What is a location?

We register providers of services to carry on ‘regulated activities’, see our guidance on the scope of registration.

It is important to know where these regulated activities are being carried on at or from. This is so:

• we can monitor and assess providers
• people can identify the places they understand as a ‘service’
• people can easily access information from our website.

When you register, you must identify each ‘location’ in your statement of purpose where you propose to carry on a regulated activity at or from. Locations that meet the following ‘rules’ must also be included in your application form. We restrict your registration to only carry on the activity at or from these locations by using conditions of registration. If you add or remove a location, you must apply to vary your conditions of registration.

Here, we describe what ‘locations’ you must include in your application. Locations may be where a regulated activity is being:

• delivered to people and may represent a ‘service’ (for example, a care home or dentist surgery)
• organised or managed from but the regulated activity is carried out elsewhere (for example, a domiciliary care (home care) agency or community nursing service)

Multiple regulated activities, reflecting different services, may be carried on at or from the same location address. For example, a variety of different inpatient and outpatient services will take place within a single hospital location.

We have identified 9 rules to help define locations in a consistent and proportionate way.

If you are a provider who is based outside of England, but are carrying on regulated activity in England, you will be expected to supply an address in England.

This guidance supersedes the previous version of this guidance published in 2016.

Identifying your locations

To identify all the locations to be included in the conditions of your registration, work through the 9 rules.

Read the additional guidance to identify who is responsible for the regulated activity (and location) when:

• partnerships, jointly funded, integrated care or other arrangements are in place; and
• services are operated between or on behalf of service providers in a range of places.

Once you are registered, your registration certificate will show the address and CQC ID for each location included in the condition that is applied.

What is not a location?

A location is not:

• the private address of a person who uses services
• a PO box address (those that don’t have a full address and post code) used as a location or provider address.

The 9 location rules in detail

Location rule 1: A place to which people are admitted for the purpose of receiving a regulated activity to meet healthcare needs

Under this rule we consider people to be admitted where the place is not their main or sole place of residence.

It includes where people either:

• stay overnight within that place, or within a defined area of that place (such as a prison hospital wing), for the specific purpose of receiving the regulated activity
• use beds, trolleys, couches or reclining chairs provided for recovery following procedures delivered in an operating theatre, dialysis room, endoscopy room or treatment room. This excludes recovery rooms within a GP or dentist’s surgery
• are detained there under the Mental Health Act 1983, other than under a section 135 or 136.

Regulated activities may be carried on at or from a group of buildings (for example, acute hospital services). You may apply to register to carry on any regulated activities from the group of buildings as one ‘location’. The address for that location will be the postal address for one of the buildings within that group of buildings. You may select which of the buildings it is most logical to give as the address. For example, this may cover a large hospital site that people would reasonably recognise as a distinct, single location, even if it comprises multiple buildings across a large area, possibly intersected by roads.

An NHS trust or independent hospital provider may manage a satellite clinic located away from a hospital location’s postal address. For example, an outpatient clinic a few miles away that is managed and overseen by the same management team as the hospital. Provided that the clinic does not admit patients into a bed for treatment, you can consider the satellite clinic as part of the same location.

These criteria apply to services including, but not restricted to, acute hospitals, community hospitals, mental health hospitals, day surgery units (including for surgical termination of pregnancy), and stand-alone dialysis or endoscopy services.

Location rule 2: A place in which people live as their main or sole place of residence or in which they are educated, and they receive care or treatment there

This rule includes, but is not limited to, these types of services:

• Care homes where people are accommodated and receive personal care and/or nursing care
• Substance misuse services where people receive accommodation together with treatment
• Further education establishments where students are accommodated and receive nursing and/or personal care

A location is where you provide residential accommodation that is contractually bound together with treatment or care for people who regard the accommodation as their home or their main or sole place of residence, if:

