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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Professional Registration and Revalidation Policy

1. Purpose

The purpose of this policy is to set out the arrangements and expectations of {{org_field_name}} for the professional registration and revalidation of Registered Nurses (RNs) employed or engaged by the agency and supplied to hirers.

{{org_field_name}} operates as a temporary staffing employment business. It does not itself provide, manage or control regulated nursing or personal care and does not carry on a regulated activity requiring registration with the Care Quality Commission solely by reason of supplying nurses to hirers.

This policy is designed to ensure that all Registered Nurses supplied by {{org_field_name}} maintain current and appropriate registration with the Nursing and Midwifery Council (NMC), satisfy the professional requirements applicable to the assignments for which they are supplied, and remain appropriately authorised to practise.

The policy also establishes the arrangements used by {{org_field_name}} to verify, record and monitor professional registration and to support nurses in meeting their NMC revalidation responsibilities, in accordance with the Nursing and Midwifery Order 2001, the NMC Code, the NMC’s current revalidation requirements, the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003, as amended.

The director(s) of {{org_field_name}} are responsible for implementing, monitoring and auditing compliance with this policy.

2. Scope

This policy applies to:

• All Registered Nurses (RNs) employed or otherwise engaged by {{org_field_name}} and supplied to hirers on temporary assignments, including those engaged under zero-hours contracts or other lawful arrangements.
• The director(s) and any member of staff of {{org_field_name}} responsible for recruitment, compliance, professional registration checks, assignment decisions or revalidation support.
• The provision of registration and professional-authorisation information to hirers and, where legally required, to relevant regulatory, enforcement, safeguarding or professional bodies.

For the purposes of employment agency legislation, {{org_field_name}} operates as an employment business when it supplies temporary workers to work for and under the supervision and direction of a hirer.

{{org_field_name}} does not provide or control regulated nursing or personal care and is not required to register with the Care Quality Commission merely because it supplies nurses to a service provider. Nurses supplied by {{org_field_name}} remain subject to the professional regulation of the Nursing and Midwifery Council and to the requirements imposed by the hirer for the particular assignment.

Healthcare Assistants (HCAs) and other unregistered roles are not subject to NMC registration or revalidation. They remain subject to all applicable recruitment, suitability, right-to-work, safeguarding, training, competence and conduct requirements relevant to their role.

3. Related Policies

• Recruitment Policy
• Pre-Employment Checks Policy (including DBS & References)
• Training and Development Policy
• Temporary Staffing Handbook
• Supervision and Appraisal Policy
• Complaints and Disciplinary Policy
• Safeguarding Policy
• Whistleblowing Policy

4. Legal and Regulatory Framework

This policy is governed or informed, as applicable, by the following legislation and professional requirements:

• Employment Agencies Act 1973, as amended.
• Conduct of Employment Agencies and Employment Businesses Regulations 2003, as amended.
• Nursing and Midwifery Order 2001, as amended.
• The current Nursing and Midwifery Council Code: Professional standards of practice and behaviour for nurses, midwives and nursing associates.
• The current Nursing and Midwifery Council revalidation requirements and associated guidance.
• Employment Rights Act 1996, as amended, where applicable to the employment or worker status of individuals engaged by {{org_field_name}}.
• Agency Workers Regulations 2010, as amended, where applicable.
• Health and Safety at Work etc. Act 1974 and applicable health and safety legislation.
• UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.

As an employment business supplying temporary workers, {{org_field_name}} must comply with the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003. This includes obtaining and verifying information relevant to a work-seeker’s suitability, qualifications and professional authorisations before supply and complying with the additional requirements that apply where work involves vulnerable persons.

The Fair Work Agency is the state enforcement body responsible for regulating employment agencies and employment businesses and enforcing the relevant employment agency legislation.

The professional registration of nurses remains the responsibility of the Nursing and Midwifery Council. {{org_field_name}} will therefore apply the current NMC requirements in force at the relevant time.

5. Professional Registration Requirements

All Registered Nurses employed or engaged by {{org_field_name}} must:

• Hold current, valid registration with the Nursing and Midwifery Council (NMC).
• Remain registered and in good standing throughout their engagement with {{org_field_name}}.
• Notify the director(s) immediately of any changes to their registration status, including lapsed registration, conditions of practice, cautions, suspensions, or fitness to practise investigations.

As a condition of engagement, no nurse may be allocated to any client without active NMC registration.

6. Pre-Employment Verification of Registration

Before a Registered Nurse is approved for supply to a hirer, {{org_field_name}} will verify that the individual holds the professional registration and authorisation required for the proposed position.

The director(s), or a suitably authorised member of staff acting on their behalf, will:

• Verify the individual’s identity in accordance with the agency’s recruitment and pre-employment checking procedures.
• Verify the nurse’s current registration directly against the NMC register or the NMC’s employer registration checking service.
• Confirm that the individual is registered in the appropriate field or fields of nursing required for the proposed assignment.
• Record the nurse’s NMC PIN and relevant registration and revalidation information necessary for compliance monitoring.
• Check any conditions of practice, suspension orders, interim orders or other restrictions or sanctions shown on the NMC register that may affect the nurse’s ability or suitability to undertake the proposed assignment.
• Confirm that the nurse possesses any experience, training, qualifications and professional authorisations required by law, the NMC or the hirer for the position.
• Obtain and retain appropriate evidence of qualifications and professional authorisations where required under the Conduct of Employment Agencies and Employment Businesses Regulations 2003.
• Where required by those Regulations, offer the relevant qualification or authorisation information or copies to the hirer before the nurse is supplied.
• Complete the additional suitability and safeguarding checks required for work involving vulnerable persons under the agency’s Recruitment Policy and Pre-Employment Checks Policy.

