It’s been just over a month since the CQC launched its new method of assessing compliance with Regulation 13 of the CQC (Registration) Regulations 2009. Compliance with this Regulation will now be assessed at the point of application for registration and is to be provided in the form of a letter by a professionally qualified accountant or accountancy company with a recognised accountancy supervisory or qualifying body, or a bank or financial services firm regulated by the Financial Conduct Authority.

The CQC recommends that financial advisors complete and submit the CQC’s template statement of financial viability which includes a confirmation that the applicant has the “financial resources needed to provide and continue to provide the services as described in the statement of purpose”. 

Initial feedback from the Market is that financial advisors are uncomfortable confirming the future financial viability of an applicant.

Depending on the size and complexity of the applicant provider, getting to a position where a financial advisor will provide this sort of confirmation is likely to result in additional costs for applicants, as advisors will want to carry out detailed financial due diligence in order to be in a position to provide the requisite confirmation. 

Financial advisors will want to couch their statements with all of the usual caveats. Such caveats should be considered carefully and applied in box 3 of the template statement.

The new approach applies to all providers submitting a new registration application excluding NHS Trusts/FTs, GPs, dentists, local authorities, private providers with NHS contracts and adult social care providers currently in the Market Oversight Scheme.