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Advice for temporary registrants

Returning to practice is always a little daunting, but we understand that is particularly so in the current climate.

We are doing all we can to help by developing the information and support we provide and will be providing clear guidance against the standards as soon as possible.

This will include areas such as: approach to care, communication, scope of practice, delegation and supervision, data protection, infection control and personal protective equipment, and raising concerns.

We will keep our information and support up-to-date, and are working with other stakeholders to ensure they do so too.

COVID-19 advice for temporary registrants

  • Registration on the COVID-19 temporary Register is automatic.

    A list of eligible former registrants and third year students is available on the website. This will continue to be updated, as more individuals become eligible. Name, location and past registration number (for former registrants) or name of the education and training provider (for third year students) is provided to identify eligible individuals.

    If your name is on this list, and you would like to offer to support your profession in the COVID-19 pandemic, you do not need to do anything further with HCPC in order to practice.

    It is for employers recruiting COVID-19 temporary registrants to decide what, if any, checks they will need to put in place to prove identity.

    We expect that for the majority of former registrants, this will be fairly informal, relying on professional networks, employer records or HCPC documentation (if still available).

    For students, we would expect employers to liaise with education providers to confirm identity. As with the above, for the majority of cases this should be fairly informal, as most third year students will likely be working in settings where they have already been on placement and so there is already an existing relationship.

    If further proof of identity is required, please contact e-regtemp@hcpc-uk.org.

  • Please email the Registration team at e-regtemp@hcpc-uk.org with your updated contact details. We will get this information sent to you as soon as possible.

  • Thank you for your willingness to support the NHS.

    Currently, the temporary register is only eligible for individuals who have de-registered in the last 3 years. However, you can support the NHS in other ways such as by practising in an assistant role or under a non-protected title which reflects your current level of skills and knowledge. If you get in touch with your local NHS trust, they will be able to advise on what support they need / roles are available.

    We are also in conversations with colleagues in the NHS about if there is anything further we can advise current registrants wanting to help. We will share updates on the website as and when we know more.

  • There is no need to do anything further. The COVID-19 temporary Register simply provides for a list of eligible professionals who could go back into practice, if they choose to.

    By creating this Register, we are removing the regulatory barrier to practise that de-registered professionals and third year students would otherwise face. This is to ensure that the NHS is as prepared as it can be for the COVID-19 pandemic. However, this does not confer any duty on you to go back into practise if you do not want to, or do not feel you would be able to safely and effectively.

    If you would like us to remove your name from the COVID-19 temporary Register, please contact e-regtemp@hcpc-uk.org.

  • We are very sorry if the names of any individuals who have passed away are on the COVID-19 temporary Register. As we do not collect any data on de-registered individuals, we are unable to identify if someone has since passed away.

    We have had to act quickly to respond to this ever-evolving situation. This has meant we have had to rely on the limited data we hold on de-registered individuals.

    We do appreciate this may be upsetting for close relatives and families. If you get in touch with the HCPC Registration team at e-regtemp@hcpc-uk.org, we will remove the details of anyone who has passed away as soon as possible. Please be aware that you may need to provide us with a death certificate.

  • There is no need to pay fees to the HCPC whilst on the COVID-19 temporary Register, whether or not you decide to go back into practice.

    This is a temporary measure we have made using emergency powers given to us by Government. Therefore our usual regulatory costs do not apply.

  • The HCPC standards will only apply to people on the COVID-19 temporary Register if they go back into practice. If you do not return to practice under your professional title, the HCPC standards will not apply to you, and so will not have any impact on your personal life.

    If you do plan to go into practice, we provide some further guidance on how to apply the standards in your emergency role below. 

  • Appropriate professional indemnity insurance should be provided by employers (whether that be in the NHS or private practice). We expect further details to be published by Government in due course. 

  • We do not require anyone on the COVID-19 temporary Register to make a health or character declaration to us in order to practise. We have already taken steps to remove from the pool of de-registered individuals those who have been the subject of a fitness to practise concern in the past.

    However, in order to go back into practice, temporary registrants will need to ensure they are able to meet our standards. This includes an expectation that they will:

    • take all reasonable steps to reduce the risk of harm to service users, carers and colleagues as far as possible;
    • not do anything, or allow someone else to do anything, which could put the health or safety of a service user, carer or colleague at unacceptable risk; and
    • make changes to how you practise, or stop practising, if your physical or mental health may affect your performance or judgement, or put others at risk for any other reason.

    Therefore, if you believe that your health will impact on your ability to practice, you should not return to practice. Nor should you go back into practice if your conduct since leaving the Register has fallen significantly short of the standards, or you otherwise feel that your skills and knowledge are no longer sufficient to allow you to practise safely.