• People regard the place as their home because they have a tenancy, licence and/or contract that gives them rights both:
  • as a resident of that accommodation, and
  • to receive care or treatment in that accommodation.
• The tenancy or contractual agreement binds together the provision of the accommodation and the provision of the care or treatment.
• Where the tenancy or contractual agreement binds together the accommodation and the care or treatment, but those elements are provided by legally distinct entities, it will be the service provider who directly provides the regulated activity that:
  • is required to be registered, and
  • must cite the place as a location
• People receive accommodation together with care for the purpose of respite care away from their usual care setting.
• You deliver care to people to whom you are also providing further education (for the purposes of paragraph 4 of Schedule 1 of the Health and Social Care Act (Regulated Activities) Regulations 2010).

A location could be made up of several buildings grouped closely together and managed together (for example, they share a manager and staff).

An NHS trust providing care home services (for example, providing assessment or respite care to people with mental health problems or learning disabilities), should identify these locations using this rule or rule 1, depending on where the care home is located.

A place is not a location under this rule where the address is a person’s ‘private address’. These are common indicators that an address would be considered a ‘private address’:

• The person may have lived at the private address for some time before supportive care services were required and supplied.
• The private address is either:
  • a home privately-owned by the person or
  • they have a tenancy agreement that does not, in any way, bind together the provision of accommodation with the provision of care or treatment.

Examples of places that are not a location under this rule might include these types of accommodation:

• a privately-owned home
• a home rented from a local authority, housing association or private landlord in which the tenancy agreement does not include the provision of care
• the individual houses where people live under a supported living scheme
• Extra Care Housing schemes where people rent or buy their own accommodation
• lived in care arrangements where the carer lives in the person’s private home
• where people live with someone else under a shared lives scheme.

Location rule 3: An urgent treatment centre

Urgent care services can be provided at a range of urgent treatment centres. Examples of urgent treatment centres may include a:

• walk-in-centre
• minor injuries unit
• urgent care centre

Urgent care services may be provided by primary care providers, trusts and independent providers.

To be a location in its own right, an urgent treatment centre must be:

• where a permanent urgent care service is delivered, and
• the place where one or more regulated activities are provided under the direct control and management of the service provider.

A location is the place where this service is delivered.

If the place does not fulfil these criteria, it is not a separate location but included within your headquarters (HQ) or another location address (read rule 9).

Where other community health providers that require registration deliver services within the same place as an urgent care service location, those providers should refer to rule 9. This is because their services are likely to be delivered in a range of places in the community but managed from another administrative base (for example, the provider’s headquarters).

Location rule 4: The premises where a primary care provider carries on regulated activity

This rule includes, but is not limited to, these types of services:

• primary medical care (GP)
• primary dental care
• primary out-of-hours
• community substance misuse
• sexual assault referral centre (SARC)

GP

The location is a surgery where medical care is provided at or from.

• If one or more branch surgeries are associated with a main GP surgery, each branch surgery will not be a location as long as only patients from the same registered patient list are seen or treated at the branch. All branch surgeries must be listed in your statement of purpose
• For the purposes of this rule, branch surgeries will be locations if there is a different registered patient list to that of the main surgery.

Dental care provider

The location is the surgery where dental care is provided at or from.

Primary out-of-hours service

The location is the place from where:

• the primary out-of-hours service is run
• calls are received
• healthcare professionals are dispatched and co-ordinated from
• patients are asked to attend in order to see a healthcare professional.

The primary out-of-hours service location is not:

• the various vehicles used, or
• the homes or places that healthcare professionals visit when seeing patients.

Community substance misuse services

These are typically delivered from one or more locations (sometimes referred to as ‘hubs’) where a regulated activity is carried on. These hubs are an administrative base and people attend these locations for assessment, care planning, key-work, group work, detoxification, maintenance prescribing, and other related activities.

