Policy Regarding the Professional Registration of Doctors, Nurses, Dentists, Dental Staff, Pharmacists and Allied Health Professionals Responsible Directorate: Responsible Director: Date Approved Committee
Human Resources/Organisational Development Sue Ellis Director of HR and OD Calderdale and Kirklees PCTs 9th July 2008 Governance Committees/Partnership Forum, PCT Board
Document Title
Policy regarding the professional registration of doctors, nurses, dentists, dental staff, pharmacists and allied health professionals
Document number Author Contributors Version Date of Production Review date Postholder responsible for revision Primary Circulation List Web address
Two Lesley Shotton Terry Service Three 12 June 2008 12 June 2011 Lesley Shotton All staff http://www.kirklees-pct.nhs.uk/publicinformation/publications/policies-and-procedures/employmentpolicies/ None
Restrictions
Domain Core Standard Reference Performance Indicators
Governance C10a undertake all appropriate employment checks and ensure that all employed or contracted professionally qualified staff are registered with the appropriate bodies Clause in contract of employment Professional codes of conduct
1
Index Section
Heading
Page
1
Policy Statement
3
2
Introduction
3
3
Associated Policies and Procedures
3
4
Aims and Objectives
5
Scope of policy
4
6
Accountabilities
4-6
7
Equality Impact Assessment
7
8
Training
7
9
Compliance
7
10
Stakeholders
7
3-4
Appendices 1
1.
Contact details
8-12
Policy Statement It is a legal requirement that doctors, nurses, dentists, dental staff, Pharmacists and Allied Health Professionals, must be registered with their
2
appropriate professional body. Registration is also a requirement of their contract of employment with the PCT and as part of the terms of service for independent practitioners. In the event that an individual has no registration the employment will have been deemed to have ended by operation of the law. This policy sets out the various responsibilities and action required to ensure professional registration is maintained. 2.
Introduction Employees who are required to maintain the appropriate professional registration in order to practice have a contractual obligation to maintain their registration. Professional regulation is intended to protect the public, making sure that those who practise a health profession are doing so safely. Employers must check the registration of health professionals with the relevant regulatory body. The PCT recognises its responsibility to verify that all its staff maintain their relevant professional registration.
3.
Associated Policies and Procedures This document should be read in conjunction with the PCTs Procedure on Professional Registration of Staff. The following documents should be referred to when handling cases of failure to maintain professional registration. •
4.
Disciplinary Procedure
Aims and Objectives To ensure that all staff employed by Kirklees PCT and who are required to maintain a professional registration to practice do so in a timely manner. The purpose of registration checks is to ensure that employees are recognised by the appropriate regulatory body. It must be made clear to prospective employees that appointment to any position is conditional on a satisfactory registration check. Prospective employees must also be informed that any offer of appointment may be withdrawn if they knowingly withhold information or provide false or misleading information, and that employment may be
3
terminated should any subsequent information come to light once they have been appointed.
Ensure the appropriate action is taken when a practitioner fails to reregister. 5.
Scope of the Policy This policy applies to all PCT employees including staff on temporary, or bank contracts who are required to maintain a professional registration in order to practice.
6.
Accountabilities & Responsibilities The Chief Executive is accountable for ensuring that adequate procedures are in place to ensure all Doctors, Nurses and Allied Health Professionals are legally registered but devolves the responsibility to the Director of HR/OD and the Assistant Director of HR through direct processes or service level agreements. Individual Responsibility
Individual practitioners have the responsibility to ensure that they are eligible to practice. A key element of this eligibility is that of being registered with their professional body. Unless registered, a practitioner does not have the legal authority to practice. Lack of registration can have serious consequences for themselves and for the employing organisation. Practitioners, therefore have certain responsibilities, both to themselves and the PCT, these include: • Having current and appropriate registration on joining the PCT. • Maintaining continuous registration, in order to practice legally. • Complying promptly with reminder notifications received from their registering body, to ensure that they continue to remain registered at all times. • Advising their manager, as soon as possible, if any difficulty is experienced in re-registering. • Providing acceptable evidence of re-registration. • Ensuring that the registering body and the PCT are notified of changes to their private addresses promptly. Practitioners should be aware that because of the seriousness of not being registered, failure to re-register could lead to suspension without pay and action taken in accordance with the PCT disciplinary policy.
