Guidance

Who Requires a DBS check?

• For Salaried GPs & Locums. If a DBS has already been undertaken in order to be admitted to the performers list (pre the Covid-19 pandemic) and for those who were in their practice prior to 1st April 2013 (when CQC came into being) a DBS is not needed until/unless they change practice or change status e.g. from Salaried GP to Partner. In these circumstances a risk assessment needs to be undertaken including ensuring they are on the Medical Performers List and that they have current GMC registration. Also obtain satisfactory references and check their C.V. to ensure there are no un-explained gaps in employment etc. The National Performers List website can be accessed at:  http://www.performer.england.nhs.uk/ .  Ensure you keep a written risk assessment of the steps taken. If offered a DBS certificate then take a copy or at least record the number and check it online if it’s a transportable version. Ensure you keep a written risk assessment of the steps taken.
• For Partners, If you are applying to be a registered partner, registered manager or individual provider you must get a Disclosure and Barring Service (DBS) check before you submit your application. However, if you are registered with any of the professional bodies listed below, you do not have to apply for a CQC-CE-DBS (CQC countersigned enhanced DBS) check. This is because registration with the professional bodies listed below incorporates checks on your identity and professional standing.

For more information, please see  DBS checks for CQC registration

• If a Locum GP changes status to become a full partner then you need to advise CQC as your registration changes. The new partner will then need to apply for an enhanced DBS via the LMC. Regulation 15: Notice of changes – Care Quality Commission (cqc.org.uk)
• Other members of staff who joined the Practice after 1st April 2013 need to be risk assessed to see whether a DBS check is required. The rule of thumb is that all clinicians, nurses, HCA’s, phlebotomists & chaperones need an “enhanced check” plus anyone else who may be in a one to one situation with a child or vulnerable adult – so not usually admin staff or receptionists but probably the Practice Manager/Deputy etc – a “standard check” would suffice for these roles.
• For Chaperones A few practices have been advised that all of their chaperones must have a DBS check even where they’ve been working at the surgery and as a chaperone for many many years. The practices involved have undertaken risk assessments, the staff have undergone training, they’re following their chaperone policy to the letter and we had initially advised that this was OK. We asked CQC Inspector Joanne Ward if anything has changed. Her response is: All staff who chaperone need to have a risk assessment to determine need for a DBS and record how the decision was made. The practice policy needs to state the role of the chaperone clearly including how to ensure assessment to be a chaperone, training and specifics of the role requirements. However if they do not have a DBS completed then the role of that chaperone must  include that they leave  the room if the clinician leaves the room. We find most practices do ensure that DBS checks are completed and this is encouraged.
• For Dispensing staff, the practice will need to carry out a risk assessment to determine if the staff member requires a check and have this assessment documented on file. If the dispensing staff member is to undertake one to one consultations then an enhanced DBS check is suggested.
• For Locum Practice Nurses, the individual will require an enhanced DBS check specific to their place of work, unless they are in receipt of a transportable DBS certificate.
• Any volunteers within the surgery also need to be risk assessed.  Contract cleaners do not need a DBS check unless the practice states in its own policy that a check is required. It was originally thought that cleaners required a DBS check as they could observe financial or confidential data but DBS and CQC have clarified that this is about protecting patients. Practices sometimes choose to insist upon a check to ensure that anyone left alone/unobserved  in their building is a fit person for this purpose.
• If you yourself require a DBS check, please do not apply on behalf of yourself, please speak to your manager about arranging this for you. Your Manager will need to initiate your application and verify your identity documents for us. Should you create your own application online the system will not allow you to proceed. Please ask a Manager to create the application for you.

DBS requirements for Trainees in a Practice Placement

Foundation doctors (F2) in a GP placement

F2 doctors are employed by a hospital trust and have a DBS check at the start of their F2 year.. As they remain with the same employer, this DBS is sufficient for the duration of the F2 year. F2 doctors are exempt from requirement to be on the National Medical Performers List. The practice can ask to see trainees’ current DBS certificate.

ST1 and ST2 trainees in a GP placement

As with F2 doctors, for ST1 and ST2 trainees who are employed by a hospital trust, the original enhanced DBS is sufficient for the duration of the placement provided they have subscribed to the DBS Update Service.

The regulations were amended in September 2023 and ST1 and ST2 GP Trainees are not required to apply to join the National Medical Performers List (NMPL) until they are reaching the end of their training programme.

ST3 trainees in a GP placement

Similarly, for ST3 trainees who are employed by a hospital trust, the original enhanced DBS is sufficient for the duration of the placement provided they have subscribed to the DBS Update Service.

A GP Registrar (ST3) needs to submit their application to the National Medical Performers List (NMPL) no earlier than six months prior to obtaining their certificate of completed training (CCT) and no later than three months prior to CCT. If the applicant is living in, or has previously lived in the UK, the applicant must present evidence of having applied for an enhanced DBS check, or of having signed up to the DBS update service.

What Happens when Convictions are Disclosed?

In applying for job vacancies there maybe occasions when applicants disclose previous convictions. What do you do? Also, whilst the vast majority of DBS checks come back clear, there will be occasions when some will be returned showing convictions. Has the practice got anything in place to deal with such a scenario?
Essentially this will involve a risk assessment, however there are other factors that will also need to be looked at and considered.
Julie Meakin from The Vine Medical Group has developed a Protocol – Recruitment of ex-offenders  to deal with these issues. You may download and adapt for your practice should you wish to do so, with kind thanks to Julie.

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