CQC registration is a legal requirement for every GP practice providing regulated activities such as treatment of disease, disorder or injury, but the way that registration works, is monitored and is rated differs in several important respects from how the CQC regulates a care home. Both sit under the same Health and Social Care Act 2008 framework, yet the ownership structures, the regulated activities registered against, and the rhythm of inspection are genuinely different.
As the pillar page for our regulatory and compliance series for GP practices, this post sets out where those differences actually matter in practice, and where they don’t. We act for GP partnerships, single-handed practices and primary care networks on registration, governance and CQC-related disputes, and this is the ground-level detail we see catch practices out most often.
Why GP Practices and Care Homes Sit Under the Same Regulator but Different Rules
The CQC regulates both sectors under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. A “regulated activity” is any activity involving, or connected with, the provision of health or social care, and the regulated activities themselves are set out in Schedule 1 to those Regulations. Every provider carrying on a regulated activity, whether from a GP surgery or a residential care home, must register with the CQC before providing that activity, and must register separately for each regulated activity it carries on.
Where the two sectors diverge is in which regulated activities apply, how the provider is structured for registration purposes, and how CQC subsequently monitors and rates the service. Treating GP compliance as “the same as a care home, but with doctors” is the single most common misunderstanding we see among newly appointed practice managers and incoming partners.
Regulated Activities: What a GP Practice Actually Registers For
Most GP practices register for the regulated activity of treatment of disease, disorder or injury, which covers the great majority of core general practice work carried out from a surgery. Depending on the services offered, a practice may also need to register separately for:
- Transport services, triage and medical advice provided remotely (relevant to practices offering telephone or online triage as a distinct service)
- Maternity and midwifery services, where these are provided directly by the practice
- Family planning services
- Assessment or medical treatment for people detained under the Mental Health Act 1983, where relevant
- Surgical procedures, where minor surgery is carried out on-site
A care home, by contrast, typically registers for accommodation for persons who require nursing or personal care, and separately for personal care or nursing care where these are delivered independently of the accommodation service. There is no hierarchy between regulated activities: a provider must register for every regulated activity it carries on, and registering for one does not automatically cover another, although CQC guidance confirms that some activities (such as nursing care delivered as part of treatment of disease, disorder or injury) do not require a separate registration where they are genuinely part of another registered activity.
The practical implication for a GP practice is that its registration profile is built around clinical treatment activities delivered episodically to a registered patient list, not around ongoing accommodation and personal care delivered to residents. This shapes everything downstream, from the evidence CQC collects to how a breach is investigated.
Registered Manager and Nominated Individual: The Structural Difference That Matters
This is where GP practices and care homes diverge most clearly, and where we see the most confusion at registration stage. Every CQC-registered provider must appoint a registered manager with day-to-day responsibility for compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and this applies equally to GP practices and care homes.
However, a nominated individual is only required where the provider registers as an organisation (typically a limited company). If a GP practice registers as an individual or as a partnership, which is how the great majority of traditional GP practices are structured, no nominated individual is required. Many care home operators, by contrast, are corporate providers running multiple locations, and those providers must appoint a nominated individual who is CQC’s main point of accountability for how the organisation’s registered managers are supported and how quality is maintained across all of its locations.
For a GP partnership, this means CQC accountability sits more directly and personally with the partners and the registered manager than it typically does in a large, multi-site care home group. Partners taking on or stepping back from CQC responsibilities should have this reflected clearly in the partnership agreement, since disputes over who is actually accountable for compliance failures are far easier to resolve when the partnership deed addresses it explicitly. Our related post on GP partnership agreements covers what every partner should have in writing on this point.
How CQC Monitors and Rates GP Practices Differently from Care Homes
Care homes are typically subject to unannounced, on-site inspections carried out on a risk-based schedule, reflecting the continuous, round-the-clock nature of the regulated activity. GP practices are monitored on an ongoing basis, which includes an annual regulatory review drawing on data CQC already holds, alongside inspections and, where appropriate, targeted assessments carried out remotely by phone or email rather than always requiring a site visit. Critically, the annual regulatory review itself cannot change a practice’s rating: only an inspection or a formal assessment against the single assessment framework can do that.
Both sectors have moved to a risk-based inspection frequency rather than a fixed timetable. Practices rated inadequate or requires improvement are revisited more often; those consistently rated good or outstanding may go longer between full inspections, but remain subject to ongoing monitoring and can be assessed sooner if concerns, complaints or notifications suggest a problem.
We cover exactly how the current assessment model works, including the quality statements and scoring thresholds that determine a rating, in our companion post on the CQC single assessment framework for GP practices.
CQC Compliance Checklist for GP Practices
| Compliance area | What CQC expects | Care home comparison point |
|---|---|---|
| Registration | Registered for every regulated activity actually carried on (typically treatment of disease, disorder or injury, plus any additional activities such as maternity or family planning) | Care homes register for accommodation with nursing/personal care, plus personal care or nursing care where delivered independently |
| Registered manager | A named, CQC-approved registered manager with day-to-day responsibility for compliance | Same requirement applies |
| Nominated individual | Only required if registered as an organisation; not required for individual or partnership registration | Frequently required, since many care home operators are corporate providers |
| Statement of purpose | Kept current and reflecting the services actually delivered from the registered location | Same requirement applies |
| Monitoring rhythm | Ongoing monitoring, annual regulatory review (cannot itself change a rating), inspections and targeted assessments | Typically unannounced, risk-based on-site inspections |
| Rating basis | Single assessment framework: five key questions, quality statements scored 1 to 4, aggregated into a published rating | Same framework, but evidence collected differs by service type |
| DBS and fit and proper persons checks | Required for the registered manager and relevant staff under the fit and proper persons requirement | Same requirement applies |
What This Means in Practice for Partnership Changes and New Registrations
Because most GP practices register as partnerships rather than corporate bodies, a change in partners can trigger a need to update or, in some cases, re-apply for CQC registration, particularly where the change affects who holds ultimate legal responsibility for the registration. This is a step that gets missed surprisingly often during partnership changes, mergers between practices, or when a practice joins a primary care network as a distinct legal entity. CQC’s own guidance on registration for federations and PCNs confirms that practices working in collaboration need to actively decide whether a new legal entity requires its own registration, rather than assuming the existing registration extends automatically.
Practices going through a merger, incorporation, or a significant change in partnership structure should treat CQC registration as a workstream in its own right, run alongside (not after) the legal and partnership documentation, since a lapse in registration or an inaccurate statement of purpose is itself a regulatory breach.
What This Means for Your Practice
The regulatory principles are the same Act, but the practical reality of CQC compliance for a GP practice, from who holds accountability, to what gets registered, to how and when you are assessed, is meaningfully different from a care home’s experience of the same regulator. Getting the structural basics right, particularly around registered manager and partnership accountability, saves considerable difficulty later, whether that is at a routine assessment or when something has gone wrong. For more on what a strong outcome looks like, see our post on what an outstanding CQC rating looks like for a GP practice.
If your practice is approaching a new registration, a partnership change, or wants a second opinion on where compliance responsibility genuinely sits, get in touch with our healthcare team or call us on +44 207 566 1188. You can also reach us by email at info@gurvelegal.com. Our regulatory compliance team works alongside GP partnerships on exactly these issues on a regular basis.
