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GP mythbuster 59: Registering a federation - update
This mythbuster describes how federations who have not formed a legal entity to provide regulated activities could organise themselves to avoid having to register every location with CQC.
We have updated our guidance to include additional details to reflect issues raised by a number of federations. This update relates particularly to federations that have not formed a new legal entity and therefore do not need to register in their own right. In these instances, regulated activity is usually provided by each of the providers that are part of the federation and they will usually already be registered in their own right for the regulated activities they will be providing for the federation.
The queries have related to situations where providers provide care and treatment (regulated activities) to patients from other practices at surgeries other than their own. This usually improves access for patients but can trigger the need for providers to add those surgeries to their conditions of registration. Our updated guidance suggests some options that federations can use to avoid the need to add each other’s locations.
Federations that have chosen not to form a legal entity could arrange themselves in one of two ways:
- Option A – ‘patient led option’
- Option B - ‘premises led option’
Option A – ‘patient led option’
The participant providers enter into a written agreement between themselves, so whenever a doctor sees a patient they work under the direction and control of the provider of the practice from whose list the patient comes. Under this arrangement, the patient’s regular practice provider is always responsible for the regulated activity provided – no matter which doctor sees them or in which premises they are seen.
In this case, none of the federation participants would need to add any locations, because each provider would only ever be responsible for the regulated activity delivered to their own patients. The participants would use each other’s locations as satellites or branches of their own location – they’d simply list them in their statements of purpose.
Option B - ‘premises led option’
The participating providers enter into a written agreement detailing that it is always the provider of the practice in whose premises the patients are seen who is responsible for the regulated activity delivered there. When a healthcare professional works in the premises of another participating practice, they are always working for the host provider, following their policies and procedures, regardless of whose list the patient comes from.
Providing that the federation only delivered regulated activities in the premises of its participants, then none of the federation participants would need to add any locations.
In Options A and B the federation would need to document the agreement carefully to ensure that the identity of the provider (of the regulated activity) was always clear. We would need to be satisfied that the provider could be held to account.
There are two case studies in our guidance, 7a and 7b to help illustrate this in practice.
If you have questions about new models of care, including federations, please contact us at: firstname.lastname@example.org
Please contact us at email@example.com for all questions about registration, including those about any
- potential changes to existing CQC registration, or
- new registration that you may need to apply for
as a result of forming a federation.
- Last updated:
- 29 April 2021