1. Introduction 1.1 The verification of registration status of all registered professionals is essential to ensure that both King's College Hospital NHS Foundation Trust and the public can be confident that all professional staff providing a service are appropriately qualified, registered with the relevant body and meet statutory registration requirements
1.2 Anti-Discrimination Statement
Our commitment extends to all protected characteristics under the Equality Act 2010 as well as other vulnerable groups. We expect every employee to respect and uphold this in relation to all our trust policies, practices, and procedures.
It is against the law to discriminate against anyone because of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, ethnic or national origin), religion and belief, sex, and sexual orientation.
Discrimination towards our staff or patients, in any form, is strictly prohibited. This includes, but is not limited to, racism, ableism, homophobia, biphobia, transphobia, sexism, ageism, religious discrimination, and any other prejudiced behaviour that u ndermines the rights, wellbeing and identity of our staff, and patients.
We embrace our duty to address discrimination in all its forms, and we pledge to:
- listen to the voices and lived experience of colleagues and patients, and other groups who suffer discrimination or lack of fair representation - commit to working towards removing inequalities within our Trust, including differences in access, experience and outcomes for our diverse patient groups - turn that commitment into positive action and real change - use our voice and influence within the wider system to address the wider social determining factors of health - accept our responsibility to listen to, and learn from, the experience of all underrepresented groups - listen with respect and genuine curiosity, acknowledging that continued action and resource is required to bring about the change we need to see - ask all colleagues to work with us to remove unfairness and discrimination within our organisation and within our wider communities
2. Purpose
2.1 The policy outlines the resp onsibilities and correct processes for staff and managers on the registration checks that must be carried during on-going employment of relevant individuals in the Trust. It is one of six mandatory employment check standards as detailed by NHS Employers Employment standards and regulation | NHS Employers. The process for registration checks at the point of employment is covered in the Trusts Recruitment Policy
2.2 This policy contains guidance and instructions for managers regarding their responsibilities to ensure the compliance of their staff and actions that should be taken regarding lapsed Professional Registration policy and guidance for clinical staff
registrations or licence to practic e. Also, if necessary the reporting of concerns to professional regulatory bodies. The frequency of professional registration, licence to practice and revalidation requirements are also provided.
3. Scope
3.1 This policy applies to all directly employed non-medical staff including bank, temporary and substantive registered staff. This includes the following posts that have been accepted onto the register of the statutory regulatory bodies outlines in the NHS Employment Check Standards. - Nursing and Midwives - Allied Health Professionals - Healthcare Scientists - Social workers - Pharmacy and Pharmacy Technicians
4. Duties and responsibilities
4.1 Chief People Officer & Chief Nurse
The Chief People Office & Chief Nurse are responsible for implementing and reviewing this policy with an appropriate framework in place for monitoring compliance with the policy.
4.2 Professional Leads and Line Managers
Professional leads and line managers are r esponsible for ensuring compliance with this policy, and assuring the appropriate action is taken to ensure all staff have current and appropriate professional registration and where a lapse has occurred a consistent approach is followed.
Professional Leads and Line Managers must:
- Be familiar with the requirements of the appropriate registering bodies governing the employment of staff in the professions. - Make clear to all relevant staff members the Trust policy regarding Professional Registration, their responsibilities regarding the maintenance of their registration and the implications of allowing their registration to lapse at any time. - Maintain knowledge and engage in consultations relating to changes of professional standards. - Review their staff members against the monthly report provided by HR which includes details of staff whose registrations are due to expire or have already expired including those undertaking a period of absence. - Deal appropriately with any employees whose registration is found to have lapsed during employment, managing the situation fairly and consistently including those undertaking a period of absence. - Report any concerns that may impact on an individual's registration to the Chief Nurse, Medical Director, Chief of Therapy Services, Chief Pharmacist, Head of Pathology Professional Registration policy and guidance for clinical staff
Services or professional lead/manager for referral where necessary to the appropriate Regulatory Body. - With the exception of NMC and G PhC records which should automatically update inform HR of all renewals so that staff records can be updated on ESR. - Where automatic updating via ESR is in place, ensures that they and/or their managers take necessary action as requested to maintain Trust records to ensure such reporting and updating is effective and robust. - Ensure provision of evidence at interview of each applicant's current professional registration status including any restrictions on practice. - Establish procedures to ensure that the registration of Bank, and agency workers are verified the first time the individual works on the ward / department; this will include checking a photo ID of the worker. - Ensure agency staff are only supplied by Trust approved agencies which belong to a recognised and Trust approved procurement framework. This will ensure that the agency has demonstrated a robust system is in place for checking the validity of registration, in line with the Temporary Staffing Policy. - In exceptional cases if not using an approved agency must ensure that a registration check is completed before allowing the individual to work.
