Start-ups · Introductory care agency
Introductory Care Agency Registration
An introductory agency that keeps an ongoing role in the care it introduces must register with CQC. One that genuinely steps back need not. Most agencies that believe they are on the safe side of that line have drifted across it.
CQC calls it the ongoing role test, and it is specific
If you have no ongoing involvement in how care workers provide personal care after the introduction, you fall outside registration. If you have an ongoing role, you are carrying out a regulated activity and you must register.
CQC treats these as signs of an ongoing role: monitoring the service the workers you introduced are providing and acting on that feedback; arranging rotas on the client’s behalf; taking the initiative to cover absence rather than waiting to be asked; charging continuing fees rather than a one-off introduction fee; reviewing and updating people’s care needs; and requiring workers to accept supervision, wear a uniform or use particular equipment in delivering care.
And these as consistent with staying outside it: vetting a worker’s suitability before introducing them; offering general training that is not about a specific person’s care; charging a one-time introduction fee; introducing a replacement only when the client asks; and contacting the client about the introduction service itself rather than about the care.
It is a criminal offence to carry on a regulated activity without registration. This is not a filing question.
Already trading and unsure which side you are on?
Ring before you write anything down. If the position needs correcting, the order in which you do it matters.
Find which side in four questionsWhat we do
Establish the position first. Register only if the position requires it.
An honest assessment of your model
We go through what you actually do — the fees, the rotas, the replacements, the reviews — against CQC’s own criteria, and give you a written position rather than an opinion.
If you need to register
The full application: provider and registered manager, statement of purpose, policies and the evidence pack. Prepared on the basis that you are providing personal care, because at that point you are.
If you do not
What to change or document so it stays that way, and what would push you over. Most of the drift we see is administrative convenience rather than a decision anyone took.
Contracts and client documentation
Terms that describe an introduction rather than a care service, which matters if the position is ever tested.
Correcting a position quietly
If you have been operating on the wrong side of the line, there is a sensible order in which to put it right. Doing it in the wrong order attracts more attention, not less.
Where it goes next
Many introductory agencies eventually decide to become a full domiciliary service. If that is where you are heading, build for it now. Live-in care.
Before you commit
The introductory model is attractive because it carries no registration, no inspection and far less liability. That is exactly why the boundary is policed.
Our experience is that agencies rarely cross the line deliberately. They cross it because a client rings on a Friday, a carer is ill, and somebody in the office sorts out a replacement rather than leaving a vulnerable person without care. That instinct is right and it is also the moment the model changes.
Fees are quoted before any work starts. Nothing on this page is an offer.
Describe what happens when a carer calls in sick.
It is a better test of your model than any policy document, and it is usually where the conversation ends up. Thirty minutes, no charge, in confidence.
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07426 919823If it is easier to write it down than say it out loud, send a message.
Get the scope right and the rest follows.