CQC Registration Opinion for an Expanding Clinical Pharmacy Provider

A fast-growing clinical pharmacy provider in Greater London approached PCMS with a key question: did their evolving model of care require CQC registration?

Operating across GP practices and PCNs, they had built a strong reputation for delivering pharmacist-led support in areas like medication reviews, structured medication counselling, and long-term condition management. But as their services became more patient-facing, particularly with remote consultations and independent prescribing, they needed clarity on whether they were now crossing into regulated activity territory.
The stakes were high. Registering unnecessarily could mean extra cost and compliance burden. But failing to register when legally required could put the organisation and its commissioners at serious regulatory risk.

That’s when they turned to PCMS.
We began with a full audit of their service model, including the nature of their patient interactions, staffing structure, and contractual obligations. We mapped each element against the CQC’s regulated activities, paying particular attention to Treatment of Disease, Disorder or Injury (TDDI) and Diagnostic and Screening Procedures.
Using our in-depth knowledge of CQC guidance and inspection trends, we provided the provider with a formal, evidence-based opinion on whether registration was necessary based on how they were currently operating and where they were planning to go next.

Crucially, our guidance didn’t stop at a yes or no answer. We outlined:
• The specific services that would trigger registration if expanded.
• Scenarios in which remote prescribing or clinical triage might fall under regulation.
• Governance steps they should take if they decided to pursue registration later.

For this provider, working with PCMS meant more than just compliance. It meant peace of mind. They left the process fully informed, with a clear path forward that aligned both with their business goals and regulatory expectations.