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The Department of Health launched a consultation to seek views on the registration of health and adult social care providers, including the regulation of primary care services to ensure patients continue to receive safe, good quality care closer to home. The document entitled A consultation on the framework for the registration of health and adult social care providers puts forward proposals on which services will be required to register with the new regulator and the requirements that they will need to meet. This document summarises the RCN's response to the consultation.

We strongly support the proposal that all GP and primary dental services should be within the scope of registration for a number of reasons.

Firstly, the majority of the population access health and some social care services via their GP in the first instance. However the absence of any regulation has meant that there is a lack of consistent and accessible information about ‘what happens and how’ at the practice level and members of the public are often unable to compare one practice to another when choosing a practice in all but a limited manner.

Secondly, many of our 390,000 members work in practice settings or under the supervision of GPs. Whilst there are many examples of good practice, more action needs to be to taken to ensure that GP services implement good employment practices similar to those described in the proposed topics for registration requirements 15, 16, 17 and 18. The ‘Working In Partnership Programme’ produced a toolkit for HCAs and Nurses working in general practice which gives all the information required to develop high standards of employment practice.

General Practice Nurses now provide a high proportion of skilled nursing care and are constantly expanding their clinical practice so that more care can be provided in general practice. The RCN is aware of the working currently being carried out by the RCGP on the accreditation of general practice. The CQC should investigate this work as part of considering how it could be meaningfully involved with the regulation of general practice.

Thirdly, Government policy is driving more services toward practice level. As Practice Based Commissioning takes hold and more PCTs shift provider services to the practice level, it is absolutely essential that practice based services, whether commissioned or provided by the GP are covered within the scope of registration.

The CQC would do well to learn lessons from PCTs who have demonstrated successfully that they are able to scrutinise and improve the ways in which its general practices implement the GMS Contract (2004). The Contract, if implemented within a framework of professional standards of practice and behaviour can ensure that the public have access to exemplary general practice.

The RCN believes that currently too few PCTs focus attention on effectively monitoring the standards of care provided in general practice. However there are opportunities within the proposed regulatory framework and with the introduction of ‘World Class’ commissioning which would, in time, help to improve the capacity of PCTs to drive up standards of care provided in the general practices.

For further information, please email papa.ukintl.dept@rcn.org.uk