CQC Applications – Common Problems

Since it became a legal obligation for dentists to register with the CQC on 1st April 2011, the application process has evolved to become a bureaucratic nightmare for most applicants.

The form to register as a new provider has now been merged with applications to register as an Organisation, Partnership or Individual – a whole 67 pages.

Ancillary forms are often required to be submitted at the same time including the application to register a Registered Manager (22 pages) and the Statement of Purpose, parts one to four (12 pages).

A total of 101 pages!

I have been assisting dentists with their applications since 2011 and here are the top five questions I have been asked:

How do I get a DBS check?

DBS checks have replaced the more commonly known enhanced CRB checks.

You must get a DBS check via the CQC countersigned by them and it must not be more than 6 months old when you submit your application.  You can obtain one at https:/cqc.disclosures.co.uk/.

There are agencies which can provide DBS checks which are often cheaper and quicker.  Whilst acceptable for the purposes of recruitment (eg dental nurses, associate dentists and therapists) they will not be accepted when submitted with your CQC application. 

Enhanced DBS checks can take over four weeks to be processed.

If you will be treating the whole of the population (as is the norm under a GDS Contract), please ensure that when you are registering for your DBS check, you indicate you will be working with both children (POCA) and vulnerable adults (POVA).  I have recently come across a number of applications which have been rejected as a result of the wrong groups being applied for.

When should I start the process when buying or selling a dental practice?

The common misconception is that you should start the process as soon as possible but this is not always the case.  You should always seek the advice of your solicitor as the CQC application needs to be tied-in with your sale/purchase. 

If you apply too early, the CQC will reject your application and you must remember that your DBS check will only be valid for applications of they are no more than 6 months old.

Your application should be submitted roughly 10 weeks before you are due to complete.  A good indication of when to apply for your DBS check and start completing the CQC forms is when all the replies to the business and property enquiries have been sent to the buyer’s solicitor – or received from the seller’s solicitor.

Who do I put down as a referee?

The application form states that your referee must be your last employer and if you do not have a last employer then your referee:

Must not be related to you

Must be able to provide a reference as to your competence to provide the service

Must have employed or worked with you for a period of three months

If you are selling or buying a practice, finding a suitable referee could be difficult.

From a seller’s point of view, you may not want to ask a colleague to provide a reference if your team do not know about your intention to sell the practice.

From a buyer’s point of view, you may not have given notice to your principal and would not feel comfortable in asking them to be your referee.

In both cases, I would suggest asking your accountant and inserting their details.  They know your financial background and your ability to maintain your income working as a dentist.

I am currently being investigated by the GDC.Will this have an effect on my application?

Unfortunately – yes. 

You must give a declaration within the form and confirm whether or not you are currently or have been in the past, subject of any investigation or proceedings by any professional body regulating dentistry – which obviously includes the GDC.

If the GDC investigation is historical then you simply need to give details and this should not affect your application.

However, if the matter is current then this can become problematic particularly if the investigation is in relation to conduct/clinical fitness to practice and the outcome of the investigation is pending.

When this has arisen in applications I have dealt with, in all but one, the assessor has put the application on hold pending the outcome of the investigation.

This is very much taken on a case by case basis so don’t be too disheartened – do check with your solicitor first.

I have an NHS Contract in my name but also carry out private work through my limited company.How does this affect my CQC registration?

In this scenario, you effectively have two providers at your practice – you as an individual and your limited company as an organisation.  You must ensure that BOTH are registered with the CQC and you will have to pay 2 sets of annual CQC registration fees.

You may argue that there is no material change to the provider, you are still the dentist and you are registered – won’t this do?  Unfortunately not.  In the eyes of the CQC (and in law) there are two separate legal entities which therefore require 2 separate registrations. 

If you ignore this requirement, you could be subject to an unlimited fine and/or a maximum of 12 months imprisonment.  You must have this rectified as soon as possible.

In short, the CQC application process can be complicated if you are unfamiliar with the registration requirements.  I know of many dentists who have attempted to complete the forms and have come to me asking for assistance when they have reached the end of their tether!

If you are in this situation (or if you simply can’t face it!) then please do not hesitate to contact me, Hewi Ma at [email protected]  Goodman Grant offers a highly popular bespoke CQC application service to take away the headache of tackling this process.



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