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Acquiring a Dental Practice: Important CQC Considerations
The Care Quality Commission (CQC) is an independent regulator of health and social care, including the dental profession. It became a legal requirement for dentists to register with the CQC from 1st April 2011. As a result, individuals looking to acquire a dental practice should not underestimate the amount of time needed to fulfil CQC requirements.
Applying for the DBS certificate, completing the applications and waiting for the CQC to process the applications can altogether take a number of months. It is of utmost importance that the forms are completed correctly, as any mistakes will lead to the CQC rejecting the application, which can slow the process of the sale significantly. Furthermore, any lenders involved will hold back with financing the deal until CQC has been granted. This article highlights some important considerations regarding CQC to help make sure your practice acquisition runs smoothly and efficiently.
Obtaining a Disclosure and Barring Service (DBS) Certificate
The CQC requests that the following groups obtain CQC countersigned DBS checks:
• individuals applying to carry on or manage a care service;
• all partners; and
• registered managers.
It is necessary that your DBS is countersigned by the CQC as opposed to obtaining a standard DBS, or it will be rejected. DBS checks can take over four weeks to be processed. Although many people think it is important to apply for one as soon as instructions commence, this may not be the case. The CQC needs to see DBS certificates valid within the last six months. So depending on the nature of the practice acquisition, you may need to hold off from obtaining one at the early stages. You should seek your solicitors’ advice to time this correctly.
You can register for a CQC countersigned DBS here:
Once you have received your DBS certificate you can proceed to make your application.
NHS Partnership/Private Practice Buyer Applications
Where a new principal dentist is going into partnership with another dentist on an existing NHS contract, you will need to make an application to register a CQC partnership with the current principal using the ‘New Provider Form’. The current principal will also make an application to cancel their existing registration as sole Provider. It is useful if these forms are submitted to the CQC at the same time. Some people find the concept of registering a partnership with a principal, who may be intending to retire in the not-so-distant future, an unusual one, but it is just the CQC’s formal process that needs to be followed. You will need to enter a name of the partnership and various details will need to be fully completed for each partner, such as employment history. If there are more than two partners, you will need to download the additional partner form, which can be found at this link: http://www.cqc.org.uk/guidance-providers/registration-notifications/provider-application-add-partner#no-account.
There is a significant amount of information needed for each Buyer/Partner, which can take time to retrieve from all parties, let alone to fill out by a first-time provider who is just getting to grips with the forms. Crombie Wilkinson can make this process more straightforward for you by collecting all relevant information in our standard questionnaires tailored for buyers and partners. Our experience in navigating the forms means that we can provide an efficient service for you, saving you the worry of completing the forms incorrectly.
Once the CQC has accepted your application, they will issue a ‘Position Statement’, conditionally confirming their acceptance of the partnership, providing that details in your applications do not change. The Position Statement is used as evidence of the CQC’s approval when making the partnership application to the Local Area Team (LAT).
Registered Manager Application
Alongside your New Provider application, you will need to submit a Registered Manager form if you are applying to register a partnership or Company. It may be that you would like to be the Registered Manager, but some people choose for this to be the Practice Manager, as they are the person who is to be in charge of the day-to-day running of the practice. If so, you need to be sure that the particular employee will continue working at the practice post-completion and that they are responsible enough to comply with the regulations. Additionally, they will also need to have a DBS certificate countersigned by the CQC. The existing Registered Manager will need to simultaneously submit their de-registration form (unless the Registered Manager is staying the same post-sale).
Post-Completion CQC Application
Often, the original principal becomes a sleeping partner on completion and intends to retire soon after. This involves a de-registration of the new partnership registration.
Clearly, there are a number of important stages to complete during the purchase of a dental practice and timings are vital. Any neglect to follow correct CQC procedures or any mistakes in applications can greatly hamper the sale. For purchasers this can be a very daunting task, especially with many other aspects of the purchase going on. At Crombie Wilkinson we offer a straight-forward CQC service to help ease the process and give our clients peace of mind that their CQC application will not be a setback to their practice purchase.
If you would like assistance with CQC work during your practice sale or purchase, please do not hesitate to call our specialist dental team on 01904 624185.