4
Managerial Responsibility Managers have responsibility for ensuring that their staff hold appropriate and current registration. They must also ensure that the Human Resources Department is informed of their staff’s current registration status and PIN. Managers who are aware of an individual who requires registration, but has not produced satisfactory evidence of such (i.e. PIN), should take the following action: • Advise the individual of the seriousness of the situation. • Inform them that failure to provide evidence of registration prior to the expiry date, will lead to suspension from duty without pay, which could lead to action being taken in accordance with the disciplinary policy. • Instruct the individual to cease practicing immediately and inform him or her that s/he is suspended from duty without pay until evidence of reregistration is provided. • Inform the individual that failure to produce the necessary evidence of registration is regarded as negligence and that as a consequence the disciplinary procedure could be invoked. • Confirm any actions outlined above in writing to the individual concerned. • Inform the Human Resources Directorate of the action taken, particularly of any decisions that affect pay. Responsibility of the Human Resources Department All professionally registered staff will, when asked to attend for interview, be asked to bring along proof of their professional registration. Interviewers must carry out a visual check of registration evidence and record the registration number. Human Resources will check the current registration of new starters, to ensure it is valid for the purpose the practitioner was employed. Confirmation is printed out and place on the personal file. The procedures for the verification and monitoring of ongoing registration of practitioners are outlined in the document procedure for professional registration of staff. Human Resources department maintain checks each month for all existing staff with the relevant bodies to ensure renewals have been made. Human Resource department inform managers of any staff who have not registered and ensure the appropriate action is taken. Human Resources department will maintain and update practitioner’s registration details on the ESR system.
5
Doctors, Dentists, Pharmacists and Ophthalmologists Under a service level agreement, West Yorkshire Central Services Agency will maintain up to date information on the professional registration of all Doctors Dentists, Pharmacists and Ophthalmologists employed either directly or through a commissioned service including a locum arrangements with Kirklees PCT and advise in writing of any changes immediately. Confirmation in writing of registration is an absolute prerequisite for employment as a General Practitioner or commissioned service and will be required from West Yorkshire Central Services Agency prior to any employment. The registration details will be available to authorised managers via a password system on the intranet for Allied Health Professions and through direct contact with West Yorkshire Central Services Agency. The procedures for the verification and monitoring of ongoing registration of Doctors, Dentists, Pharmacists and Ophthalmologist by West Yorkshire Central Services Agency are included as appendix 2 (A – G).
West Yorkshire Central Services Agency can be contacted at; West Yorkshire Central Services Agency 2-8 Brunswick Court Bridge Street Leeds West Yorkshire LS2 7RJ Telephone 0113 29 52500 Facsimile 0113 29 52555 enquiries@wycsa.nhs.uk
6
7.
Equality Impact Assessment All public bodies have a statutory duty under the Race Relation (Amendment) Act 2000 to “set out arrangements to assess and consult on how their policies and functions impact on race equality.” This obligation has been increased to include equality and human rights with regard to disability age and gender. The PCT aims to design and implement services, policies and measures that meet the diverse needs of our service, population and workforce, ensuring that none are placed at a disadvantage over others. In order to meet these requirements, a single equality impact assessment is used to assess all its policies/guidelines and practices. This policy was found to be compliant with this philosophy with a copy of the assessment attached to the policy.
8.
Training Training will be provided to enable staff and managers to recognise the importance of checking and maintaining the professional registration of staff. The Training will be commissioned by the HR department. Checking of professional registration is covered in the Recruitment and Selection Training Module.
9.
Monitoring Compliance with Policy This policy will be monitored by HR Shared Services who will be responsible for ensuring that the policy is made available for staff and managers and that any necessary training is provided.
10.
Key Stakeholders •
Assistant Director Corporate Governance and Risk Kirklees PCT
•
Provider Services Board
Page 7 of 12
Appendix 1
Checking Registration with Statutory Regulatory Bodies
There are currently eight regulatory bodies covering the health professions and, in total, they have around 1.1 million health professionals on their registers. Their four main functions are: •
Establishing standards of competence, ethics and conduct
•
Establishing standards for training
•
Keeping a register of those who meet the standards
•
Dealing with registrants who fall short (eg by placing conditions on their registration or erasing them from the register).
What employers should ask for in every case Before NHS employers appoint any health professional they must always check the following three areas: •
That the applicant is registered to carry out the proposed role
•
Whether the registration is subject to any current restrictions which might affect the duties proposed
•
If the applicant has investigations against them about their fitness to practise that the regulatory body has a duty to disclose.
Each regulatory body has different procedures for the disclosing fitness to practise information:
General Medical Council The GMC can confirm a doctor’s •
Full name
•
GMC number
•
Dates of registration (provisional, full, specialist or limited)
•
Current registered address
Page 8 of 12
•
Sex
•
Current registered status
•
Primary medical qualification
•
Specialist qualifications
•
Due date for annual retention fee
The GMC has the power to suspend or place conditions on a doctor’s registration. Employers must check a doctor’s registration status and fitness to practice prior to employment and then on an annual basis in one of the following ways: •
Online via an enquiry form at www.gmc-uk.org
•
By phoning the contact centre on 0161 923 6602.
