CQC and Beyond First Aid

I got an email a while back, asking if I could provide medical cover for a large corporate event coming up in the new year. I asked for more information and this was sent almost by return, with the potential customer stating that I had been highly recommended by another of my customers.

Unfortunately, it turned out that this was basically a large business conference in a local hotel that is part of a large chain. I had to turn down the work as Beyond First Aid is not registered with the Care Quality Commission (CQC). The CQC is the independent regulator of all health and social care services in England. They basically monitor, inspect and regulate hospitals, care homes, GP surgeries, dental practices and other care services to make sure they meet fundamental standards of quality and safety and publishes what they find. This includes both NHS and independent ambulance services.

Now some may say, Beyond First Aid is an independent ambulance service, we do after all go to events, hire medical professionals, fix the sick and broken, and even have a blue flashy thing on top of some of our cars. So why are we not registered with the CQC? This was the very question I was asked by this potential customer.

Let me explain…

The starting point when considering registration with the CQC is… are any regulated activities being carried out? For example the treatment of disease, disorder, or injury (TDDI), diagnostic and screening procedures, transport, triage and medical advice. Well, TDDI is only regulated when the treatment is carried out by a listed healthcare professional. Any treatment of an injury by someone not on that list is not regulated by CQC under any circumstances. Similarly, transport is only regulated when a patient is transported for treatment in a vehicle designed for that purpose. Transport of a patient in any other vehicle, my Mondeo for example, or me driving to the casualty, are outside the scope of the CQC.

Just so you’re clear on that… First aid delivered from a vehicle , i.e. the vehicle was used to bring the first aid to the patient and the patient is not being transported, is exempt. If the patient is being transported, this will generally rule out the first aid exemption. At which point, if the vehicle is an ambulance, the regulated activity of transport, triage and remote medical advice may be triggered, as may TDDI unless another exemption applies, such as the treatment taking place at an event. The net effect, however, is that if the patient is being transported in a vehicle other than an ambulance, and the treatment is provided through temporary arrangements for a sporting or cultural event, neither activity would be triggered. Got that? Good, clear as mud.

There are some general exemptions from registration which exempt Beyond First Aid entirely, and there are some exemptions specific to certain regulated activities.

First aid is a general exemption. First aid organisations such as Beyond First Aid, non-health care professionals trained in first aid, healthcare professionals in unexpected or potentially dangerous situations requiring immediate action, do not need to be registered, whether TDDI or surgical procedures , to deliver first aid. However, this will not exempt them from regulated activities that are not first aid. An example would be transporting a casualty in an ambulance, this is not first aid, we can however use an ambulance to get a first aider to the casualty, or use an ordinary vehicle to ‘give a lift’ to a casualty so they don’t have to walk to the first aid point. This does not mean we can ‘give a lift’ to Accident and Emergency. Medical professionals (Paramedics, Nurses or Doctors) can act as First Aiders, but can not be employed by Beyond First Aid as medical professionals, i.e. I can not employ a paramedic as a first aider and expect him or her to turn up to an event with intubation kit and a drug bag. This would be employing that person as a medical professional, I would need to register, they would want more wages, my insurance would go up, the customer would get a bigger bill and everyone is out of pocket. This does not however mean that our customers are getting a second rate service, as I will explain.

TDDI has several specific exemptions. Any treatment in a sporting ground or gymnasium, for participants or spectators, is exempt. So you can hire us for a martial arts tournament in the local gym. Any treatment provided through temporary arrangements for sporting or cultural events is exempt. So you can hire us to cover that 5km running event around the local country park, or that family fun day to raise funds for a local charity. These exemptions are not limited to first aid and could encompass quite complex treatment, treatments that may, in other circumstances, be considered as being beyond first aid… Hmm, good name for a company that! Now you may begin to see why I employ people who are a bit more than first aiders.

To quote an old article from a CQC Correspondence Team…

“For first aid event cover the TDDI classification expands the general first aid exemption to doctors, nurses and paramedics etc, but only when treatment is provided in a sports ground or gymnasium for the sole benefit of persons taking part in, or attending, sporting activities or events. Not covered within the exemption are weddings and business conferences.”

Hmmm? Weddings? Business Conferences? These are apparently intended as some examples of events that do not fall under sporting and cultural and shouldn’t be considered an exhaustive list of things not covered. Don’t ask me why, but if I cover first aid at a business conference, or a wedding or even a bar mitzvah, I need to be CQC registered. If I cover a food or beer festival, or even a festival intended for outdoor types who talk about their adventures, I don’t need to be registered. This brings me to the guy who asked me why I could not cover his large corporate event, and hopefully goes some way to explaining why I had to turn away work.

Now, why do I employ health care professionals such as doctors, nurses and paramedics? After all, they must register with CQC if carrying out diagnosis and screening surely? Well, guess what, “Exemptions”

Someone carrying out a 2- or 12-lead ECG, taking a blood pressure with an automatic machine or a sphygmomanometer and a stethoscope, someone using a pulse oximeter, a thermometer or ophthalmoscope… you guessed it, exempt. BUT… diagnostics and screening is not limited to health care professionals. Anyone carrying on these procedures will need to register with the CQC, unless they benefit from an applicable exemption, like us.