A substance misuse location (or hub) will be:

• where regulated activity is provided on an ongoing basis, with staff presence
• where records and equipment are stored
• services are delivered from a permanent place

These locations (hubs) may have satellite sites (sometimes called ‘spokes’) where dispersed activities are carried out in the wider community. For example, these may include weekly recovery support groups in a local community centre, detoxification support in a local pharmacy, or weekly assessment drop-in clinics at a range of supported living services. These ‘spokes’ are not locations in their own right, but will come under the hub location if:

• they are not permanent bases or services (for example, regulated activity may only be provided once a week) and places may vary over time, and
• activity is organised from the main location (hub)

All location (hubs) and satellite sites (spokes) must be listed in your statement of purpose.

Sexual assault referral centres (SARCs)

These are places where medical, practical and emotional support services are provided to survivors of rape and serious sexual assault, both adults and children. Some services are only open at certain times of day, but more commonly they are a 24/7 service. Centres that are run by independent healthcare providers are usually stand-alone services that each constitute a location.

Occasionally they may operate on a ‘hub’ and ‘spoke’ model, as described above under community substance misuse services.

Shared premises

If two or more legally distinct providers of primary care services carrying on a regulated activity share premises, each provider must include the premises as a location.

Where other community health providers that require registration provide services within the same premises as any primary medical care service location, those providers should refer to rule 9. This is because their service is likely to be delivered in a range of places in the community but managed from another administrative base (for example, the provider’s headquarters).

Location rule 5: A premises from which a provider organises or manages a regulated activity that is delivered to people in their homes

This rule includes, but is not limited to, these types of services:

• domiciliary care (home care)
• supported living
• extra care housing
• live-in services
• Shared lives schemes
• nursing agencies

Read our guidance on Housing with care services.

A location is each premises from where the activities of those staff you supply to deliver regulated activities in people’s own homes are directly managed. These premises will usually be offices. If there are multiple locations (offices) these may be referred to as ‘branches’. A location may be at the same address as a business address or HQ.

A location is any given setting that is a place where care is routinely planned, co-ordinated and the regulated activity is managed across the geographical area covered from that location in an effective way. For example, this includes where records relating to the management of the regulated activity are maintained and/or where staff management activities take place (meetings, supervisions, training, etc.). This may include local office bases within sheltered housing or supported living complexes.

For NHS trusts providing domiciliary care services (home care) to people in their own homes, rule 1 may apply if the office is based within a hospital site.

If a model of care uses virtual/online organisational arrangements rather than physical office premises, rule 9 may apply.

A location is not:

• a private home, where that private home is not the primary place from where the service is managed
• a facility only used for storing records or another purely administrative function
• temporary premises, such as hotels or serviced offices used for short periods as a convenient location for recruitment
• premises used solely as accommodation addresses to receive mail or diversion of phone calls
• premises where a person receiving care lives.

Supported living services

A location is the premises from where the service provider co-ordinates the care provided to people who they support across all places where those people live.

A location is not usually the individual places where people live who receive care. This is the case even if staff have a room on the premises where they keep some records with the permission of the people living there.

An exception may be where:

• an office based in a Supported living house/premises is separate from people’s personal living space and
• it is the only office from which the provider manages the care delivered to all people who they provide support to in an area.

Examples of locations under this rule might include:

1. Provider A provides personal care to people in their own private homes from one office, which is also the provider’s HQ. This main HQ office supports the staff team who work out in the community from this location. (Support could be booking the work, processing timesheets, supervising staff and providing training.) This HQ office will be the sole location for the service provider.
2. Provider B provides personal care to people in their own private homes from six ‘branch’ offices located across a large geographical area. Each branch office supports the staff team who work out in the community from that office, co-ordinating the service delivered in that geographical area. The provider also has a HQ office from which no care services are managed and a records storage facility on an industrial estate. Each of the six ‘branch’ offices from where the care services are managed is a location. The provider HQ and the records storage facility is not
3. Provider C provides a range of services including personal care to people in their own homes and to people who live in supported living accommodation. People living in the supported living houses might need various hours of support from staff as they will have individual needs. Provider C might provide 24-hour support with a regular staff team working in people’s houses. Although staff working in the supported living houses have a small base in each house to keep the care records of the people who live there, all staff are managed from one office which is also the provider’s HQ. The HQ is the location for the service provider, not the individual houses where care is provided.
4. Provider D works in the same way as Provider C but has only one supported living house in which care is provided. The staff and business are managed directly from a substantial office in the house itself. The house address itself will be the location for the service provider.
5. Provider E operates a Shared lives scheme. The provider arranges accommodation at a carer’s home (which might be owned or rented by the carer) for people who may need support with specific needs (such as learning disabilities or mental health). The carers’ homes are not locations in their own right but will come under the provider’s office where they manage the scheme. This is their sole location and may also be the provider’s HQ.