4.3 Human Resources Department
The HR department are responsible for producing a monthly report of all lapsed registrations. This report is shared with the Professional Leads and Line Manager. It is the responsibility of the HR team to record the outcome of all lapsed registration with the Professional Leads and maintain a robust database for monitoring of compliance.
- Ensure that procedures are in place to make sure that all employees are registered on starting employment with the Trust. - Ensure that procedures are in place via the Trust's external bank and agency management partner to make sure that all bank and agency workers are registered on starting assignments with the Trust. - Ensure that the external bank and agency partner's procedures are regularly audited to ensure compliance. - Advise the manager of any conditions / restrictions / fitness to practice. - Records registration (and where applicable revalidation) details within ESR. - Maintain the Trust policy and advise managers and staff on the procedure in the event of lapses of registration. - Maintain staff records in relation to registration and editing/updating such records to ensure accurate data collection and compliance reporting for internal and external stakeholders. - Provide accurate records to allow managers to be kept informed of registration details and lapses and provide relevant data to alert professional leads and managers of pending registration renewal and any potential breaches to Trust policy. - Provide a report on professional registration monthly to professional leads and relevant managers.
Professional Registration policy and guidance for clinical staff
4.4 Professional Staff Members
All Professional staff are individually responsible to attain, maintain and provide valid proof of statutory registration before taking up a post, at renewal and at any further time in their employment. This includes Career breaks and any paid periods of absence including but not limited to maternity Leave, sickness and secondments.
The staff member must: - Make their appropriate registration status clear when applying to and when joining the Trust. - Take all necessary action to maintain continuous registration/revalidation in order to practice legally. - Plan and pay the fee in time for registration or renewal to occur. Inform the line manager and the Human Resources Department immediately in the event of a registration lapse or any internal or external event which could impact upon their professional registration. - Undertake whatever personal development and appraisal is required to maintain registration and draw to the Trust's attention any matters affecting their registration. - Keep the regulatory body informed of changes of address, name, status and factors that may impact their ability to practice for an extended period of time. This is to ensure their records are up to date and that renewal advice and information from the regulatory body is received. - Comply with the regulatory body's code of professional conduct and standards. - Provide acceptable evidence of registration as required and whenever requested. - Take reasonable action in line with the measures in this policy and be aware of the implications for lapses in registration. - Notify the Trust if they are refe rred to their professional body for review of fitness to practice.
Failure to maintain your registration is a breach of contract which may bring about disciplinary action leading to dismissal and potential removal from the relevant professional register. The list of professions, regulatory body and renewal period are outlines in Table 1.
Table 1:
Profession Regulatory Body Renewal Period Nurses, Midwives & Nursing Associates https://www.nmc.org.uk/ Nursing and Midwifery Council (NMC) 020 7637 7181 Annual Payment - staggered throughout year. 3 yearly revalidation (appendix 1) Pharmacists & Pharmacy Technicians www.pharmacyregulation.org
General Pharmaceutical Council 020 3713 8000 31 December - 1 year Annual - staggered throughout year. Requires annual revalidation - see GPhC website for details on specific requirements. Chiropodists & Podiatrists www.hpc-uk.org Health & Care Professions Council (HCPC) 0845 300 4472 31st July 2024 - 2 years Dietitians - www.hpc-uk.org HCPC - 0845 300 4472 30th June 2024 - 2 years Occupational Therapists www.hpc-uk.org HCPC 31st October 2025 - 2 years Professional Registration policy and guidance for clinical staff
Arts Therapists www.hpc-uk.org HCPC 31st May 2024 - 2 Years Operating Department Practitioners www.hpc-uk.org HCPC 30th November 2024 - 2 years Physiotherapist www.hpc-uk.org HCPC 30th April 2024 - 2 years Prosthetists &Orthotists
HCPC 30th Sept 2025 - 2 years Orthoptists HCPC 31st August 2025 - 2 years Clinical Scientists - www.hpc-uk.org HCPC 30th September 2025 - 2 years Speech and Language Therapists HCPC 30th September 2025 - 2 years Radiographers www.hpc-uk.org HCPC 28 February 2024 - 2 years Biomedical Scientists www.hpc-uk.org HCPC 30 November 2023 - 2 years Psychologists www.hpc-uk.org HCPC 31st May 2025 - 2 years Social Workers - www.socialwork england.org.uk Social Work England (SWE) 30th November - 1 year Optometrists General Optical Council (GOC) 15th March - 1 year
Professional Registration policy and guidance for clinical staff
5.0 Process
5.1 Monitoring of Professional Registration during Employment
The NMC and GPhC have automated processes that interface with the Trust's electronic staff record system, for other bodies' manual updates are required. Reports are sent to the professional leads and line managers monthly, exception reports are also produced by the HR administration team indicating those workers who have either not renewed their registration or who's records are preventing assurance of renewal and these should be acted upon by the senior and line managers. The monthly reports will provide the professional leads and line managers with the below information regarding registrants pending expiry and those with lapsed registrations. - Full name - Job title - Division - Assignment number - Fee expiry date (annual) - Renewal date
The professional leads will liaise with the relevant managers to ensure legal compliance and accordance with the terms and conditions of employment. The registrations must be checked AFTER midday by the Line manager , to ensure that the Body has refreshed their register that day. The check should be via the official sites and using employee caller codes issued by the Registration Body (where applicable).