  • As this is a COVID-19 temporary Register, we recognise there are increased risks involved. Therefore should anyone raise a concern about a registrant on the COVID-19 temporary Register, which meets our Triage test as explained in our Threshold Policy, we will remove them from that Register with immediate effect.

    This means we will not carry out a fitness to practise investigation into the concerns raised, or seek comments or information from any of the parties concerned.

    In addition, if we are made aware that someone is misusing their temporary registration (for example, by practising in a way which is not linked – directly or indirectly – to COVID-19), we will remove them from the temporary Register.

  • COVID-19 temporary registrants will be able to use the protected title of the profession they are working in for the duration of their time on the COVID-19 temporary Register. However they should be open and honest about their level of experience and qualifications.

    It is likely employers will set in local policies how COVID-19 temporary registrants will be deployed. This might include practising under a different title, which makes it clear to the public their COVID-19 temporary status. 

  • If you are going through the returning to practice process and have been out of practice for between 0-3 years, your name should already be on the temporary register. This means you are allowed to go back into practice on a temporary basis.

    However, you must continue with the returning to practice process to achieve your permanent registration with HCPC.

    If you have been out of practice for 3 years or more, based on our current risk assessment you will be unable to join the temporary Register. You will therefore need to continue the returning to practice process in order to re-join your profession.

    Our approach is continually under review, and so may be subject to future change.

    If you have any questions, please contact e-regtemp@hcpc-uk.org.

  • We have taken all possible steps to ensure that the personal information of former registrants is kept securely.

    The information on the COVID-19 temporary Register that is publically available is the minimum amount of information we considered necessary for establishing this Register and protecting the public. If you have any concerns about this, please get in touch with our Data Protection Officer at foi@hcpc-uk.org

  • The NHS is coordinating the workforce response to the developing situation. If you have not already done so, you can express your interest by completing the NHS survey.

  • Thank you for your willingness to support the NHS at this time.

    The COVID-19 Temporary Register enables de-registered individuals to re-join the Register and their profession, where there would otherwise be a regulatory barrier to them practising.

    As you are currently registered with the HCPC (albeit not in a frontline / clinical role) those same barriers do not apply; you are still entitled to practice using your protected title. I would advise getting in touch directly with your local NHS trust to establish what support you could provide. They will also be able to advise you on what training and support will be on offer.

    We are liaising with colleagues in the NHS about if there is anything further we can advise current registrants wanting to help. We will be updating our COVID-19 hub on the website as and when we know more: https://www.hcpc-uk.org/covid-19/

    You may wish to speak to your professional body (if a member). They will be able to give you guidance and information on current clinical best practice to help you update your skills and knowledge. You can find a list of professional bodies on our website: https://www.hcpc-uk.org/about-us/who-we-work-with/professional-bodies/

  • The NHS has confirmed the following with regard to payment for temporary former registrants:

    'You will be remunerated for any work you do in a way that reflects the responsibilities you undertake. Most AHPs returning to help will be asked to provide general support and be paid at Agenda for Change Band 5. You may be asked to undertake work in line with the grade you were when you left the NHS, in which case you would be paid at that grade.'

    They are currently developing their approach to final year students, but as soon as we have any further information we will publish it to our website, here. The NHS will be updating the information on their website too - you can find that here.

Advice for practice

  • The COVID-19 temporary Register has been created to ensure that the NHS is as prepared as it can be for the COVID-19 pandemic.

    If anyone is practising under the COVID-19 temporary Register, they will need to demonstrate that their scope of practice is linked in some way to the COVID-19 pandemic.

    This does not necessarily need to be directly related to COVID-19 (for example treating service users diagnosed or with symptoms of COVID-19). It could be indirect, such as by back-filling other roles in the health and care sector to fill workforce gaps where large numbers of professionals are on sick leave or have been called to work more directly with those with COVID-19.

    This also does not need to be restricted to roles in the NHS. Private practice roles will be essential in supporting the NHS to cope with the COVID-19 pandemic. Therefore working in a private practice role could still be sufficiently linked to COVID-19.

    In general, it will not be appropriate for a COVID-19 temporary registrant to set up their own private practice or work on a self-employed basis (not including agency workers or roles which support established private practices). If you have any queries in this regard, please contact policy@hcpc-uk.org.

    The COVID-19 temporary Register should not be misused. If we are made aware that someone is misusing their temporary registration (for example, by practising in a way which is not linked – directly or indirectly – to COVID-19), we will remove them from the Register.

  • The HCPC standards will only apply to people on the COVID-19 temporary Register if they return to practice. If you do not return to practice under your professional title, the HCPC standards will not apply to you, and will therefore not have any impact on your personal life.