Location rule 6: A place from where an ambulance or patient transport service is managed

Where an ambulance or patient transport service is operated and managed by an English NHS body:

• all services, wherever they are provided from, are one location under the service provider’s headquarters’ address.

Where an ambulance or patient transport service is not operated and managed by an English NHS body (that is, an independent ambulance provider):

• where operating in a single region – the regional headquarters (the place from which operational management takes place for the region) will be a location. This may also be the service provider’s headquarters
• where operating across multiple distinct regions – each regional headquarters is a location. A regional headquarters is where operational management for a region takes place. You must designate regional headquarters and determine the size and boundaries of each region depending on what is practicable for day-to-day operational management of the service by the same registered manager. You are responsible for ensuring that the arrangement is practicable, bearing in mind that inability to do so may call into question your fitness to manage the service. One of the regional headquarters may also be your headquarters.

These are not locations (for either NHS or independent providers):

• a vehicle
• an ambulance station (unless an ambulance station is at the same place as a location)
• a place where a vehicle is temporarily parked, landed or anchored as a holding or stand-by point
• a place where a vehicle is parked, landed or anchored while responding to a call for assistance

Location rule 7: A stand-alone permanent diagnostic or screening facility

A location is where a provider carries on the regulated activity of diagnostic and screening procedures, providing a service to people in a stand-alone, fixed site facility used for the purpose of undertaking such procedures. By stand-alone we mean that the facility is not based within any of your other locations (for example, within a hospital).

Examples include stand-alone health assessment services, CT or MRI scanning services, and fetal screening services. It includes medical laboratories that directly receive people in order to remove samples and specimens as well as laboratories that only analyse samples.

If you carry on regulated activity from one or more permanent stand-alone facilities, each of these is a location.

The following are not locations:

• mobile facilities: if you also have permanent facilities, you can select which of your other locations the mobile facilities will come under. If you have no permanent facilities, the mobile facilities will come under a location at your HQ/business address - read rule 9.
• a small medical laboratory that is a satellite of a larger medical laboratory: this comes under the main laboratory location
• a stand-alone diagnostic and screening facility run by an NHS trust: if it is part of services delivered at or from a hospital location but not based on a main hospital site, this is a satellite of the main hospital location.

Other facilities that are not locations in their own right must still be described in your statement of purpose.

Location rule 8: A location is a place from where urgent remote clinical advice and triage are managed

This rule only applies to “medical advice” in cases where immediate action or attention is needed, or triage provided, over the telephone or by email by a body established for that purpose. It includes services such as NHS 111.

All of the services are provided remotely:

• there is no face-to-face contact with people who use the service
• there are no places in which people are treated.

For the purposes of this rule, you must group all urgent medical advice services into one location at your headquarters or designated business address.

Service providers who operate an ambulance service alongside urgent remote clinical advice will be captured under rule 6.

Location rule 9: A place identified as the location when regulated activities are being delivered at or managed from places that would not constitute a location under rules 1-8

Regulated activities may be delivered at or from places that do not meet any of rules 1-8.

Where it is not possible to identify the place where a regulated activity is being carried on from under rules 1-8, the regulated activity may be considered to be delivered or managed from your headquarters (HQ) or business address. In this instance, your HQ or business address is the location.