In most cases registration renewal will occur, and no further action need be taken. However, when issued with an exception report or upon discovery of staff non-compliance, each professional lead is responsible for following up the alert, taking appropriate action as per the Trust Policy and updating the HR Administration team of any new data to be entered into incorrect or incomplete staff records. Acts involving suspension, investigation, disciplinary action, and dismissal must be performed in conjunction with the Employee Relations Advisory Service.
Anyone requiring professional registration upon discovery of them not having valid registration will not be permitted to practice unless and until evidence of renewal has been seen.
If renewal does not occur by midnight on the day of expiry the line manager must in all other than exceptional circumstances suspend the employee without pay, they must complete a 'Change of Contractual Details' form, accessible vi a Kingsdocs , to apply suspension without pay with immediate effect.
In very exceptional circumstances if a decision to temporarily downgrade a staff member is agreed then a change of pay or post should also be affected by sending a change form to the HR Administration team. For Nursing, Midwifery and AHP staff any decision to temporarily downgrade a staff member will need to be reviewed and approved by the Chief Nurse. This change in banding would be recommended to be at band 3, as all bands above this require an active professional registration. Professional Registration policy and guidance for clinical staff
Written confirmation of suspension and/or temporary change will be sent to the staff member by the respective line manager stating the details of the action taken and that the individual cannot work in their professional capacity in the United Kingdom until their application for re-entry to the register has been processed and their registration re-instated.
A record of monthly PIN lapses will be collected and maintained including registrants' clinical division, and actions taken. These records can be anonymised and shared at site Outstanding Care Board (OCB) providing assurance of appropriate monitoring and governance.
Nursing, Midwifery and Nursing Associate Posts Only
For Nurses, Midwives and Nursing Associates it is recommended that each department has one calling code that can be shared within that department. This is in line with advice given by the NMC. Managers can apply for an NMC Employer caller code by completing the application process at https://www.nmc.org.uk/registration/employer-confirmations.
This allows managers to check live registrations for each of their nurses and midwives. The employer caller code and pass number are registered to the individual who has applied and the Trust they are employed by. This allows an audit trail for the checking of registrations with the NMC.
5.2 In the Event of a Lapsed Registration
Where an employee or bank worker's registration has lapsed, the relevant manager will meet with the employee to establish whether there is a legitimate reason for the lapse and any mitigation. Where there is no exceptional mitigation and suspension/exclusion is appropriate, the employee/worker will be suspended without pay until relevant registration is restored. There is an expectation that this process may take some time however, exceptional mitigating circumstances will be taken into consideration on a case-by-case basis.
During this period the employee will not be permitted to practice and should take care not to misrepresent themselves as a registered professional. This may include but is not limited to ensuring they are not wearing uniform associated with their lapsed registration or signing off emails with their lapsed job role.
Any exceptional mitigating circumstances requiring deviation from the above e.g. temporarily downbanding an employee/bank worker, would need to be discussed and agreed by their Chief professional lead e.g. for Nursing and Midwifery - the Chief Nurse.
If following suspension/exclusion and informal investigation their professional registration has not been renewed, the failure to maintain registration will be formally investigated by the manager to determine the circumstances under which registration has lapsed. Following this investigation, the matter may proceed to a disciplinary hearing , potentially resulting in dismissal and/or removal from the Staff Bank - if Bank only employee. Professional Registration policy and guidance for clinical staff
The manager will meet with the registrant to discuss and agree all actions confirming with them at each stage of this process in writing. Where there is a change to the registrant's terms and conditions or pay status, the line manager will ensure the relevant forms are completed (i.e. suspension/exclusion without pay) . This should also be reflected on Healthroster, with suspension without pay being recorded as 'Unauthorised Unpaid Leave'.
