Professional registration checks

Professional registration is a statutory requirement for nurses, GPs and other health care workers. Practice Managers are usually up-to-speed with the various requirements for their clinical staff and this is often reflected in their recruitment procedures.

However, some policies do not go far enough to satisfy the CQC who will expect you to have robust procedures in place setting out precisely how you deal with both routine and exceptional circumstances.

Your Professional Registration and/or recruitment policies should include:

Every step of your process for communicating and verifying individuals’ professional registration throughout the recruitment and selection process
Your process for monitoring renewal dates and ensuring employees maintain their registrations
What written evidence is required, where it will be recorded and/or filed
Employees’ responsibilities and the process they should follow
The consequences of non-compliance i.e. for employees whose registration lapses (this may be suspension from duties, allocation to alternative duties, reduction in pay, etc.
Who is responsible for each step of the process
Who is responsible for taking decisions on, for example, suspension or disciplinary action where registration lapses
The categories of professional registrations required for various clinical roles
The relevant professional bodies
Who is responsible for the cost of registration and renewal
Where temporary agency and/or in-sourced staff are employed, who is responsible for checking and verifying professional registration and renewals; and how this is done

Lapse of Professional Registration

While Practices will have different ways of dealing with an employee’s lapse of professional registration it’s important that immediate action is taken as soon as any lapse in mandatory professional registration is identified.

Here are some options to consider:

Suspension or leave without pay (due to breach of contract – providing that you have made this a contractual requirement)
The employee may be allowed to take annual leave until registration becomes effective
Where practicable, demotion to a position not requiring professional registration, with the corresponding reduction in pay for the period in question
Formal disciplinary action may be instigated as the individual is no longer able (or no longer fulfils the criteria) to carry out the duties required of their post; they are in breach of their contract of employment; and/or their actions adversely affect the operation of the Practice
Should the employee not be able to regain effective registration within a reasonable time frame then this may result in dismissal
Exceptional mitigation may be considered, such as organisational problems within the regulatory body
In all cases of lapsed registration you, as the employer, should reserve the right to address the issue by initiating the Disciplinary Policy and Procedure.