Preparing for the CQC Fit Person Interview
This interview needs to be taken seriously as you will not be registered if you do not successfully demonstrate you are a fit and proper (suitable) person who can run the care business safely and meet all regulatory requirements. Remember, the role of a registered manager is enshrined in law. You and your organisation (registered provider) have a joint responsibility under the regulations.
As part of your preparation, you have to try your best to be calm and reflect about the purpose of the interview. You do not need to be afraid. The fit and proper person interview is not there to trap you or make your life difficult. It is an opportunity for you to demonstrate to the CQC inspector that you are ready to provide a safe service and meet all regulations. You will be ready to face the interview if you take your time to truly understand about your services, service user bands, plans, policies, procedures and CQC Key Lines of Enquiry (KLOE).
Ensure you have your evidence on hand when it comes to your experience (managing and leadership), qualifications, employment history, knowledge and an understanding of the service you will be managing. The CQC will also want to know about any criminal records or any other character and behavioural issues such as disciplinary procedures. Under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: Regulation 19 you are required to be of good character. Where there are issues such as fraud, theft and robbery there should be clear risk assessments and assurances given to CQC to protect the people who will be using your service.
During the Interview
The CQC inspector might be with a colleague who will assist mainly with administrative tasks during the interview. You need to have a good insight about your own organisation and what it intends to do. You might be asked about the service user bands, demographics of the clients who will be using your service, recruitment and basic business information such as any marketing research you have conducted. You might also be asked about the source of your finances. The CQC inspector might also want to know about the balance of power in your organisation in particular where there are many senior members of staff. They would seek clarification on different roles and responsibilities and ensure there is clear accountability. The interview will address the role of the registered manager and nominated individual. If you are going to be performing both roles it is advisable to have a conflict of interest policy in place.
The CQC fit person interview is not just about memorising regulations and knowing them. You need to demonstrate your understanding and application in practice. The CQC inspector will unlikely not going to ask you to name regulations. They will however likely ask direct questions about your practice or give you scenarios that will address your competency against the fundamental standards.
You will be expected to have a good idea and understanding of all the policies and procedures in place. Your role and responsibility during the interview is to demonstrate how all the essential standards have actually been embedded and implemented by your service. You will need to demonstrate how you are going to run the service by carrying out effective recruitment which includes ensuring references and DBS checks have been made for all staff.
There should be policies and procedures regarding how you seek consent and promote involvement of people using your service, you need to be articulate regarding how you carry out assessment of needs and risks. There should be care plans for each of the people who will use your service. You should fully embrace the principles of the Mental Capacity Act 2006, Equality Act 2010, and have systems in place to check for quality. There should also be systems to address when things go wrong such as complaints and safeguarding. Your knowledge and practice should embrace GDPR 2018 regulations, safe handling of medication, the Care Act 2014 and Health and Social Care Act 2008 among many other legislation and regulations associated with your practice.
Do not aim for the minimum when responding to the questions and scenarios put forward by the CQC inspector. Your aim is to convince the CQC that you have a clear over sight of your business and know what you are doing with appropriate skills and expertise. You are required after all to prove you can provide a safe, effective, caring and well-led service.
Before responding to any questions please pose to think how this relates to any of the fundamental standards. Do not get carried away and lose your composure which might result in you not fully reflecting your ability, professionalism, knowledge, understanding, policies and procedures. The CQC inspector will quote and record your response which they will refer to when making a decision about your application to become a registered manager.
Sometimes depending on the situation, further opportunities might be given to clarify or submit further evidence. The CQC might also choose to register you with some restrictions by issuing a "Notice of proposal to Register with conditions".
Unsuccessful (Failed) CQC Fit Person Interview
Like any interview, you can be unsuccessful with your CQC Fit Person Interview. It is possible for the interview to go wrong if you are unable to convince the CQC inspector that you fully understand and can perform the demands of your role. The decision is normally made after a few weeks. It is possible for the interview to end after a short time if it is clear you are not prepared, do not understand the regulations and are a risk to others.
The inspector in this case can give you informal verbal feedback. They will issue a Notice of Proposal to refuse an application to register as a manager in respect of a regulated activity when your fit person interview has not been successful. You have up to 28 days from the date the notice is served to make written representations. We are able to assist you to make representations and come up with a detailed action plan to address each of the reasons given to refuse registration. Please refer to our representations web page.
Depending on your situation, there is some comfort that a negative outcome of a fit person interview can be turned to positive if you successfully address any concerns highlighted by the CQC Inspector. For example regarding finances and training.