Each licensee that provides the prescribed licensable healthcare service is required to formally appoint a QAC for their own institution to discharge their duties under Section 25 of the HCSA.

If each healthcare institution under the cluster holds its own licence (i.e., is a Section 25 licensee), it is required to appoint a QAC for itself. Nevertheless, the same individual can sit in multiple QACs. This means that it is possible for multiple licensees to appoint the same members to their QACs. Most importantly, each licensee’s QAC should discharge their duties in relation to each licensee e.g., the QAC should make findings/recommendations for each licensee’s service.

However, if the cluster holds HCSA licences for all its healthcare institutions (i.e., the cluster is a Section 25 licensee), the cluster can appoint an overarching QAC, and the QAC can review matters that may be relevant to both the cluster and the healthcare institutions under the cluster, while enjoying protections afforded to the QAC for all these matters. However, there are broader governance issues (e.g., direct legal responsibility, appointment of key appointment holders, etc.) that the cluster needs to consider determining if the cluster should hold one licence for all its healthcare institutions.