Advice for temporary registrants

The student temporary register will close on 30th November 2020. After this date, all graduates will need to be on the full Register to practice lawfully.

The temporary register for former registrants currently has no planned date for closure.

Please see our approach to closing the temporary registers for more information on the closure.

There will be no automatic transfer of student temporary registration to the full Register for any profession. If you are a biomedical science or clinical science student with your name currently on the temporary register, you can continue to practice. However we encourage all other students to focus on completing their studies successfully and applying for full HCPC registration upon completion.

We have ensured nobody appears on this list who has been subject to fitness to practise concerns in the past.

We have also decided to exclude annotations on the COVID-19 temporary register(s).

This means registrants on the COVID-19 temporary register will not be able to practice in high-risk areas, such as prescribing or podiatric surgery.

This may however be subject to change, and we will continue to monitor developments to ensure this continues to be an appropriate approach.

You can find the COVID-19 temporary register here.

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.

We have also issued information pages on applying the standards during COVID-19. 

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 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.'

HCPC registrants working for an NHS trust to provide NHS services should have insurance and indemnity cover through the existing NHS mechanisms. To ensure there are no gaps in indemnity coverage, the Coronavirus Act 2020 provides additional powers to provide clinical negligence indemnity arising from NHS activities related to the Coronavirus outbreak, where there is no existing indemnity arrangement in place. There are no requirements for professionals to seek additional cover.

For further, more detailed guidance, please see the FAQs provided by NHS Resolution.

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.

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. More information about our expectations can be found on our information pages on applying the standards during COVID-19.

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. You can also read our advice page on scope of practice during COVID-19 for more information.

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.

You can also read our advice on record keeping during COVID-19 for more information.

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.

You can also read our advice on supervision and delegating during COVID-19 for more information.

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 or alternatively you can read our advice on medical entitlements during COVID-19.

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.

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.

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 has collated relevant e-learning content from the existing catalogue for the health and care workforce into one programme. This is available to all health professionals, including those outside of England.

Resources will be available here:

 https://www.e-lfh.org.uk/programmes/coronavirus 

If you suspect that you have symptoms of COVID-19, have been exposed to the virus or have been told to isolate by NHS Track and Trace, you should get tested as soon as possible. More information on getting a test can be found on the NHS website. 

If employed, you should also speak to your employer to see if there are any local policies in place you need to follow.

If you told to isolate, you will need to follow the latest advice issued by Government about self-isolation and who you need to tell. This might include service users, if you are delivering face to face services.

We are sorry to hear you’ve experienced these challenges. As your regulator, we would expect you to follow Government advice and therefore self-isolate if required in order to protect your health and others.

It is important you raise these concerns with your employer. We have issued advice for registrants about this, which can be found at Speaking up during an emergency. You may also want to speak to your professional body and/or trade union if you are a member.

You can also speak to an employment advice service like ACAS or seek advice directly from your employer's HR team.

The HCPC is unable to recommend personal protective equipment to registrants. You should speak to your professional body, if a member, to see if they have any specific advice for members of your profession in your position.

You can also read our advice on infection control and managing risk which links to relevant guidance on PPE in the four countries.

We expect registrants to follow Government advice about travelling including the relevant government advice about self-isolation if they re-enter the UK. Government is constantly updating their guidance on the COVID-19 outbreak and what impact this has on travel. You can find this advice on their website.

You should consult this before your trip, as you may be advised to cancel your plans or take certain steps on your return. This may include self-isolating for a period of time.

If you are employed, you may also want to speak to your employer to see if they have any guidance. We would expect registrants to adhere to their employer’s policies. You should notify your employer as soon as possible if you need to self-isolate, so that appropriate measures can be put in place for the service users under your care.

If you are self-employed and need to self-isolate, you will need to communicate this to service users and direct them to other sources of care and treatment where required.

If you need to hand over the care and treatment of a service user to a colleague, you must share relevant information as appropriate.

We are acutely aware of the issues our registrants are facing with regard to PPE shortages, and so have provided guidance in how they should approach this issue in our Managing risk: infection control information sheet.

In summary, this information recognises the challenging circumstances, highlights current guidance on PPE, affirms the role of the employer in providing appropriate PPE, and supports registrants in making professional judgements to protect themselves and the wider service user population.

The information also sets out that, should any concerns be raised about your practice (which could include refusal to practice because of a lack of PPE) we will take account of:

• The circumstances and context you were working in;
• any steps you took to raise your concerns; and
• relevant resource, guidelines and protocols in place at the time.

This position is set out in the joint statement from Chief Executives of statutory regulators of health and care professionals

Service user safety should be your primary concern, and so we expect you to prioritise treatment.

Notwithstanding this, if the PPE available is not the appropriate standard or in short supply, you may need to make changes to the manner and/or frequency with which you provide treatment.

If the risks of treating a service user is too high you should raise your concern with your employer, escalating where necessary. You should keep a clear record of your decision, outlining the reasons for that decision.

The circumstances leading to any decision to refuse to treat a service user will vary greatly. It is for you to consider the specific circumstances you face and use your professional judgement to determine and appropriate approach.

Should any concerns be raised about your practice in this regard, we will take account of:

• the circumstances and context you were working in;
• any steps you took to raise your concerns; and
• relevant resource, guidelines and protocols in place at the time.

This is why it is vital you keep a contemporaneous record of your decision making.

Our Approach to the Removal of Registrants from the Temporary Register document explains how we will assess and consider a concern we receive about someone on the temporary register.

If you have a concern about a COVID-19 temporary registrant, please email ftp@hcpc-uk.org.

There is additional guidance on raising a concern available on our website.

Our Approach to the Removal of Registrants from the Temporary Register document explains how we will assess and consider a concern we receive about someone on 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.