The Law of Conservation of Paperwork.

Every so often, someone in healthcare finds a corner the regulator hasn't reached yet. A service that technically isn't a regulated activity. A process nobody has thought to write a form for. A brief, glorious patch of open ground.

Enjoy it. It won't last.

This week DHSC asked CQC to regulate diagnostic-only ADHD and autism assessments. For years these services sat in a gap in the wording of the regulations: a clinic could diagnose to its heart's content, provided it didn't then treat anyone. That gap is now being filled, as all gaps eventually are, with a registration application, a statement of purpose and a registered manager who is about to find out what a Regulation 18 notification is.

We've come to think of this as a law of nature. Energy can't be created or destroyed…and neither can paperwork.

It simply flows from places that have plenty to places that have none, until the whole system reaches equilibrium. This usually happens the week of your inspection.

A few observations from a career spent on wards, in law and in information systems:

• Any process that "doesn't need a policy" will need one the morning after the incident.

• The form you abolish in a streamlining exercise will be back within 18 months as a template, a checklist and a dashboard.

• "We'll document it later" is the most expensive sentence in healthcare.

• There's no such thing as an unregulated activity. There are only regulated activities that haven't been noticed yet.

• Every framework is eventually replaced by a new framework. That brings guidance, the guidance brings FAQs, and the FAQs bring clarifications. CQC's new frameworks land at the end of the year, and I've cleared some shelf space.

Now the serious bit, because as a governance consultant I'm contractually obliged to include one!

Health and safety professionals have a saying: regulations are written in blood. Behind almost every rule there's someone who got hurt before it existed.

Healthcare is no different. Bureaucracy tends to win because somewhere underneath it there's a patient who was let down while nobody was looking. The ADHD gap was where people could receive a poor service with no one checking, and closing it is the right call.

So if your service is sitting in a gap right now, the cheapest time to build good governance is before anyone tells you to.

You'll have to do it eventually. Better to do it on your own timetable than on CQC's.

The paperwork is coming. You may as well make friends with it.