CQC to regulate diagnosis-only ADHD and autism assessments

On 9 October 2026, alongside the Fonagy review (the independent review into mental health conditions, ADHD and autism), the government asked the Care Quality Commission (CQC) to regulate all ADHD and autism diagnostic assessment, including services that diagnose but do not treat. Nothing changes until new regulations are made, and no date or draft has been published.

What this means for you

• If you only diagnose, you do not need to register with CQC today, but you should expect to in future.
• If you diagnose and treat, and a doctor, nurse or other listed professional gives or supervises the treatment, you should already be registered. Your assessment work may get more attention at inspection.
• DHSC says NHS-funded, non-NHS-funded and self-funding patients will all be covered, so Right to Choose and self-pay assessments are both in scope.
• CQC regulates services in England. Scotland, Wales and Northern Ireland have their own regulators.

This piece is part of our series on the Fonagy review.

Every ADHD and autism diagnostic assessment is set to come under CQC#

The final report of the independent review chaired by Professor Peter Fonagy recommends making all ADHD and autism diagnostic assessments a CQC-regulated activity (Recommendation 5, p444).

The same day, CQC said: "The Department for Health and Social Care (DHSC) have asked us to regulate all diagnostic assessments for autism and ADHD, once new regulations are in place."

DHSC says it is working towards this. The Health Secretary, quoted in the press release, and Minister Alison McGovern, in her speech, put it more firmly: all ADHD and autism assessments will come under CQC regulation. The government has committed to the policy, but the law has not changed yet.

Nothing announced makes scope depend on funding or remote delivery#

DHSC says the change will cover NHS-funded, non-NHS-funded and self-funding patients. Funding does not change the answer: an assessment-only clinic with a mix of Right to Choose and self-pay patients would be in scope for both. Neither CQC's guidance nor the announcements make registration depend on whether you assess in person or remotely.

ICBs must also improve oversight, but no advertising ban was announced#

Other measures came with it. All ICBs must improve oversight of the ADHD and autism assessment services they commission. The Health Secretary will write to the Advertising Standards Authority about adverts for ADHD and autism services. NHS England will consult on national prices, and NICE will look at what the review means for its guidance. The review had recommended banning direct-to-public advertising of NHS-funded assessments; no ban has been announced.

The ADHD Taskforce and the Ombudsman had already called for CQC oversight#

The ADHD Taskforce's final report, published on 6 November 2025, already said CQC should have oversight of all ADHD service providers (see our Taskforce summary). In August 2026 the Parliamentary and Health Service Ombudsman recommended the same for NHS-funded providers that only assess, calling the gap something that "should be addressed urgently".

The Fonagy review wants CQC registration because commissioners often cannot see what they buy#

The independent market grew faster than the checks on it#

The review describes a market that outgrew its checks. It reports that:

• independent providers now carry out more than half of NHS-funded ADHD assessments and more than a third of autism assessments (p18)
• spending on independent-sector ADHD services rose by around 252% in three years, with a projected £164 million overspend in the areas analysed (p18, citing the Centre for Health and the Public Interest)
• only around 10 of about 120 ADHD providers submitted data (p329)
• some providers delivering NHS-funded ADHD assessments were working without CQC registration, though the review says the scale is not known (p267)

The review says this is not a criticism of independent providers in principle (p18). Its concern is that commissioners often cannot see what they are paying for.

The review pairs registration with standards and data, which are not yet committed#

The review sees registration as part of a package. Recommendation 5 puts CQC registration alongside common quality standards, data reporting and oversight (p444). So far the government has committed to CQC regulation and closer ICB oversight, but not to the standards or the data condition. It also asks every provider, including Right to Choose, to submit activity, quality and outcomes data as a condition of funding and accreditation, with NHS-funded and private referrals reported separately (p445). We cover the data side in Right to Choose data reporting.

