CQC registration for online GP and digital doctor services
An online GP or digital doctor service in England must register with CQC before it treats its first patient, even with no clinic, usually for treatment of disease, disorder or injury. We prepare your applications, remote prescribing policies and interview from £1,795, and stay with you until CQC makes its decision.
If a clinician treats patients through your service, you need to register
Treatment of disease, disorder or injury is a regulated activity when it is carried on in England by, or under the supervision of, a doctor, nurse or other listed health care professional. The definition turns on who treats the patient, not where they are seen, so a service that consults and prescribes by video, phone or online form is covered even with no clinic. Providing it without registration is an offence under section 10 of the Health and Social Care Act 2008.
Taking blood or urine samples, swabs or skin scrapings, and reporting the results, needs no second activity once you are registered for treatment. Diagnostic and screening procedures is needed for imaging, instruments inserted into the body, a biopsy, or equipment that monitors a body system to plan care, such as an ambulatory ECG or blood pressure monitor.
Read the legal definitions (Regulated Activities Regulations 2014, Schedule 1)Weight loss prescribing online
Services in slimming clinics covers services provided in a slimming clinic. When a doctor prescribes weight loss medicines through an online service, CQC’s scope guidance places it under treatment of disease, disorder or injury instead.
Urgent advice and triage lines
Urgent medical advice or triage by phone or email, from a body set up for that purpose, is a separate activity: transport services, triage and medical advice provided remotely. A service that also prescribes usually needs treatment too. We confirm the right activities on the free scoping call.
Needs CQC registration
- Video, phone or online consultations where a doctor or nurse diagnoses and treats
- Remote prescribing by a doctor, nurse or other listed health care professional
- Online weight loss prescribing led by a doctor
- Remote treatment for a mental disorder by a doctor, nurse or social worker
- Urgent medical advice or triage by phone or email, from a body set up for it
- Remote monitoring with equipment such as ambulatory ECG or blood pressure monitors
Not regulated on its own
- Prescribing by pharmacists alone, as they are not on the health care professional list
- Medical services arranged only by a patient’s employer or a government department
- Blood or urine samples and swabs, once you are registered for treatment
- Pharmacy services provided from a registered pharmacy
Everything CQC asks an online GP service for
Written for your service, not a template pack. Stage 1 gets your application in. Stage 2 carries you through assessment and the interview.
Your application pack
Required from every provider
- Statement of Purpose
- Safeguarding policy and procedure
- Medicines management and prescribing policy, including remote prescribing safeguards
- Infection prevention and control policy
- Recruitment policy
- Complaints policy
- Consent policy and procedure
- Equality, diversity and human rights policy
- Governance and quality assurance policies
Extra for online primary care
- Inclusion and exclusion criteria policy, setting out who your service will and will not treat
- Medical emergency policy
- Financial viability statement guidance, completed with your accountant
- Provider and registered manager forms, plus the additional form for online primary care providers, completed with you
Assessment, interview and follow-up
- Additional documents CQC may ask for during assessment, prepared and kept ready
- Registered manager interview question and answer pack
- Two-hour mock interview with written feedback
- Follow-up with CQC on your behalf until a decision is made
- Appeal support if your application is challenged
What a remote service has to prove
The extra evidence an online primary care application needs, and what we make sure is in place before you submit.
Remote prescribing safeguards
Your medicines and prescribing policy has to show how you prescribe at a distance. GMC guidance expects identity checks so medicines go to the right person, consent to contact the patient’s GP, and prescription details shared with that GP.
Who you will not treat online
Online primary care applicants send an inclusion and exclusion criteria policy, setting out the patients, conditions and medicines you will not take on remotely. GMC guidance, for example, says injectable cosmetic medicines such as Botox must not be prescribed remotely.
A medical emergency policy
You also send a medical emergency policy. Yours has to work when the patient is at home and you are on a screen, not in a clinic room with equipment to hand.
A financial viability statement
Most online healthcare applicants send CQC a financial viability statement, completed with your accountant. We give you the guidance and check it matches the rest of your application.
Indemnity that covers online work
Your medical indemnity quote or policy must cover online services, not only face-to-face work. GMC guidance also tells doctors to check their indemnity covers remote consultations.
Capacity and safeguarding on screen
Your consent and safeguarding policies need remote answers: how you assess capacity, and what you do if a patient may not be safe or free to speak, for example because of domestic abuse. GMC guidance lists these as times a face-to-face consultation may be more appropriate.
Five steps from first call to certificate
Our part is fast. CQC’s assessment sets the overall timescale, and we stay with you through it.
Scoping and onboarding
We map your clinical model and platform, confirm your regulated activities, and give you a checklist of what only you can get: DBS checks, indemnity that covers online work, ICO registration and financial evidence.
Stage 1 pack
Your policies written for remote care, the inclusion and exclusion criteria, the medical emergency policy and your forms, once your requirements are met.
Submission
We check everything and support the provider and registered manager applications through the CQC provider portal.
Stage 2 support
Requested documents, the interview pack, a two-hour mock interview with written feedback, and follow-up with CQC on your behalf.
Decision
You receive your certificate of registration and can begin seeing patients online.
One package, paid in two halves
Our fee covers both stages. The regulator’s fee and your set-up costs are separate, so budget for them too.
CQC registration package
Or pay in full and take 10% off.
Also budget for
Paid to others, not to us. CQC itself charges no application fee.
- CQC annual fee, charged once you are registered
- Medical indemnity insurance that covers online services
- Public and employer’s liability insurance
- DBS checks
- ICO data protection fee
- Your accountant’s time on the financial viability statement
If CQC rejects or returns your application before it reaches an inspector, we fix it and resubmit at no extra cost, as many times as it takes. Subject to our terms and conditions.
Buy single documents instead
Statement of Purpose
A Statement of Purpose written for your service, with your provider, location, manager and regulated activity details.
Registered manager interview prep
Practice questions, answer guidance and feedback for the CQC registered manager interview, on its own.
Business continuity plan
An editable plan template covering staffing, premises, utilities, IT, medicines and suppliers, with recovery and review records.
Keep your policies current
CuraFlow Policies keeps your full library up to date with law and CQC changes once you are registered.
Online GP registration questions
Do I need a physical clinic to register an online GP service?
Can a sole doctor register, and who is the registered manager?
What if we only prescribe, or prescribe from an online questionnaire?
Do we have to tell the patient’s NHS GP?
How long does registration take, and what does it cost?
What happens if CQC sends my application back?
Guides for online GP providers
The words you will meet in your application
Ready to register your online GP service?
No obligation. We confirm the regulated activities you need, what you still have to get, and a realistic timeline.
