What is the Role of the Primary Care Network CQC Registered Manager and Who Should Hold This Position?
- 23 hours ago
- 6 min read
Sponsored by BAXCQC Consulting
Introduction
Who should be the CQC Registered Manager, and what does that role actually entail?
With neighbourhood health contracts on the horizon and more PCNs moving towards formal CQC registration, Tracy Green, Associate for BAXCQC Consulting, helps us think through this thoroughly as part of our partnership with BAXCQC.
This blog explores the critical questions that every PCN must consider and compares how adult social care has traditionally approached this challenge, with lessons that primary care can usefully apply.
What is a CQC Registered Manager?
The Registered Manager (RM) is a legally defined role under the Health and Social Care Act 2008. Every CQC-registered service must have one, and the person named in that role carries significant personal accountability for the safe and effective delivery of regulated activities.
This is not a figurehead role. It is not a title you hand to someone because they are the most senior clinician in the room. The RM is the person who, in the eyes of the CQC, is responsible for how care is delivered on a day-to-day basis: how risks are managed, how staff are supervised, how the service improves. The CQC can and does hold Registered Managers personally to account. That includes enforcement action against them individually.
The question you need to ask is not ‘who is the most obvious person?’ It is ‘who actually has genuine oversight of what happens in this service every day?’
The Nominated Individual: a different role entirely
It’s also worth knowing the difference between the Registered Manager and the Nominated Individual (NI), two roles that often get confused. The NI is required where the registered person is an organisation, and they hold accountability at a strategic and governance level. The RM holds operational accountability. In most PCN structures, the NI will sit with a GP partner or Clinical Director, while the RM sits with whoever is running the service day to day.
Think of it this way: the Nominated Individual holds organisational accountability. The Registered Manager holds operational accountability. Both roles need to be held by people who genuinely understand what they are taking on.
How should a PCN decide who the Registered Manager should be?
There is no one-size-fits-all answer here. What I would encourage you to think through is a structured assessment across four areas.
1. Who has genuine day-to-day operational oversight?
The CQC expects the Registered Manager to be identifiably in charge of how the service runs. If a Clinical Director is primarily focused on clinical strategy and partnership responsibilities, they may not have the operational bandwidth to fulfil this role effectively. A PCN Manager or Operations Manager who oversees staffing, governance, processes, and patient pathways is often far better placed.
2. Who has the capacity?
Being a Registered Manager is time-intensive. It involves engaging with CQC inspections, maintaining evidence of compliance, overseeing quality improvement, responding to incidents, and managing staff governance. This cannot be someone who is already stretched to capacity. The role will suffer. And so will the person carrying it.
3. Who will be present and accessible?
The CQC expects Registered Managers to be contactable, present in the service, and able to respond to concerns. A partner who splits time across multiple sites or is frequently in clinical sessions may genuinely struggle to meet this requirement. Not because of any failing on their part, but because of the practical reality of their role.
4. Who has the right knowledge base?
The RM must understand the regulatory framework, the CQC’s fundamental standards, the specific regulated activities being delivered, and the governance systems in place. This knowledge can absolutely be developed, but it must be genuine, not theoretical.
Practical tip: before making a final decision, consider mapping potential RM candidates against their current responsibilities, operational knowledge, capacity, and appetite for regulatory accountability. A simple SWOT analysis can make the decision much clearer.
Does the Registered Manager have to be a clinical partner?
No. And this is one of the most important things I want you to take from this blog.
There is an assumption in primary care that clinical seniority equates to regulatory accountability. It does not. A GP partner may have clinical authority and professional accountability, but that does not automatically make them the most appropriate Registered Manager.
In fact, appointing a Clinical Partner as RM can create real problems. Partners are often clinically busy, may not have detailed operational knowledge of all the services being registered, and may not have the capacity to respond promptly when the CQC comes knocking. Placing the RM burden on a clinician already carrying a full patient list is a risk to the quality of the registration and to the individual’s own well-being.
A non-clinical PCN Manager with strong operational oversight, governance experience, and the willingness to build regulatory knowledge can make an excellent Registered Manager. The CQC does not require the RM to be clinically qualified. They require the RM to be competent and accountable.
What matters most is that whoever holds the RM role has excellent working relationships with clinical leadership and the full confidence of the partnership. They cannot operate in isolation, but they do not need to be a GP.
Appoint the right person for the role. Not the most senior clinical person. Fitness for the RM role is about operational accountability, capacity, and regulatory competence.
What adult social care gets right, and what PCNs can learn
In adult social care, it is standard practice for the Registered Manager to be the person who actually runs the service: the care home manager, the supported living lead. The business owner takes the Nominated Individual role. The parallel for PCNs is clear: GP partners and the Clinical Director hold strategic accountability, while the PCN Manager or senior operational lead is the natural equivalent of the service manager and the person best placed to hold the RM role.
The RM role belongs with the person who runs the service, not necessarily the person who owns or funds it.
What skills and experience does a Registered Manager need?
The right RM needs operational management experience, a working knowledge of CQC’s regulatory framework and the five key questions, the ability to maintain governance records, and the personal resilience to carry accountability through inspections and enforcement.
Crucially, none of this needs to be in place from day one. It can be developed. What matters is the appetite to learn and the right support behind the person.
We’ve put together a full CQC Registered Manager: Responsibilities & Expectations document that you can download alongside this blog. It is designed to sit within an existing role rather than create a new post, and it includes a template your PCN can adapt to clarify what this role means in your specific context.
Getting registered is the first step. Like passing your driving test. The real work starts afterwards.
The changing landscape: at-scale working and neighbourhood health
One final thing worth flagging: the landscape is shifting. As PCNs move towards at-scale delivery and neighbourhood health working, the RM role will only become more complex: more sites, more services, more partners, more accountability. That is not a reason to delay getting the right person in place. It is a reason to do it properly, now, with the right support behind you.
Ready to take the next step?
CQC registration is not something to navigate alone. BAXCQC support Primary Care Networks through every stage of the process, from initial scoping through to post-registration compliance, and they understand the pressures of making this work in a busy primary care environment.
Don’t navigate CQC registration alone. The right preparation today protects your PCN and your patients tomorrow.
Get In Touch with BAXCQC today
Please email Kelsey Price at kelsey.price@baxendale.co.uk to find out more about the CQC registration process for PCNs, understand the timelines involved, and get expert guidance on identifying and supporting your Registered Manager.
About Us
THC Primary Care is an award-winning healthcare consultancy specialising in Primary Care Network Management and the creator of the Business of Healthcare Podcast. With over 20 years in the industry, we've supported more than 300 PCNs through interim management, facilitation, training, and consultancy.
Our expertise spans project management and business development across both private and public sectors. Our work has been published in the London Journal of Primary Care, and we've authored over 250 blogs sharing insights about primary care networks.
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