    If you do plan to practice, you will need to meet the Standards of conduct, performance and ethics and the standards of proficiency for your profession (as far as they relate to your scope of practice).

    You will not need to meet our standards for CPD, nor will you be subject to CPD audit. This reflects that registration is a temporary, short term measure. However, you should take all steps possible to ensure your skills, knowledge and experience are kept up to date when practising. We have provided more information about this below.  

    All our standards need to be read in the round. How to meet them, and what is and is not appropriate, will depend on the full circumstances of an individual’s practice. We recognise that working in a pandemic may give rise to particular challenges that are uncommon in your everyday practise. We would still expect you to use your professional judgement to assess what is safe and effective practise in the context in which you are working during the pandemic. Any queries can be sent to policy@hcpc-uk.org.

  • Former registrants and third year students may not have up to date skills, knowledge and experience for all areas of practice.

    In order to keep your service users safe, we expect you to limit your practice to your current skills, knowledge and experience level. In practice this means:

    • If you are a former registrant, this is likely to mean you would return to a similar scope of practice to that of the role you were most recently practising in. However, we expect professionals on the COVID-19 temporary Register to use their professional judgement to make this decision. If entering a role outside your traditional scope of practice, you may need to seek out additional training or support (such as supervision) from your employer.
    • If you are a third year student, you should consider what parts of your education and training you have not yet completed or had experience of. You should use this to inform what roles you undertake and where you need to seek out additional support.

    Employers may also require COVID-19 temporary registrants to undertake certain training, or arrange for you to be supervised by another professional when you start practising. You should speak to your employer to establish what requirements they might have.

    Professional bodies are often a good resource for advice and support, so you should get in touch with them if you have any concerns.

  • Our standards require you to keep full, clear and accurate records.

    We recognise that in an emergency scenario record keeping standards may vary. You should consult with your employer about what records you need to keep and in what form.

  • Our standards require registrants to only delegate work to someone who has the knowledge, skills and experience needed to carry it out safely and effectively. Therefore, COVID-19 temporary registrants should only be given work that they and their employer feels they are able to do.

    You may be given supervision by another professional. As set out above, you should always be open and honest with them about your current level of skills and experience and what areas of practice you may need additional support with.

  • All of our professions have different medical entitlements – this includes prescribing rights, exemptions and access to PGDs (patient group directions). The specific rights vary for each profession. A full list can be found on our website.

    With the exception of annotations (such as prescribing rights), COVID-19 temporary registrants will be able to access their medical entitlements as normal. However, they should only do so if they feel they have the required skills, knowledge and experience (see above for more information). Temporary registrants should continue to follow the law and guidance in this area, as well as local policies set by employers.

    However, temporary registrants should only use these if they feel they have the required skills, knowledge and experience (see above for more information). Temporary registrants should continue to follow the law and guidance in this area, as well as local policies set by employers.

    Third year students in particular should consider whether they have enough training and experience to start practising in this area. Medical entitlements cannot be delegated so students are unlikely to have much experience, if any, in these areas. Employers will therefore need to support third year students in the usual way they would newly qualified registrants.

    Some former registrants may have had annotations on the Register – either in prescribing or podiatric surgery. Due to the high risk associated with these areas, we do not plan to give former registrants with annotations these rights when they join the COVID-19 temporary Register. Therefore, if you were able to prescribe and have recently de-registered, you will not be able to prescribe in this temporary role.

    This is based on our current risk assessment, but we will monitor developments to ensure this continues to be an appropriate approach.

  • You should always communicate appropriately and effectively and be open and honest with service users. This includes being honest about your experience, qualifications and skills.

    You should therefore always be open and honest with service users about your registration status. You should not mislead service users about your level of experience or qualifications. Nor should you suggest to a service user that you have an ability to practice outside of your COVID-19 temporary role.

    COVID-19 temporary registrants are able to use their protected title(s) for the duration of their time on the COVID-19 temporary Register. However, they should be open and honest about their level of experience and qualifications.

    The NHS is coordinating the workforce response to the developing situation. Further information can be found at [NHSEI LINK]

  • Health Education England (HEE) has a remit to support the workforce requirements and will have access to significant resources that can be utilised during this time. HEE Technology Enhanced Learning (TEL) is working with colleagues to outline how HEE can enable the access to resources through their role in supporting, at a national level, simulation-based education and digital learning resources.

    HEE e-Learning for Healthcare is currently collating relevant e-learning content from the existing catalogue for the health and care workforce into one programme. Resources will be available here https://www.e-lfh.org.uk/programmes/coronavirus 

Page updated on: 19/03/2020
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