Where an employee can provide clear evidence from the registering body that the responsibility lies with the body itself, then any period of suspension/exclusion that is required will be regarded as paid at their substantive rate of pay unless directly linked to an issue relating to the employee, for example, failure to disclose a conviction which the regulatory body will need to investigate prior to re-registration.
Once it is clear that the registrant has re -registered, they will be allowed to return to work in their substantive role and their staff bank restriction will be lifted. Disciplinary action may be considered but this will be determined according to the circumstances of the case.
5.3 Referral to Professional Body
In the event that concerns are raised regarding a registrant's fitness to practice via any route then it is the responsibility of all trust employees to escalate these concerns appropriately. This may first be to a local line manager however it is essential that these concerns are escalated to the relevant professional Leads within the care group then onwards to the executive professional lead.
Ultimately it is the Chief professional leads e.g. for Nursing and Midwifery - the Chief Nurse, that will have oversight of any decisions to refer registrants to the relevant professional regulatory body on behalf of the trust.
Any decisions regarding the need to refer a registrant to their professional regulatory body should be undertaken in conjunction with any necessary disciplinary or capability processes as outlined within the Capability Policy and the Disciplinary Policy and Conduct Standards.
6.0 Implementation of the Policy
6.1 The updated policy will be distributed to all Professional Leads and Line managers via an email, the policy will be available on Kingsdocs.
7.0 Education & Training Requirements
7.1 Training and support will be provided to all Professional Leads and Line Managers in the implementation and application of this policy as required.
7.2 All staff within the HR Teams who are responsible for advising Professional Leads and Line Manager will receive training as part of their induction and receive on-going updates in relation to updated employment legislation.
Professional Registration policy and guidance for clinical staff
8.0 Process for Monitoring Compliance
The process for monitoring compliance is set out below.
Measurable Policy Objectives Monitoring / Audit Method Frequency Responsibility of Monitoring Responsible Committee Lapse of professional registration Review of lapse and process followed for each individual Monthly Report HR workforce with relevant nominated professional lead for staffing group Site Outstanding care board Lapse of professional registration Review of lapse and process followed for each individual 6 monthly Report HR workforce with relevant nominated professional lead for staffing group Outstanding Care Board
9.0 Associated Trust Policies
Recruitment Policy Induction Policy Criminal record and barring check Policy Nursing, ODP & Midwifery e-Rostering Policy Temporary Staffing Policy Capability Policy Disciplinary Policy and Conduct Standards Maternity Support Leave & Pay policy (Parents Policy) Equality Diversity and Inclusion Workforce policy Sickness absence policy Special Leave Policy
Professional Registration policy and guidance for clinical staff
10. References
NHS Employers (2019) Employment Checks https://www.nhsemployers.org/your- workforce/recruit/employment-checks Professional Registration policy and guidance for clinical staff
Appendix 1 - Revalidation guidance for Nurses, Midwives and Nursing Associates Revalidation is the process that allows nurses and midwifes to maintain their registration with the Nursing Midwifery Council, (NMC). All Nurses/Midwifes/Nursing Associates need to meet a range of requirements designed to show that they are keeping up to date and actively maintaining their ability to practice safely and effectively. Revalidation is required every 3 years in order for Nurses/Midwives/Nursing Associates to maintain their registration and continue to practise. The NMC Code ( October 2018, Page 23 of 26, paragraph 22) requires NMC registrants to fulfil all registration requirements. To achieve this, registrants must: - Keep to any reasonable requests so we (the NMC) can oversee the registration process - Keep to our (the NMC) prescribed hours of practice and carry out continuing profe ssional development activities - Keep your knowledge and skills up to date, taking part in appropriate and regular learning and professional development activities that aim to maintain and develop your competence and improve your performance. NMC revalidation requirements To renew registration with the NMC, registrants must demonstrate and evidence how they have: - Practiced for 450 hours during the last three years, - 900 if renewing for as both a nurse and midwife or nursing associate and nurse; to include 450 hours in each respective registration - 1350 hours for triple registration as a nurse, midwife and nursing associate - Complete 35 hours of continuing professional development (CPD) relevant to their practice over the three years prior to renewal, at least 20 must have included participatory learning; - Obtain five pieces of practice related feedback; - Complete five written reflections on their CPD, feedback or other events that have occurred and how they relate to the code using the approved form; - Complete a reflective discussion with another nurse or midwife covering the five written reflective accounts how they relate to the Code; - Provide a health and character declaration; Professional Registration policy and guidance for clinical staff
- Confirm that they have cover under an indemnity arrangement (as a King's employee this is in place automatically you do not need to do anything further); and - Obtain confirmation from a third party peer, usually their line manager, that they have met the requirements. Further information can be obtained from the KWIKI pages http://kweb/kwiki/Nursing_and_Midwifery_Revalidation or NMC Revalidation pages https://www.nmc.org.uk/revalidation/requirements/