Examples of services that may be included under the service provider’s HQ or business address as the location include:

• Community services provided in a variety of settings. These include health visiting, district and school nursing services, community mental health teams, hospital-at-home, palliative care. Settings may include a primary medical service, health centre, community centre, supermarket, or people’s private homes. If you are not carrying on and managing the regulated activity from one of these places on a permanent and regular basis:
  • these places are not locations in their own right but may be considered ‘satellites’, if the regulated activity is managed from another location such as an HQ.
  • you must include the individual addresses of any satellite locations in a statement of purpose.
• Mobile medical facilities such as mobile surgical, endoscopy or diagnostic imaging services that are carried on in a vehicle that travels to different places to provide the regulated activity. Such vehicles are not locations. If there is no other permanent location where the regulated activity is carried on, the vehicles you use to carry on a regulated activity will come under a HQ location. Your statement of purpose will describe your use of these vehicles in carrying out the regulated activity.
• Healthcare professional or a partnership of healthcare professionals carrying on a regulated activity:
  • from a consulting room (which does not fall into any of the previous rules), the location is the address from which that regulated activity is provided.
  • where the service provider travels to a variety of places to provide the care or treatment to people (for example in the person’s permanent private residence or temporary address such as a hotel) the location can be the address from where services are managed, which may be a HQ or business address.
• Online primary care services where providers deliver a regulated activity through an online means only. This involves:
  • transmitting information by text, sound, images or other digital forms to deliver care and treatment to patients and to follow this up. Examples include providers that only deliver healthcare consultations by video link and providers prescribing medicines in response to online forms.

Additional guidance

This section contains additional guidance on identifying locations where regulated activities are carried on between or on behalf of service providers in a range of places and partnership, jointly funded, integrated care or other arrangements are in place.

Formal or informal arrangement for the provision or subcontracting of services

The Health and Social Care Act 2008 requires that "any person" who carries on a regulated activity must be registered to provide that activity. "Any person" can be an individual (sole trader), a partnership or a body other than a partnership - such as a local authority, NHS trust, limited company, or voluntary body.

There are many examples where a service provider may enter into a formal or informal arrangement for providing or subcontracting of services that has an impact on deciding:

• firstly, who the registered person is, and
• secondly, the locations that must be included in a service provider’s statement of purpose.

Examples could include, but are not limited to:

• A section 75 arrangement (National Health Service Act 2006, or, previously section 31 of the Health Act 1999) where a service is being jointly funded by an NHS trust and a local authority
• Services provided by service provider A on service provider B’s premises for the benefit of service provider B’s service users.
• Services provided by service provider A on service provider B’s premises for the benefit of service provider A’s service users, under either temporary or longer-term arrangements.

Section 75 of the Health Act 2006 enables local authorities and NHS bodies to cooperate in providing some of the services they are each obliged by law to provide. Section 75 agreements do not usually constitute a new, separate legal partnership and each body that provides a regulated activity must be registered. In general, the person (‘body’) who should be registered to provide any particular regulated activity is the body (NHS trust or council) that has the original statutory power or obligation to provide that service (as they are the one that retains accountability for it).

CQC also takes this principle to apply to any other informal or formal partnership or subcontracting arrangement in terms of identifying who is the “person” who must be registered. Providers must be clear about which one of them has responsibility for the direction and control of regulated activities they are providing under the Health and Social Care Act 2008. They should make this clear in contracts, service level agreements and other documents. If multiple entities all carry on the regulated activity, whether separately or together, then unless they are individuals that form a partnership, they must all be separately registered and the location rules apply to each of them.

It is important that the service provider who ultimately holds responsibility is the registered person for the purposes of registration, compliance and enforcement.

Service providers must register for each of the regulated activities they provide. Even when providing activities in partnership with other providers, each service provider who must be registered will need to apply the location rules 1-9 to each part of their service for the regulated activities they are applying for.

