings, or for a solo GP a dated monthly governance log, covering incidents, complaints, audits, risks and actions
- Policies reviewed on schedule, with staff acknowledgement
- A risk register and a business continuity plan
- Duty of candour and whistleblowing (speaking up) procedures
- Statutory notifications to the CQC sent when required
- ICO registration, a privacy notice, data protection impact assessments and your information governance arrangements
- Current indemnity and insurance certificates
Show it from the records
Inspectors of independent doctors often review a sample of clinical records. Be ready to run searches that answer questions such as:
- Which patients take high-risk medicines, and are they monitored?
- How many results are outstanding, and for how long?
- Which patients declined sharing with their NHS GP, and what did you record?
- Were antibiotics prescribed in line with guidance?
A record system with coded data, searches and a full audit trail makes these answers quick. See systems that help you prepare.
Keeping evidence current
Most practices keep evidence in a mix of shared folders, a compliance platform such as QCS or GP TeamNet, and the clinical record. Some newer tools organise it around the inspection itself. A good example is Practice Control Tower, a CQC readiness register built on the five key questions. For each requirement it records the questions an inspector is likely to ask, your answer, an owner and the evidence. It rolls these into a red, amber and green readiness score, and flags evidence as stale after about 12 months. It is pre-launch and taking a waitlist, and it covers the CQC in England only.
When the assessment starts
- Read the request carefully and note the deadline.
- Send what is asked for from your index. Don’t send everything.
- Brief anyone who works with you on what to expect, and make sure they can find the policies.
- On the day, be open about gaps and what you are doing about them.
- Check the draft report for factual accuracy and send corrections with evidence.
Wales, Scotland and Northern Ireland
The CQC only covers England. The other regulators work differently:
- Wales: Healthcare Inspectorate Wales inspects independent clinics against the Independent Health Care (Wales) Regulations 2011 and national minimum standards. Its inspections may be announced or unannounced.
- Scotland: Healthcare Improvement Scotland regulates independent clinics, including private GP services, and publishes its inspection reports.
- Northern Ireland: RQIA registers and inspects independent clinics. Its guidance for private doctor services expects each doctor to have a responsible officer, and to know the GMC’s prescribing guidance.
Build your evidence index around your own regulator’s standards. Most of the evidence in this checklist will still apply.
Tools that can help
Frequently asked questions
How soon after registration will the CQC inspect me?
There is no fixed timescale. The CQC plans assessments by risk and responds to concerns, and some services wait more than a year for a first rating. Be ready from the day you open.
Do I need a compliance platform for a small practice?
No. A well-organised folder structure and an evidence index can work for a solo GP. Platforms save time as you add staff, services or sites.
Can I use bought-in policy templates?
Yes, as a starting point. Edit each one so it describes your service, staff and procedures, and remove anything that doesn’t apply.
What if I disagree with my rating?
Raise factual errors when you get the draft report. After publication, you can ask for a rating process review within 15 working days, but it looks at whether the CQC followed its process, not at the evidence again.
Sources
- Assessment framework
- Independent doctors: evidence categories (caring)
- How often we assess
- Improving how we work: May 2026 update
- Improving how we work: June 2026 update
- Extra documents: GPs and independent consulting doctors
- Regulation 16: Receiving and acting on complaints
- Independent hospitals, clinics and medical agencies
- Information for service providers: independent clinics
- Independent clinic: private doctors provider guidance 2026-27