Responsibilities Nurses/Midwives/Nursing Associates must ensure/will Register on the NMC website to gain an NMC Online account, and then ensure they submit their Revalidation process by the due date online. Ensure their statutory and mandatory training is up to date and provide evidence of this in their portfolio. Undertake annual appraisal with their line manager Undertake and gather for evidence for their revalidation: 450 practice hours (900 if maintaining duel registration or 1350 for triple), 35 hours of CPD - 20 participatory, 5 pieces of practice related feedback and 5 written reflections. Undertake a reflective discussion with another NMC registrant Receive confirmation from the registrant's line manager on the revalidation requirements. When the above is all completed the registrants submits their confirmation via NMC Online. This is the responsibility of the registrants. During the confirmation process the registrants is required to personally confirm with the NMC that they are: - Of good a health and character - this requirement asks the registrants to declare that their health and character are sufficiently good to enable them to practice safely and effectively, and to declare any cautions or convictions. The registrants doesn't need to collect evidence to prove you meet this requirement - they just need to complete the declarations when making their application. - Hold professional indemnity insurance - arrangements in place to cover their practice. KCH provides the appropriate cover for its employees. Act honestly and in good faith completing the process in line with the guidance laid out in this policy and the NMC guidance. Professional Registration policy and guidance for clinical staff
Nurses and midwives are strongly recommended to keep a portfolio of evidence to demonstrate they have met the revalidation requirements. A NMC Registrant employed by KCH must comply with the employers requests to provide supporting evidence of revalidation e.g. training logs, checklist or e portfolio where available etc.
NMC registrant Reflective Discussion Partner Must hold an effective registration with the NMC. This means they can't be subject to any kind of suspension, removal or striking-off order at the time of having the discussion. Participate in a face-face discussion with the registrants, reviewing the five (5) written reflections at the same time with the registrants. Complete and sign the Reflective discussion form as laid out by the NMC. Recording name, NMC Pin, email, professional address including postcode, contact number, discussion date and a summary of the discussion. Mandatory form to be used (only 1 form to be completed) - http://www.nmc.org.uk/globalassets/sitedocuments/revalidation/reflective-discussion-form.doc It may be necessary to verify the information that the nurse or midwife has provided in their application if contacted by the NMC.
Confirmers/Line Managers Confirmers are the line managers or other suitable manager of the registrants. Confirmers need to follow the guidance laid out by the NMC: https://www.nmc.org.uk/revalidation/confirmers-and-employers/confirmers/ It is not necessary that the confirmer holds an NMC registration, but within KCH it is recommended. This also allows the reflective discussion and confirmation to happen at the same time. If the confirmer is another professional then the registrants will need to ensure that they have had their reflective discussion with an appropriate person (NMC registrant) before their confirmation discussion. Ensure provision of adequate time for a face to face Confirmation discussion to take place with the registrants to review their portfolio of evidence. Complete the Confirmer Checks as laid out by the NMC. Complete the Confirmation Discussion Form as laid out by the NMC once the confirmer is satisfied that all the relevant evidence has been presented to them by the registrants Complete and sign the paper copy of the template. Professional Registration policy and guidance for clinical staff
Confirmers need to provide the Registrants with their NMC personal identification number (PIN), email, professional address and contact details, as the Registrants will need to input this information to the NMC during their online submission. Act Honestly and in Good Faith: Confirmers have acted to the best of their knowledge have checked the evidence presented to them by the Registrants and feel sufficiently reassured that the evidence is appropriate and meets the requirements for revalidation. It may be necessary to verify the information that the nurse or midwife has provided in their application if contacted by the NMC. Extensions For Nursing and Midwifery staff, extensions to submit an application for revalidation can only be made by the registrant themselves and the NMC will not usually consider requests for extensions as registrants should have met the requirements for revalidati on during the 3 years prior to the renewal of their registration. Revalidation can only be delayed under exceptional circumstances. The Trust cannot make applications on behalf of registrants for extensions or exceptional circumstances. Should a registrant feel they may be eligible for an extension or have exceptional circumstances they should contact the NMC as far in advance of their revalidation date as possible. Disputes Revalidation is not a substitute or replacement for fitness to practice and any issues of competence should not wait to be identified through the revalidation processes. Concerns around registrants professional performance should addressed in a timely manner and managed via the Capability Policy with support from employee relations. Should a registrant make a false declaration during the revalidation process this will be addressed through the Trust Disciplinary Policy. Should a registrant fail to revalidate this will be addressed through the Trust Professional Registration Policy.
