The CQC is still examining how it will work with PCNs - which will become operational from from July this year - but confirmed to GPonline that some networks may need to register and face inspection.
The CQC's role is to 'monitor, inspect and regulate services that provide health and social care' - and although most PCNs are not expected to provide services initially, both the CQC and the BMA have recognised that there may cases in which they would need to register with the CQC.
A handbook published earlier this year by the BMA, which sets out five possible structures for PCNs, includes one model with a 'possible need for CQC registration'.
Primary care networks
Under this model, in which a PCN sets up a limited liability 'provider entity' to deliver services, the handbook suggests that the PCN could need to register with the CQC 'depending on who is providing the regulated activity'. The handbook suggests this could be a model increasingly adopted by PCNs to protect practices from significant liabilities that they will be 'exposed to as the network workforce grows'.
How PCNs are structured will be key to determining the extent to which they face CQC scrutiny as the NHS moves to awarding enhanced services at network level rather than to individual practices, as networks become 'responsible for the provision of network-level services' to patients whose practices choose not to join a network, and as delivery of vaccination programmes shifts to network level.
A CQC spokesperson confirmed that a PCN could have to register for inspection if it provided services - although the spokesperson added that where ‘PCNs represent a formalised relationship between a group of providers and are not providers themselves', registration with the CQC would not be necessary.
Ruth Rankine, deputy chief inspector of general practice at the CQC said: ‘As ever, if a service provides regulated activities itself – as defined by the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – they are required to register with CQC as a provider.’
Ms Rankine added: ‘We are working with NHS England, NHS Improvement and CCGs to understand how PCNs are developing as well as gathering our own intelligence to better understand how CQC may work with these new bodies. With such potential variation in how they work, we will look at each of these emerging models on a case by case basis.’
GPC chair Dr Richard Vautrey, however, suggested PCN registration with the CQC was unlikely: ‘PCNs are an extension of the practice contract and don't need to be registered with CQC. We will be working with CQC on these new changes to help them develop their understanding.’
Practices have been asked to ‘complete and return’ their primary care network (PCN) registration by 15 May 2019 to sign up to the network contract DES. This involves identifying a list of ‘proposed member GP practices’ with whom they plan to form a network, as well as nominating a ‘single practice or provider’ to receive funding on behalf of the whole PCN.
NHS England confirmed that core PCN funding of £1.50 per registered patient will commence from 1 July and ‘should be backdated’ to 1 April 2019.