Today the law leaves diagnosis-only services outside CQC#

Where does your service sit?Pick what you provide to see why.What you provideTodayOnce regulations are madeDiagnosis onlyToday:Registration not requiredLater:Expected to be regulatedDiagnosis and treatmentToday:Usually requiredLater:Usually already in scopeTitration or prescribing onlyToday:Usually requiredLater:No change announcedPost-diagnostic support onlyToday:Depends who delivers itLater:No change announcedDiagnosis only. Today: Registration not required. Once new regulations are in place: Expected to be regulated.Diagnosis only, todayCQC does not count diagnosing ADHD or autism as treatment.Once regulations are madeDHSC has asked CQC to regulate all ADHD and autism diagnostic assessment. No date yet.Not yet known–When the regulations will be made or take effect–Which regulated activity assessment will come under–Whether there will be a consultation–Fees and timescales for newly regulated services–How services already running will move acrossStatus as of 10 October 2026. Sources: CQC, Scope of registration: treatment of disease, disorder or injury (page last updated 27 August 2026); CQC and DHSC announcements, 9 October 2026.

Diagnosis-only services are out of scope today and expected to come in. Services that diagnose and treat with a doctor or nurse involved are already in. Nothing has been announced for titration-only services, and for post-diagnostic support it depends on who delivers it.

CQC does not count diagnosing ADHD or autism as treatment#

ADHD and autism services usually need to register because they provide "treatment of disease, disorder or injury", one of the activities listed in the 2014 Regulations. It covers treatment given or supervised by a listed healthcare professional, such as a doctor or nurse, or by a multidisciplinary team that includes one. For mental disorders, treatment by a social worker counts too.

CQC's scope guidance, last updated on 27 August 2026, says CQC does not count diagnosing ADHD or autism as treatment. A service that only diagnoses does not need to register for it, and CQC's announcement confirms current law does not let it regulate them. The Ombudsman's report notes that the separate "diagnostic and screening procedures" activity does not apply either, because the wording of the current regulations leaves ADHD and autism diagnosis out of scope.

Psychology-led teams can sit outside CQC even when they treat#

Psychology-led teams are a second gap. Clinical psychologists are not on CQC's list of professionals for the treatment activity, so a standalone psychology-led service, such as an autism assessment team, can sit outside CQC even when it offers therapy, as long as no listed professional (such as a doctor or nurse), or social worker treating a mental disorder, is part of the treating team. The announced wording, all diagnostic assessments, would bring their assessments in, but how the regulations will define scope is not yet known.

CQC regulation timeline: no date yet; NHS payment changes intended from April 2027#

CQC and assessment: what has a date so farHappenedTiming givenNo date yet6 November 2025ADHD Taskforce final reportSays CQC should oversee all ADHD service providers. NHS England ↗31 March 2026Interim review reportSets out the evidence so far, with no recommendations. DHSC ↗August 2026Ombudsman reportRecommends bringing NHS-funded assessment-only ADHD and autism providers into CQC registration. PHSO ↗27 August 2026CQC scope guidance last updatedSays diagnosis-only ADHD and autism services do not need to register. CQC scope guidance ↗9 October 2026Final review and CQC announcementThe review recommends CQC regulation of all diagnostic assessment. DHSC asks CQC to do it. CQC news ↗Still to comeLater this yearMental Health StrategyThe government's full response to the review. DHSC press release ↗No date givenNHS England price consultationNational prices for NHS-funded assessment, post-diagnostic support and follow-ups. DHSC press release ↗From April 2027New NHS payment arrangementsNHS England intends to bring in final payment arrangements. DHSC press release ↗No date givenNew regulations for diagnostic assessmentNo draft regulations, consultation or timetable published. DHSC press release (no date given) ↗Status as of 10 October 2026.

Six details of the new regulations are still unpublished#

As of 10 October 2026, none of the following has been published:

• a date for the regulations to be made or take effect
• which regulated activity will be used: a new one or a change to an existing one
• whether there will be a consultation
• registration fees and timescales for newly regulated services
• how services already running will move into registration
• what CQC will inspect assessments against

Our reading is that closing the gap will need ministers to amend the 2014 Regulations. It has been done recently: CQC's 27 August 2026 guidance update followed a government change that brought treatment at events into scope. No source gives a timetable for assessment.

