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Care Quality Commission Registration Guide   13/04/2012
The Association of First Aiders has recently received correspondence from members concerning the confusion of individual Care Quality Commission (CQC) registration submissions. The purpose of our newsletter is to try to resolve a couple of ambiguities surrounding first aid event cover, especially where treatment and transport provision overlap, creating uncertainty over the need to register with CQC.

The Care Quality Commission is a regulatory body, with authority to take enforcement action against providers who offer regulated activities without registration. Action can be taken at any time, without notice against those who fail to meet regulatory standards.

The starting point when considering a requirement to register with CQC is always to question: 'Is a regulated activity being carried out at all?' (The list of regulated activities can be found on page 4 of the Scope of Registration).

The second question would be 'Are there any exemptions from registration?'

There is a general exemption set out in the legislation that refers to first aid, identified as;

a) Health care professionals where first aid is provided in unexpected or potentially dangerous situations requiring immediate action. i.e they happen to be at the event as a spectator or come across on road traffic accident etc.

b) Organisations set up to provide immediate first aid treatment.

c) Non-health care professionals who are trained to deliver first aid treatment.

'First aid is a general exemption from registration.'

An overview from the Care Quality Commission suggests;

'If a provider provides first aid treatment only, or provides first aid cover at events, registration would not normally be required for that activity alone, unless an ambulance is used for patient transport.'

The CQC define an ambulance as:

'A vehicle that is designed for the primary purpose of transporting people who require treatment.'

The following examples of vehicle use are exempt from CQC registration:

a) Transport services provided in vehicles that have a different PRIMARY purpose, such as taxis, volunteers using their private cars, mortuary vehicles or Dial-a-Ride vehicles. These are not captured in this regulated activity.

b) Search and rescue transport services are also currently exempt because the service is provided under arrangements made on people's behalf by a government department.

'It is important to note, it is the nature of the vehicles use that determines the need to register.'

Case studies: Do I need to register with CQC?

Q: What if a vehicle is designed as an ambulance but the provider uses the vehicle for the purpose of transporting staff and equipment to a person requiring treatment, not for transportation of a casualty?

A: In this case the vehicle is not being used for the purpose of transporting people who need treatment, so the provider is not required to register for transport.

Q: Do I need to register a vehicle under CQC transporting services if first aid treatment is delivered in or from a vehicle at an event?

A: Yes if the primary purpose of the vehicle is an ambulance and is not your everyday vehicle modified to suit. However, if the vehicle is a personal vehicle modified to provide casualty transport and treatment at the event then registration is not required.

Q: Is the 'Treatment of Disease, Disorder or Injury' (TDDI) a regulated activity which requires CQC registration?

A: 'Treatment of Disease, Disorder or Injury' is only regulated when the treatment is carried out by a listed healthcare professional (the list is on page 59 of the Scope of Registration). Any treatment of an injury from someone not on that list are not regulated by CQC, therefore do not need to register.

However, there is an exemption under TTDI 'within a sports ground or gymnasium for the sole benefit of persons taking part in, or attending, sporting activities or events.' 'Events' not covered within the exemption include weddings and business conferences etc.

It is important to note any regulated activity carried out within transport are not covered by the same exemption. Treatment carried out in or from an ambulance as defined, is a regulated transport service activity requiring registration. Similarly, anyone carrying out Diagnostics and Screening (D&S) must register with CQC. Exemptions are: A provider carrying out a 2- or 12-lead ECG, automated non-invasive blood pressure measurement, pulse oximeter, use of a thermometer, sphygmomanometer or ophthalmoscope.

The Department of Health propose change concerning ambulance transportation services at events see below. (It is expected that this chnage will be implimented within the 6 months)

The use of ambulances within sporting and cultural events-
'Although first aid and treatment at such events is excluded from the requirement to register, there remains a requirement for any transport that is involved in moving an individual from the place they have been injured to a treatment area, to register even if that transport takes place only within the event site itself. We believe that this is overly burdensome and propose to remove this requirement where the transportation takes place within the event site only.' (Department of Health, Consultation on proposed changes to regulations for Care Quality Commission registration, P39, 2011).

'Treatment carried out in or from an ambulance as defined, is a regulated transport service activity requiring registration.'

This newsletter was submitted to the CQC for comment; while broadly correct the CQC added further comments. To view their response, access the members' area on the AoFA website.

The Q&A's within this update are only a guide, the CQC treat all registration applications on a case by case basis. The CQC Scope of Registration document provides a fully comprehensive guide through the application process, to help decide whether you need to register with the Care Quality Commission under the Health and Social Care Act 2008. Visit the CQC website for more details


First Aid Forward, are you attending?

We look forward to welcoming you to our annual first aid forward conference, held at the Kettering Conference Centre on May 4th 2012. The UK's largest meeting of first aid trainers and suppliers.

We hope you're ready for the action packed day, where we will be bringing you keynote sessions from 6 industry professionals sharing firsthand experience of first aid disciplines, including Professor, Sir Keith Porter who will once again be presenting. An event truly not to be missed. Unrivalled networking opportunities, with over 500 like minded industry colleagues and more than 30 exhibitors showcasing the latest equipment and supplies available in the pre-hospital care sector.

Complete and comprehensive contact details of each exhibitor can be found online at to book your place on the conference today, call Life Connections on 01322 660434 or book online.

All delegate rates include: Delegate bag, information pack, lunch and refreshments.

£65 plus VAT for members of the AoFA
£70 plus VAT for non-members