Professional Registration policy and guidance for clinical staff
Appendix 2 - Checklist for the Review and Approval of Trust Wide Policies
Professional Registration policy and guidance for clinical staff
Professional Registration policy and guidance for clinical staff Date of Assessment 22/5/2024 What are the aims of this project, policy, function, and or service?
The policy outlines the registration checks that must be completed prior to confirming appointments and on-going to ensure that registrations are maintained by relevant individuals so that they may continue to practice. The trust is legally required to ensure that it holds current registration details on all staff requiring professional registration and licence to practice, where applicable, to carry out their duties.
Further to the above in line with regulators work to address inequalities with the referral process, (NMC takes next steps to tackle inequalities in regulation - The Nursing and Midwifery Council ) . This policy creates a transparent pathway for management of individuals whose professional registration has lapsed or require referral to their professional regulatory body.
Decisions will be escalated to the relevant Chief Professional Lead for approval this will include discussion of mitigating circumstances and involvement of employee relations. Outcomes will be collected and monitored including registrant clinical division, actions taken will be anonymised and shared at site OCB providing assurance of appropriate monitoring and governance.
Who could be affected by this proposal? (e.g. applicants, employees, customers, service users, members of the public)
Registered Clinical Staffing Groups as outlined below: - Nursing, Midwives and Nursing Associates - Allied Health Professionals - Healthcare Scientists - Social workers - Pharmacy and Pharmacy Technicians Patient / Patient relative, carers and friends Recruitment/workforce team Employee Relations Team Kings Bank Kings Executive Team Which policies are related to or referred to as part of this assessment? Capability Policy Recruitment Policy Induction Policy Professional Registration policy and guidance for clinical staff
Criminal record and barring check policy Nursing OPD & Midwifery e-rostering policy Temporary staffing policy Disciplinary Policy + Conduct Standards How will the impact on people be assessed? (e.g. consultations forums, meetings, data collection) Monthly Pin lapse reports Bi-annual board papers - relating to ongoing cases and outcomes Meetings with NMC and other professional regulators Workforce data Trust How are we doing survey (HRWD)
Please include available Equality Data relating to the use or implementation of this policy, project, function or service? (e.g. Care Group breakdown, WRES, WDES, Sexual Orientation monitoring standard, Patient Feedback, Workforce data etc.)
Workforce data - Headcount provided for relevant staffing groups Staff Group Feb-24 Mar-24 Apr-24 Add Prof Scientific and Technic
640 630 625 Additional Clinical Services 2,132 2,117 2,113 Allied Health Professionals 933 934 926 Healthcare Scientists 231 229 228 Nursing and Midwifery Registered
5,192 5,203 5,167
Which stakeholder consultations have been included in the development or implementation of this policy, project, function or service?
Nursing, Midwifery and AHP Board Chief Nurse / Deputy Chief Nurse Site Directors of Nursing (cross site) Employee Relations and Corporate Workforce Team inc Associate Director of Workforce King's Bank Team and Head of Temporary Staffing Professional Registration policy and guidance for clinical staff
Assistant Director of Adult Safeguarding and Social Work Chief Pharmacist Chief of Therapies
Professional Registration policy and guidance for clinical staff
What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?
Protected Characteristic: Neutral
Age (People of all ages)
X Nursing and Midwifery below is based on 8 months rolling PIN lapse data. This includes 26 registrants, with any registrants that have lapsed over multiple months only being counted once, compared to current % of Nurses, Midwives and NA based on substantive employees on the 30/04/24:
Lapsed Registrants Comparison to substantive Headcount Age Headcount % of lapsed Registrants % RN's % midwives % NAs 20-29 3 11.5% 17.1% 21.3% 24.3% 30-39 10 38.5% 46.0% 31.4% 29.7% 40-49 8 30.8% 17.5% 17.9% 29.7% 50-59 5 19.2% 15.3% 19.9% 16.2% 60-69 0 0.0% 3.9% 9.5% 0.0% 70+ 0 0.0% 0.1% 0.0% 0.0%
Policy will be accessible online for all staff to access via King's Intranet
Policy is clear that it is the registrant's responsibility to keep the regulatory body informed of changes of address, name and status. This is to ensure that their records are up to date which will allow renewal advice and information from regulatory bodies to be received.