NHS trusts and independent hospitals

Examples could include:

Example A: NHS trust A provides a range of community health services that come under the location of the trust’s headquarters. NHS trust A and local authority B jointly manage a crisis response service that is formalised under a Section 75 Agreement (National Health Service Act 2006). The response service is delivered by integrated multi-professional teams; it provides a single point of contact and a range of health and social care services including community intermediate care, a number of community hospital beds and a residential care facility. Both NHS trust A and local authority B will need to include this integrated service in their registration. Each will have to register the aspect of the service for which they have overall accountability. For NHS trust A, this will be included in their NHS trust’s headquarters location.

Example B: NHS trust C is a foundation trust hospital providing specialist nursing and medical staff to NHS trust D, an acute hospital. It does this under a service level agreement to carry out services that fall within a range of regulated activities and that are carried out in a number of departments across trust D’s hospital sites. The patients are the responsibility of trust D. Trust D holds the responsibility under the Regulated Activities regulations for ensuring that the staff it is using from trust C are fit and is overall accountable for the delivery of that service, even though it is being delivered by trust C’s staff. In this case, trust C is not required to include this service within its own application for regulated activities, and it does not need to list the locations belonging to trust D within that application.

Example C: NHS trust E is a specialist hospital and receives referrals for specialist treatment for patients from NHS trust F. Usually, patients from trust F travel to trust E’s premises, but, as this is in a different city, trust E is piloting the provision of a specialist service within trust F’s premises once a month so that patients don’t have to travel long distances. In this case, trust E is the service provider with responsibility for the patients as they have been referred from trust F, so trust E must include this monthly service location within its registration. Depending on whether the service falls into location rules 1 to 4 above, NHS trust E may either list the premises it uses at NHS trust F’s hospital as a separate location in its own right, or, include it as a satellite outpatient clinic serving one of trust E’s acute hospital locations. In either event, trust E will be responsible for ensuring that the part of trust F’s premises it is using for carrying on the regulated activity meets relevant regulations. In addition, if the premises being used is defined as a location and the pilot is discontinued, trust E will need to apply for a variation to its conditions of registration to remove that location. In this example, trust F is not required to include this service within its own application for regulated activities.

Example D: NHS trust G has negotiated a temporary lease arrangement with a local independent hospital service provider H. This is for use of the independent service provider’s premises to provide surgical procedures while its own premises are being upgraded. Trust G’s staff carry out the surgical procedures, but the post-operative recovery is provided by the independent hospital provider H’s staff under a service level agreement. Trust G is the service provider as it holds overall responsibility for the patients, even though they are being treated in the independent hospital’s facilities and with shared care provided by provider H’s staff. Trust G will be responsible for ensuring that the parts of the independent service provider’s premises that it is using to carry on the regulated activity meet relevant regulations, and that the staff providing post-operative care or treatment for its patients satisfy the fitness regulations. In this example, as surgical procedures and post-operative care are being provided, the locations criteria for listing this as a separate location on trust G’s registration will apply even if this is a temporary arrangement (read rule 1). In addition, if the premises being used is defined as a location and the temporary arrangement is discontinued, trust G will need to apply for a variation to its conditions of registration to remove that location.

Example E: Independent hospital service provider J runs a private patient unit within NHS Trust H’s premises and has a registered manager on site. There is a formal lease arrangement for the use of the ward space, operating theatres and other clinical and ancillary services. The nursing staff are employed by independent service provider J, consultants work under practicing privileges arrangements with service provider J, all other staff work under the service level agreement. In this example, the service provider is the independent hospital and will need to include this place as a location in its own right within its registration. In this example, trust H is not required to include this service within its own application for regulated activities.

For other service providers it is less likely that the type of ‘hosting’ arrangements would include the hosting of services that, in themselves, would be regarded under rules 1 to 8 as separate locations.

Where two separate service providers are involved with a service that would trigger that place as a location under rules 1 to 9 for both providers, you can use the NHS scenarios in examples a) to e) above to determine how they should be managed for the purposes of this guidance.