Advice from CQC on compliance documentation for practices engaging locum GPs

Nigel Sparrow, the CQC's Senior National GP Advisor and Responsible Officer, has published some new helpful guidance to clarify what sort of information is required by practices in his latest Nigel's Surgery on GP Locums.

We've taken each of Nigel's points and provided a checklist of everything a practice will need:

Your NASGP membership gives you free access to LocumDeck, which allows you to upload, store and display all these necessary documents for practice managers.

CQC adviceNASGP explaination
Proof of being a GPCopy of medical degree and completion of GP training (if issued)
Medical indemnityDeclared as part of NHS appraisal or copy of certificate (NB certificate may not be valid if the individual is working more sessions than is indemnified for – hence NHS appraisal declaration is preferred)
GMC registrationGMC number
Performers ListCopy of certificate (and is proof of DBS check and being a GP if not originally given a certificate of completion of training). In England practices can search online for your status.
Proof of identity including a recent photographNHS smartcard or driving licence or passport
Satisfactory evidence of conduct in previous employment concerned with the provision of health or social care; or children or vulnerable adultsAt least one recent (within last year) reference
Satisfactory documentary evidence of any relevant qualificationGMC membership + copy of any relevant certificates if performing a specific role (smears etc).
A full employment history together with a satisfactory written explanation of any gaps in employmentCV
Such other information as is required under any enactment to be kept by the registered person in relation to such persons employedDBS check – NASGP advice is that for temporary self-employed locums evidence of being on a Performers List is proof of valid DBS (see separate CQC advice).

See also

As a freelance GP you'll need to hold all sorts of information - names and addresses of practices; other GPs; colleagues; educational centres etc.

And what do you do with this data - do you market yourself? Is it just for invoices? Do you give your data to other GPs or practices?

It is possible that, as a small business, you may have to register with the Data Protection Act.

Whether you need to all depends on what you use your data for and, needless to say, isn't straight forward. Fortunately, the Information Commissioner's Office website has a series of simple questions to ask and, depending on your answers, will tell you whether you need to register or not (and what can happen if you don't!).

As a GP working, or planning to work, in the UK, you need to go through a three-stage process.

Step 1 - join the GMC's GP register

  • If you are applying to work as a GP (general practitioner or family physician) in the UK, as well as being licensed by the GMC, you'll also need to be on the GMC's GP Register.
  • About the GMC GP register

Step 2 - join one of the four UK Performers Lists

  • If you you're not already working, state your “intent to work” on your performers list application, outlining roughly how many sessions a week you plan to work from a particular date.



Northern Ireland


Step 3 - join the NHS appraisal process

  • Your Area Team will assign you to a 'designated body', who'll oversee your appraisal and subsequent revalidation.

Hepatitis B immunisationIt's now a requirement of the Care Quality Commission CQC that every member of staff working in a GP practice has an up-to-date Hepatitis B status. The MPS have prepared a summary of why this is needed, as part of the CQC's Cleanliness and infection control (Outcome 8, Regulation 12) "People are cared for in a clean environment, and are protected from acquiring infections".

If you're a chambers locum or are employed as an agency locum, they'll no doubt otherwise notify every practice on your behalf. Otherwise it's a sign of a well organised locum to provide this in advance of working.

If you're employed by a practice as a salaried GP, you'll be entitled to free immunisation status checks and boosters if they're a good employer. As a locum, unless you can persuade a friendly practice, you'll have to arrange this yourself with your own GP as a private service.

Added to this, the Green Book states:

Healthcare workers in the UK and overseas (including students and trainees): all healthcare workers who may have direct contact with patients’ blood, blood-stained body fluids or tissues, require vaccination. This includes any staff who are at risk of injury from blood contaminated sharp instruments, or of being deliberately injured or bitten by patients.

As a GP, if you're exposed to continuing risk of infection, you should have a single booster dose of vaccine, once only, around five years after primary immunisation. Measurement of anti-HBs levels is not required either before or after this dose.

The Disclosure and Barring Service DBS check (used to be known as the Criminal Records Bureau CRB check) needs to be performed only once in order to appear on the National Performers list. Once on the Performers List, there is no requirement to have further DBS checks for the Performer's List as this is part of Performers List monitoring. The purpose of the national list in England is to allow GPs to move to different parts of England without having to apply to a local performers list.

DBS in England

Scotland, Wales and Northern Ireland

Locum agencies

If you work for locum agencies, not only will they each need a DBS check, but they may also have their own internal reasons to insist on one as often as they like. In which case, you may like to use the annual DBS update service for £13 per annum (which must be applied for within 19 days of receipt of your certificate being issued).

Further information on DBS checks, which reinforce the above, is available from the Care Quality Comission CQC.

Yes. The PCSE website states " [As long as it can be ascertained via HEE or GMC website that the GP has completed their training]...there should be no reason why the trainee should not be permitted to practise independently whilst the administrative change in status is undertaken."

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1 Response

  1. Paul Atkinson
    Given the National Performers List in England no longer send letters I wonder if this page needs updating? I also recommend joining the DBS 'update' scheme.

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