The Mental Health Strategy and new NHS prices have rough timings#

Two related commitments have timings. The government's full response will come in a Mental Health Strategy later this year. NHS England will consult on national prices for NHS-funded assessment, post-diagnostic support and follow-ups, with new payment arrangements intended from April 2027. (The interim report of 31 March 2026 made no recommendations.)

The review's proposed standards are the clearest guide to what inspectors may ask#

CQC has not said what it will assess diagnostic services against. Today it uses one framework for every service type; our guide to CQC evidence for ADHD and autism services explains it. In 2026 it consulted on draft frameworks for four sectors, including mental health care, but has not yet published final versions.

Whether CQC builds the review's standards into inspection is not known. They are still the clearest guide to what an inspector may ask to see in an assessment record. Our article on the review's assessment standards goes through each one.

The standards cover co-occurring conditions, remote assessment and assessor training#

The review proposes standards in Recommendation 5:

"Standards should require assessment of co-occurring conditions and functioning, clear guidance on when remote and in-person assessment are appropriate, and consistent training standards for assessors." (p444)

For autism, the review adds more consistent recording of what was assessed, the conclusions reached and the support recommended, and a formulation and summary of needs whatever the outcome (p179).

Remote assessment may get a closer look#

Nothing announced makes remote work change scope, but it may still get a closer look. Independent providers who responded reported around 90% remote delivery of autism assessments, a figure the review cites from the Independent Healthcare Providers Network report (p165), and the review lists "not face to face" among the conditions that make misdiagnosis more likely, as our article on the review's assessment standards explains. Our reading, not CQC's, is that remote-only services should be ready to give a written reason for each case; our guide to remote ADHD and autism assessments covers when video works.

Registering with CQC can take months; the people side likely takes longest#

This is what CQC asks of any new provider today. The route for newly regulated assessment services may differ.

• CQC asks you to apply only when everything is in place to run the service, including staff and locations. Running a regulated activity without registration is an offence.
• CQC says its assessment can take a few months.

Organisations need a registered manager, and your main contact's DBS check usually takes up to 60 days#

• Organisations and partnerships need a registered manager, who shares legal responsibility with the provider. They must show management experience and hold an enhanced DBS check countersigned by CQC.
• Your main contact also needs a DBS check, which CQC says usually takes up to 60 days.

We expect the people side, such as finding an experienced registered manager and getting DBS checks back, to take longest.

You also need a statement of purpose, and CQC may interview you and visit#

• You need a statement of purpose, which is a legal requirement, and supporting documents for the service you plan to run.
• CQC may hold a fit person interview and visit your premises. For online services, the registered location may be your head office.

Six steps now cover most of what CQC asks of registered providers#

None of this is legally required of a diagnosis-only service yet, but CQC already asks registered providers for most of it.

1. Pick a registered manager: a named person with the time, authority and management experience to apply.
2. Write a statement of purpose: what you provide, for whom, and whether you assess in person, remotely or both.
3. Set up governance: an audit programme, minuted meetings with tracked actions, an incident log, a risk register and a complaints log.
4. Tighten assessment records: consent, questionnaires, what informants said, how you considered co-occurring conditions and functioning, how you reached the conclusion, and why you assessed remotely or in person.
5. Keep training and safeguarding records: assessor training, supervision and sign-offs (including locums), named safeguarding leads, and DSPT if you handle NHS patient data. Our guide to DSPT and DTAC explains what each requires.
6. Start reporting NHS-funded and private referrals, waits and outcomes separately, since the review ties data to funding.

If you already diagnose and treat, check that your assessment records are as complete as your prescribing records.

Where Cerebric fits#

Cerebric keeps the assessment pathway in one record: screening, questionnaires (sent, chased and scored automatically), scheduling, the recorded assessment and a draft report where every sentence links to its source. The clinician reviews, edits and signs the report, so an inspector can trace each statement back to the evidence behind it. Cerebric is a registered UKCA Class I medical device and holds NHS DSPT (Standards Exceeded), DTAC, DCB0129 and Cyber Essentials Plus.