Complex care

CQC compliance for complex care

Complex care carries the highest clinical risk in adult social care, and CQC assesses it accordingly. The recurring theme in enforcement is the same: clinical tasks delegated to care staff without person-specific competency, oversight, or a plan for when things deteriorate.

Get the registration and scope right

  • Register for the activities you actually deliver, and name the clinical interventions in your statement of purpose.
  • Do not accept a package outside your evidenced competence because the commissioner is under pressure. Declining is a governance strength.
  • Have a written pre-acceptance assessment: clinical need, equipment, training required, clinical oversight, staffing model and escalation route — signed off before the package starts.

Delegated clinical tasks and competency

  • A named registered nurse or clinical lead responsible for training, assessment and ongoing oversight.
  • Person-specific competency sign-off for each worker and each task, with dated re-assessment intervals.
  • Written care plans and clinical protocols for each intervention, agreed with the community clinical team and reviewed when the person's condition changes.
  • Clear boundaries: what a worker may do, what they must escalate, and who they call at 3am.
  • Shadowing and supervised practice before a worker is counted in the staffing for a clinical package.

Airway, feeding and seizure management

  • Tracheostomy and ventilation: emergency equipment checked every shift and recorded, spare tube and obturator present, suction working, emergency algorithm on the wall, and staff who can demonstrate an unplanned decannulation response.
  • Enteral feeding: regimen from the dietitian, tube position checks, flushing, stoma site care, and a plan for blocked or displaced tubes.
  • Epilepsy: seizure description and thresholds, rescue medication protocol with time limits, competency to administer, post-seizure monitoring, and when to call an ambulance.
  • Deterioration: use a recognised tool such as RESTORE2 or NEWS2, record baseline observations, and evidence escalation to primary care or 999 with outcomes.

Medicines in complex packages

  • Reconciliation on discharge from hospital, with changes reflected in the MAR the same day.
  • Controlled drugs, syringe drivers and anticipatory medicines handled under clinical direction with recorded competency.
  • Time-critical medicines — particularly Parkinson's — administered within window, with exceptions reported.
  • Regular medicines audit against the current prescription, not against last month's chart.

Staffing continuity and wellbeing

  • Small, dedicated teams per package, with named consistent staff and a trained cover list — not open agency.
  • Waking night and continuous care rotas that comply with working time limits and allow for genuine rest.
  • Debriefs after clinical emergencies, and access to support for staff working in isolation with high acuity.
  • Retention data by package, because turnover is the clearest early warning of an unsafe arrangement.

Clinical governance CQC expects to see

  • A clinical governance meeting with minutes: incidents, near misses, deterioration events, medicines errors and competency status.
  • Clinical audit of each package, distinct from care plan audit, signed by the clinical lead.
  • Joint working records with community nursing, respiratory teams, dietetics, SALT, GP and continuing healthcare commissioners.
  • Risk register per package, with mitigations and review dates, escalated to provider level.
  • Duty of candour applied and evidenced whenever a notifiable safety incident occurs, alongside CQC notifications.

End of life care

  • Advance care plans, ReSPECT or DNACPR documentation valid, current and accessible to staff and paramedics.
  • Anticipatory medicines in place, with staff clear on what they may and may not administer.
  • Preferred place of care and death recorded and respected, with families supported and staff debriefed.

Common questions

What counts as complex care?

Care packages involving clinical interventions delivered outside hospital — tracheostomy and ventilation support, PEG or enteral feeding, suctioning, catheter and stoma care, epilepsy with rescue medication, spinal injury or acquired brain injury support, and end of life care with syringe drivers. Most are delivered by trained care staff under delegated authority from a registered clinician.

Which regulated activities does a complex care provider register for?

Personal care where care is delivered in the person's home, and treatment of disease, disorder or injury where the service itself provides clinical treatment through registered nurses. Get this right at registration: delivering clinical treatment without the corresponding registration is a serious regulatory problem.

How is delegated clinical competency evidenced?

By a named registered clinician who trains and assesses each worker on the specific task for the specific person, signs them off in writing, sets a re-assessment interval, and remains available for advice. Generic classroom training with no person-specific sign-off does not meet the expectation.

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