Dual registration and Nominated Individual oversight at scale

1. We designed accountability before preparing the application

The first deliverable was a dual-registration operating protocol. It defined which provider held day-to-day operational delivery, which held independent assurance and oversight, how information would move between them, where decision rights sat, the escalation thresholds and the response required in high-risk scenarios.

The protocol covered safeguarding referrals, unexpected deaths, serious incidents, local authority embargoes, enforcement activity and media interest. By addressing these scenarios in advance, we removed the ambiguity most likely to concern the regulator.

2. We built the governance suite around the Nominated Individual

We developed terms of reference for a board-level quality and safety committee, an escalation matrix and a quality dashboard with defined measures and reporting cadence. The arrangements were mapped to the CQC Single Assessment Framework, with particular attention to the Well-led quality statements on governance, management and sustainability, and shared direction and culture.

3. We prepared the people as well as the documentation

We assembled Fit and Proper Person Requirement evidence packs for the provider's directors. In parallel, we structured the Nominated Individual arrangements to satisfy Regulation 4 in substance, including DBS and supporting evidence, so the role was demonstrably ready to operate rather than being treated as a nominal appointment.

4. We submitted more than 10 locations as one coherent package

Every statement of purpose, address, regulated activity and service-user band was consistency-checked across more than 10 locations before submission. This reduced the risk of avoidable regulatory queries and ensured that the operating model was presented as one joined-up arrangement.

5. We managed engagement with CQC actively

We established a single named point of contact, anticipated likely questions in the application narrative and provided same-day responses to matters raised by CQC.

THE REGISTRATION RESULT

Registered within approximately two months across more than 10 locations.

At the time, CQC guidance indicated around ten weeks for a complete, straightforward single application. Novel structures covering multiple locations would ordinarily be expected to take longer.

Following registration, Fulcrum was appointed as Nominated Individual for the newly registered provider. Under Regulation 4, this role carries responsibility for supervising the management of the regulated activity. We therefore treated the appointment as an active governance function, not a post-registration formality.

The Nominated Individual model included:

• A defined portfolio oversight cycle, with each service visited, reviewed and evidenced on a planned rhythm rather than only when concerns arose.
• Independent mock inspections against the CQC Single Assessment Framework, led by consultants with former inspection experience and providing a separate assessment from the operator's own quality assurance.
• Data-led early warning, using trends in falls, pressure care, medicines errors, safeguarding, staffing and turnover to identify deterioration before it became a single serious event.
• Direct challenge and action tracking, with findings assigned, escalated and re-tested so that closure was evidenced rather than assumed.
• Board reporting translated into regulatory language, enabling investment decision-makers to understand both resident risk and provider accountability in the terms CQC would use.
• Direct interface with CQC, including notifications, information requests and inspection engagement.
• An independent line of sight across the operator, local management and the provider board, creating a second and differently motivated source of assurance.

THE NOMINATED INDIVIDUAL ASSURANCE CYCLE IN PRACTICE

Supporting portfolio records demonstrate how the Nominated Individual model operated after registration, linking on-site oversight, independent inspection, direct feedback, remote record testing and follow-up verification.

The wider evidence base also shows how the Nominated Individual function moved beyond reporting and into verification:

• Repeat assessments demonstrated material improvement at several services, including services that progressed by one or more assurance levels while residual risks remained under active review.
• Where improvement had been achieved, our follow-up approach continued to distinguish progress from unresolved safety risks requiring active review.
• At one service, significant operational concerns identified through NI oversight were subsequently addressed and verified through follow-up.
• At another service, follow-up oversight confirmed stable staffing, no current medicines concerns, stronger person-centred care planning, improved Mental Capacity Act and best-interest documentation, active governance and completion of environmental actions.

These examples relate to Fulcrum's independent assessments and Nominated Individual oversight. They are not presented as statutory CQC rating changes.