•
By e-mail, including the doctor’s name and GMC number, the employers name, PCT and contact number, sent to registrationhelp@gmc-uk.org
•
Through the occupational health smart card (OHSC) system, where available
Nursing and Midwifery Council The NMC can provide registration information on registered nurses and midwives and will informa an employer if a practitioner has the following status: •
Removed
•
Restored
•
Conditions of practice
•
Cautioned
•
Suspended
•
Lapsed
•
Effective
The NMC offers threee ways to confirm registration status:
Page 9 of 12
•
Online at www.nmc-uk.org, where a written report will be issued by post
•
Through the automated registration confirmation hotline (available 24 hours a day, seven days a week), which generates a written report at the end
•
By writing for confirmation to: Nursing and Midwifery Council, 23 Portland Place, London, W1B 1PZ
Health Professions Council The following health professionals are regulated by the HPC: arts therapists, biomedical scientists, chiropodists, podiatrists, clinical scientists, dieticians, occupational therapists, operating department practitioners, orthoptists, paramedics, physiotherapists, prosthetists, orthotists, radiographers and speech and language therapists. A health professional’s registration status can be checked on the HPC’s website at www.hpc-uk.org. Any changes to a health professional’s registration status are immediately entered onto the register. Fitness to practise cases are listed on the website and after a hearing, the decision is posted online. Employers are strongly encouraged to use the HPC’s online register, but if this is not possible, registration can also be checked: • • •
by phone on 0845 300 4472 or 0207 840 9802 by emailing • registration@hpc-uk.org by writing to the Health Professions Council, Park House, 184 Kennington Park Road, • London, SE11 4BU.
For further information on fitness to practise contact the Fitness to Practise (FPT) team either by phone on 0207 840 9814 (Monday to Friday 9am to 5pm) or by emailing ftp@hpc-uk.org
Royal Pharmaceutical Society of Great Britain (RPSGB) The RPSGB provides details of pharmacists who hold full-time, part-time, retired or overseas registration and details of current and recent fitness to practise inquiries. A pharmacist’s eligibility to practise in Great Britain depends on their type of registration, which is shown in their entry on the register. Pharmacists who have paid the retention fee will have either have ‘P’ (practising) or ‘NP’ (nonpractising) in their entry. Pharmacists who have not yet paid the retention fee will have either f, p, r, I or o in their entry. Only pharmacists holding NHS Employment Check Standards 7 Registration and qualification checks
Page 10 of 12
full-time (f) or part-time (p) registration are eligible to practise; pharmacists holding retired (r), ill health (i) or overseas (o) registration are not eligible to practise. Registration can be confirmed by: • • •
online at www.rpsgb.org.uk by entering the pharmacist’s registration number or using their name. by phone on 0207 735 9141 by writing to the Royal Pharmaceutical Society of Great Britain, 1 Lambeth High Street, London, SE1 7JN. Employers will need the member’s registration number, full surname and forename, date of registration and postal town of their registered address.
Details of current and recent fitness to practise inquiries can also be obtained from the website www.rpsgb.org.uk General Dental Council The GDC holds two registers that provide registration information on all dental care professionals: •
The Dentists Register, and
•
The Dental Care Professionals Register, which includes dental hygienists, dental therapists, • orthodontic therapists, clinical dental technicians and, from 30 July 2008, dental nurses and dental technicians.
Some of the information required is not publicly available in the Dentists Register and employers will need to provide evidence of the dental care professional’s consent to access it. The consent form must be signed by the dental care professional and must include: • •
Their full name Ttheir GDC registration number
Employers will also need to check applicants who may be registered on the temporary register. Overseas qualified dentists can apply for temporary registration in specific approved posts if they hold a dental qualification that is recognised by the GDC for the purposes of temporary registration and the International Qualifying Exam. This allows them to work with supervision in dental schools or hospitals and, in a limited number of cases, in primary care dental settings for training, teaching or research purposes only and for a limited period. Apart from these approved settings, temporary registration will Page 11 of 12
not allow dentists to work in general or private practice, or in the community dental services. Employers can check registration status and obtain information about any fitness to practise proceedings in one of the following ways: •
online at www.gdc-uk.org
•
by phone on 0207 887 3800
•
by writing to: General Dental Council, 37 Wimpole Street, London, W1G 8DQ.
Page 12 of 12