Outcomes will be collected and monitored including registrant clinical division, actions taken will be anonymised and shared at site OCB providing assurance of appropriate monitoring and governance. Professional Registration policy and guidance for clinical staff
Disability (Mental, Physical, and Carers of Disabled people)
X Nursing and Midwifery below is based on 8 months rolling PIN lapse data. This includes 26 registrants, with any registrants that have lapsed over multiple months only being counted once, compared to current % of Nurses, Midwives and NA based on substantive employees on the 30/04/24:
Lapsed Registrants Comparison to substantive Headcount Disability Headcount % of lapsed Registrants % RN's % midwives % NAs Yes 1 3.8% 2.7%
5.0%
8.1% No 22 84.6%
85.0%
81.8% 91.9% Not Stated 3 11.5%
12.4%
13.2% 0.0%
Trust policies engagement encouraged and signposted to: - Disability Charter for Staff and Patients - Special Leave Policy - King's Able (Disability) Network - EAP
Policy will be available for all staff on King's intranet to access
Policy is clear that it is the professional's responsibility to maintain their professional registration throughout any Career Breaks and paid periods of absence including but not limited leave, sickness and secondments.
In line with the NMC's guidance relating to the 'The Equality Act 2010' reasonable-adjustments-policy.pdf (nmc.org.uk) "The Act makes it clear that it is not discriminatory to apply competence standards (which include our Code, our revalidation and our education standards) to a disabled person. As a professional regulator responsible for protecting the public, it would not be right for us to adjust these standards. However, Professional Registration policy and guidance for clinical staff
What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?
Protected Characteristic: Neutral
we can make reasonable adjustments to assist nurses, midwives and nursing associates in meeting our standards."
We would expect our professional leads and line managers to support and advocate for any registrant that requires reasonable adjustments to meet their regulatory commitments; including access to Occupational Health support to provide any recommendations for ongoing reasonable adjustments and if needed direction to EAP.
Outcomes will be collected and monitored including registrant clinical division, actions taken will be anonymised and shared at site OCB providing assurance of appropriate monitoring and governance. Gender Reassignment
X Trust policies engagement encouraged and signposted to consider our language and pronouns of staff in our literature, assessments and conversations with staff
Policy is clear that it is the registrant's responsibility to keep the regulatory body informed of changes of address, name and status. This is to ensure that their records are up to date which will allow renewal advice and information from regulatory bodies to be received.
Outcomes will be collected and monitored including registrant clinical division, actions taken will be anonymised and shared at site OCB providing assurance of appropriate monitoring and governance. Professional Registration policy and guidance for clinical staff
What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?
Protected Characteristic: Neutral
Marital Status (Married and Civil Partnerships)
X Policy is clear that it is the registrant's responsibility to keep the regulatory body informed of changes of address, name and status. This is to ensure that their records are up to date which will allow renewal advice and information from regulatory bodies to be received.
Outcomes will be collected and monitored including registrant clinical division, actions taken will be anonymised and shared at site OCB providing assurance of appropriate monitoring and governance. Pregnancy and Maternity X Trust policies engagement encouraged and signposted to - Maternity Support Leave & Pay policy - Sickness absence policy
Policy is clear that it is the professionals responsibility to maintain their professional registration throughout any Career Breaks and paid periods of absence including but not limited to maternity leave, sickness and secondments.
Outcomes will be collected and monitored including registrant clinical division, actions taken will be anonymised and shared at site OCB providing assurance of appropriate monitoring and governance. Professional Registration policy and guidance for clinical staff
What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?
Protected Characteristic: Neutral
Race (All Racial Groups)
X Nursing and Midwifery below is based on 8 months rolling PIN lapse data. This includes 26 registrants, with any registrants that have lapsed over multiple months only being counted once, compared to current % of Nurses, Midwives and NA based on substantive employees on the 30/04/24:
Lapsed Registrants Comparison to substantive Headcount Ethnicity Headcount % of lapsed Registrants % RN's % midwives % NAs BME 17 65.4% 65.5% 34.17% 62.16% White 5 19.2% 26.7% 61.62% 35.14% Not Stated 4 15.4% 7.8% 4.2% 2.7%
Trust policies engagement encouraged and signposted to
- Equality Diversity and Inclusion Workforce policy - Staff Members and Senior Managers are encouraged to attend "Creating inclusive environments with Cultural Intelligence" training
Outcomes will be collected and monitored including registrant clinical division, actions taken will be anonymised and shared at site OCB providing assurance of appropriate monitoring and governance.
Professional Registration policy and guidance for clinical staff
What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?
