On 17 March 2020, in response to the COVID-19 pandemic, the HCPC published a COVID-19 Temporary register, of two parts. Our intention in doing so was to ensure there were no regulatory barriers to the following two groups practising on a temporary basis:
- Former registrants who had de-registered within the last three years.
Final year students, on UK approved programmes, who had completed all their work-based learning requirements
- As the UK moves through the COVID-19 emergency period, we have turned our attention to the closure of the Temporary register(s).
This document sets out our approach. A key aspect of this will be ongoing engagement with the sector to inform our understanding of workforce requirements.
Our key aim is to close the Temporary register(s) in a way which minimises disruption to health and care services and enables us to continue to perform our statutory functions in a timely and effective way to safeguard public protection.
Where possible, and recognising the potential differences across professions and the provision of healthcare across the UK, we will work to deliver a unified approach across the healthcare regulators.
We believe this will help to support understanding across our shared stakeholders, and safeguard public protection.
The Temporary register(s) should remain in place only for as long as is necessary to manage the emergency response to the COVID-19 pandemic.
On this basis, we would seek to close the Temporary register once the UK has passed through that period; and any risk of a second peak has dissipated.
This will be done in close consultation with NHS bodies, Chief Allied Health, and Chief Scientific Officers across the four nations, the Department of Health and Social Care, the Council of Deans of Health, and other relevant health and care service partners.
Temporary register (students)
We plan to close temporary registration for students by the end of September 2020.
This would mean eligible students currently on the Temporary register would no longer be able to practice lawfully using a protected title unless they complete their HCPC approved programme and make a successful application to the full Register.
Our decision is on the basis that:
- deployment numbers for students to paid employment in regulated roles supporting the COVID-19 response are low;
- education providers are facing challenges in securing placement learning for their students in light of the COVID-19 impact and the reconfiguration of non-essential care pathways to manage the pandemic; and
- the education sector is encouraging student progression to be prioritised over their inclusion in the temporary workforce, to ensure there are no delays to students entering the full register and permanent workforce.
Temporary register (former registrants)
Further spikes in COVID-19 infections may require the Temporary register (former registrants) to be open. There could be consequences if this register is closed too early and subsequently need to be re-opened.
Impacts might be felt on temporary registrants’ willingness to work, public understanding of their role, and the speed with which the NHS is able to call on this group to support any future workforce demand.
Nevertheless, the extended use of the Temporary register beyond that which is necessary presents regulatory risks. There are differences in the regulatory controls we can exert on temporary registrants as compared with full registrants, and there are less formal processes to safeguard registrants, for example providing them with an opportunity to evidence their fitness to practise where concerns are raised.
Retaining the Temporary register(s) too long after the COVID-19 peak presents a real risk of undermining regulatory processes.
Furthermore, those practising on the full Register may also be discouraged by the ongoing temporary registration of a workforce who do not pay fees, and are not subject to the usual regulatory processes; for example obligations to provide evidence of continuing professional development.
In order to minimise disruption to health and care services and to safeguard public protection, we needed clarity about the current deployment figures, future intentions, and workforce demand for our professions to inform our approach to closure of the Temporary register for former registrants. We had some initial data from the Bring Back Staff (BBS) returner survey.
However, this data didn’t cover Scotland, Wales and Northern Ireland, and was limited to those who have engaged the NHSEI returner survey; not those who have sought employment through existing/local contacts.
Soft intelligence indicated demand for healthcare professionals in practice may vary by setting (acute care, community care, etc), country and region. There may also be variation in the workforce demand by profession:
- Acute care requirements may be reduced whilst rehabilitation needs increase, engaging professions such as physiotherapists, occupational therapists and speech and language therapists.
- Mental health requirements of the UK population, both professionals and the public (of all ages), may increase as individuals cope with the ongoing pressures, and as they reflect on their experiences. Therefore, there may be an increasing demand for the services of practitioner psychologists and art therapists as we move through, and out of, the peak COVID-19 pandemic.
- Similarly, community services which have been paused during the lockdown period may face capacity issues as provision resumes, exacerbated by pre-existing shortages in professions such as podiatrists.
With these considerations in mind (and likely others), we are seeking key stakeholder views to establish intelligence around current deployment figures, temporary registrants’ future intentions, and workforce demand for our professions to inform our approach.
Survey of the Temporary register
In order to better understand deployment numbers and future intentions of temporary registrants, we undertook a short survey of the Temporary register.
Stakeholder engagement across the four nations
Ongoing stakeholder engagement will be vital in safeguarding public protection by ensuring
- we continue to gather information about current and future demand levels so that these are clearly understood (notwithstanding further peaks); and
- temporary registrants, their employers and their service users are clear about their current and future registration status.
Supporting former registrants to enter full registration
The Temporary register should not be used to mitigate pre-existing occupational shortages but we recognise the importance of encouraging those on the temporary workforce who wish to continue to practise to move to the full Register.
Whilst we will still require applicants to the Register to evidence their ability to meet our standards, we will ensure flexibility in facilitating them to do so wherever possible:
- Our returning to practice processes will take account of the impact COVID-19 may have had on the timescales within which returnees have been able to complete their period of updating.
- We will support returnees in using evidence of practice as a temporary registrant as proof of ‘supervised practice’, where appropriate.
- We will consider alternative forms of ‘formal study’ gained during the COVID-19 pandemic, where these are reasonable and give rise to similar levels of learning.
We are currently developing guidance to expand on the above, along with guidance on completion of the return to practice documentation.
Supporting education providers and students
As set out above we will at this stage look to close the Temporary register for students by the end of September 2020.
We are taking steps to ensure this is communicated to education providers and students on the Temporary register and encourage them to make an application for full registration when eligible to do so.