Corporate-level compliance

Primary care providers are growing larger, so how does the CQC work with these new corporate entities? Practice Business investigates

Primary care is seeing a growth in the number of large-scale ‘corporate’ providers, managing services over a wide geographic footprint. Because of their size, complexity and market share, regulating corporate care providers can be a challenge, the CQC acknowledges, which is why it has developed its own strategy for doing so. We explore what corporate-level compliance is and what it means for people and practices

What is a ‘corporate provider’?

The CQC defines ‘corporate providers’ as ‘made up of one or more legal entities and providing services from multiple locations, excluding NHS trusts’. While, typically, these large providers have been in acute and secondary care, a growing number are springing up in primary care, particularly in large urban centres like London.

In terms of scale, the CQC considers a corporate provider as one with over 20 locations, although it does work with smaller providers in some contexts. This relationship doesn’t extend to franchises which are, according to the CQC, treated as individual entities.

How does it work?

At a practice level, regular local CQC inspections remain in place. Corporate-level compliance provides an additional layer of assurance for the CQC but does not replace the standard inspections all healthcare organisations face.

Each corporate entity has its own relationship lead from the CQC who manages the ongoing engagement; this is designed to ensure consistency, the CQC says. It is the role of the relationship lead to maintain communication and to have oversight of the quality profile of each business. They achieve this in a number of ways, including:

• Developing and maintaining a relationship with the provider at their corporate level.
• Maintaining oversight of the performance profile of the locations in the provider’s portfolio, identifying trends, risks, issues and changes over time, and having regular discussions with the provider about this.
• Responding to monitoring information where this indicates issues of concern, sharing information with operations staff to inform and enhance location-level inspection activity.
• Exchanging information about organisational developments and strategic plans. Working with providers at corporate level 5.
• Providing a forum for feedback on CQC methodology and regulatory approach.

The CQC doesn’t seek to directly influence, or dictate, the running of the business, but provides guidance that could support the strategic direction, leadership and cultural expectations within the corporate entity that can have an influence ‘on the ground’.

How often are meetings between the two parties?

The degree of active involvement with the provider will differ depending on the size, complexity, performance and risks associated with individual providers. However, the CQC suggests between one and three routine engagement meetings per year in order to establish and maintain what it calls a, ‘meaningful and productive relationship’.

What is covered?

The regular local CQC inspections focus on the issues affecting individual business units. At a corporate level, the meetings aim to identify any systemic problems or failures that could be endemic within the business.

Some areas of concern could relate to:

• Corporate governance and systems – for example, senior management support arrangements, quality assurance arrangements, policies and procedures, strategic leadership and planning.
• Recruitment and retention issues.
• Poor performance across multiple locations.
• Similar poor performance issues across multiple locations.
• Multiple locations without registered managers.

Once an issue is identified, the relationship manager will seek information from the provider and some assurance from them that these concerns will be acted upon. The information at a corporate level will be shared with local inspectors who will consider it as part of standard investigations.

Managing impact

The CQC works with corporate level providers in a different way because of their scale, complexity and their size in the market – the potential impact of poor performance and negative organisational processes could be amplified many times over. By working closely with the those at the highest levels the CQC can have the biggest impact on those who matter most: the patients.

Read more about corporate level relationships on the CQC website.

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