Protected Characteristic: Neutral
Religion or Belief
X Nursing and Midwifery below is based on 8 months rolling PIN lapse data. This includes 26 registrants, with any registrants that have lapsed over multiple months only being counted once, compared to current % of Nurses, Midwives and NA based on substantive employees on the 30/04/24:
Lapsed Registrants Comparison to substantive Headcount Religious Belief Headcount % of lapsed Registrants % RN's % midwives % NAs Atheism 1 3.8% 7.4% 22.4% 13.5% Buddhism 2 7.7% 4.9% 0.8% 0.0% Christianity 13 50% 63.2% 47.9% 62.2% Hinduism 0 0.0% 2.7% 0.6% 0.0% Islam 2 7.7% 2.9% 2.8% 5.4% Jainism 0 0.0% 0.0% 0.0% 0.0% Judaism 0 0.0% 0.1% 0.6% 0.0% Sikhism 1 3.8% 1.1% 0.6% 2.7% Other 2 7.7% 4.1% 8.7% 8.1% Not Stated 5 19.2% 13.7% 15.7% 8.1%
Trust policies engagement encouraged and signposted to
- Equality Diversity and Inclusion Workforce policy - Staff Members and Senior Managers are encouraged to attend "Creating inclusive environments with Cultural Intelligence" training
Outcomes will be collected and monitored including registrant clinical division, actions taken will be anonymised and shared at site OCB providing assurance of appropriate monitoring and governance.
Professional Registration policy and guidance for clinical staff
What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?
Protected Characteristic: Neutral
Sex (Men and Women Includes non-binary)
X Nursing and Midwifery below is based on 8 months rolling PIN lapse data. This includes 26 registrants, with any registrants that have lapsed over multiple months only being counted once, compared to current % of Nurses, Midwives and NA based on substantive employees on the 30/04/24:
Lapsed Registrants Comparison to substantive Headcount Sex Headcount % of lapsed Registrants % RN's % midwives % NAs Female 23 88.5%
84.7%
99.4% 91.9% Male 3 11.5%
15.3% 0.6% 8.1%
Trust policies engagement encouraged and signposted to: - To consider our language and pronouns of staff in our literature, assessments and conversations with staff
Outcomes will be collected and monitored including registrant clinical division, actions taken will be anonymised and shared at site OCB providing assurance of appropriate monitoring and governance. Professional Registration policy and guidance for clinical staff
What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?
Protected Characteristic: Neutral
Sexual Orientation (Lesbian, Gay, Asexual, Bisexual, and Straight)
X Nursing and Midwifery below is based on 8 months rolling PIN lapse data. This includes 26 registrants, with any registrants that have lapsed over multiple months only being counted once, compared to current % of Nurses, Midwives and NA based on substantive employees on the 30/04/24:
Lapsed Registrants Comparison to substantive Headcount Sexual Orientation Headcount % of lapsed Registrants % RN's % midwives % NAs Bisexual 1 3.8% 1.9% 2.8% 5.4% Gay or Lesbian 0 0.0% 4.1% 1.1% 2.7% Heterosexual or Straight 14 53.8% 76.5% 79.3% 83.8% Other 0 0.0% 0.0% 0.3% 0.0% Undecided 0 0.0% 0.1% 0.0% 0.0% Not Stated 11 42.3% 17.3% 16.5% 8.1%
Trust policies engagement encouraged and signposted to: - To consider our language and pronouns of staff in our literature, assessments and conversations with staff
Outcomes will be collected and monitored including registrant clinical division, actions taken will be anonymised and shared at site OCB providing assurance of appropriate monitoring and governance.
Professional Registration policy and guidance for clinical staff
Including but not limited to social economic factors (i.e. poverty and or isolation), caring responsibility, unemployment, homelessness, urbanisation, rurality, health inequalities, and new arrivals .
Social Economic provision x While it is a registrant's responsibility to maintain a valid registration there may be times where financial difficulties may present a barrier to maintaining their registration.
If the registrant feels there may be concerns on how they will pay for their registration then they should discuss this with their line manager/professional lead at the earliest possible time, in particular before any registration lapse occurs. We would expect our professional leads and line managers to support and provide guidance to the registrant to access resources such as the EAP or support the registrant identifying alternative payment methods with their registering body such as quarterly instalments (NMC https://www.nmc.org.uk/registration/your- registration/paying-your-fee/) if available.
However it is important to note that ultimately it is the individual registrant's responsibility to maintain their professional registration which includes payment of any associated annual fees.
Outcomes will be collected and monitored including registrant clinical division, actions taken will be anonymised and shared at site OCB providing assurance of appropriate monitoring and governance.
Professional Registration policy and guidance for clinical staff
Professional Registration policy and guidance for clinical staff
ERA Action Planning Form Action Plan Owner:
Commencement date:
FOR EQUALITY DIVERSITY AND INCLUSION TEAM Date of Assessment: (dd/mm/yyyy)
24/06/2024
Arfan Bhatti Date of review
24/06/2026 - in line with policy review cycle