The existence of a condition, restriction, warning or other NMC fitness-to-practise information will be considered according to its terms and its relevance to the particular role. {{org_field_name}} will not supply a nurse where:

• the individual is not currently registered when registration is required for the position;
• an NMC order, restriction or condition prevents the individual from lawfully undertaking the proposed work;
• the required professional authorisation cannot be verified; or
• the information available establishes that the individual is unsuitable for the proposed position.

Where information indicates that an individual may be unsuitable but the position has not yet been established, {{org_field_name}} will deal with the matter in accordance with Section 12 of this policy and the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

No Registered Nurse will be approved to commence an assignment requiring NMC registration until their current registration and relevant professional authorisation have been verified.

7. Ongoing Monitoring of Registration

The director(s) will:

• Check the registration status of all RNs monthly via the NMC website.
• Document each check and retain the records securely.
• Notify the nurse immediately if any discrepancies are identified.
• Suspend or remove the nurse from active deployment if registration lapses or is subject to restrictions, until resolved.

Temporary workers are responsible for cooperating fully with registration checks and promptly updating {{org_field_name}} on any changes.

8. Revalidation Requirements

All Registered Nurses are personally responsible for maintaining their NMC registration and completing the NMC revalidation process at the intervals and by the deadlines specified by the NMC.

Under the current NMC requirements, a Registered Nurse revalidating their registration must meet the applicable requirements during the relevant three-year registration period, including:

• Completing at least 450 hours of registered practice.
• Where applicable, completing 900 practice hours when renewing two registrations, for example where an individual is registered as both a nurse and a midwife.
• Undertaking at least 35 hours of continuing professional development (CPD) relevant to their scope of practice, of which at least 20 hours must be participatory learning.
• Obtaining five pieces of practice-related feedback.
• Preparing five written reflective accounts in accordance with the NMC requirements.
• Having a reflective discussion with another NMC registrant in accordance with the NMC requirements.
• Making the required health and character declaration.
• Having in place an appropriate professional indemnity arrangement covering the practice they undertake in the United Kingdom.
• Obtaining confirmation that they have met the required revalidation requirements.
• Completing and submitting their revalidation application through the process required by the NMC within the applicable timescale.

Each nurse is responsible for checking their own revalidation application date and ensuring that all requirements are completed sufficiently in advance to maintain continuous registration.

A nurse must not undertake an assignment requiring NMC registration where their registration has lapsed or where they are otherwise not legally or professionally authorised to perform the work.

9. Supporting Revalidation for Agency Nurses

{{org_field_name}} recognises that temporary and agency nurses may require additional support to meet revalidation requirements. The director(s) will:

• Provide guidance to RNs on the NMC revalidation process.
• Offer information about available CPD opportunities organised or recommended by {{org_field_name}}.
• Facilitate reflective discussions where appropriate and if resources allow.
• Act as confirmers for revalidation if suitably qualified and not subject to conflicts of interest.
• Issue employment and practice hours confirmation letters, upon request, confirming shifts worked with {{org_field_name}}.

All RNs are encouraged to seek out additional CPD independently and maintain evidence of CPD and reflective practice.

10. Nurse Responsibilities

It is the responsibility of each Registered Nurse to:

• Maintain an up-to-date NMC registration.
• Adhere to the NMC Code at all times.
• Complete revalidation requirements within the prescribed deadlines.
• Inform {{org_field_name}} immediately if their registration status changes.
• Provide evidence of revalidation completion when requested by the director(s).
• Keep accurate records of practice hours, CPD, reflective accounts, and revalidation submissions.

Failure to maintain NMC registration will result in immediate suspension from shifts until the issue is rectified.

11. Director(s) Responsibilities

The director(s) of {{org_field_name}} have overall responsibility for the agency’s compliance with this policy.

As {{org_field_name}} operates as a temporary staffing employment business and does not itself carry on a regulated activity requiring registration with the Care Quality Commission, responsibility for this policy rests with the director(s) or another appropriately authorised person appointed by the agency rather than with a CQC Registered Manager.

The director(s) will ensure that:

• Current NMC registration is verified before a nurse is supplied to an assignment requiring NMC registration.
• Appropriate records are maintained of nurses’ NMC PINs, registration status and relevant revalidation information.
• The agency’s specified periodic NMC registration checks are completed and documented.
• Any conditions of practice, suspension orders, interim orders or other relevant restrictions identified through an NMC registration check are considered before further supply.
• No nurse is knowingly supplied to undertake work for which they do not hold the professional registration or authorisation required by law, the NMC or the hirer.
• Information received indicating that a nurse may be unsuitable or is unsuitable for an assignment is dealt with promptly in accordance with the Conduct of Employment Agencies and Employment Businesses Regulations 2003 and Section 12 of this policy.
• Nurses are provided with reasonable registration and revalidation information and support in accordance with this policy.
• Personal information obtained through professional registration and revalidation checks is processed in accordance with the UK GDPR, Data Protection Act 2018 and the agency’s Data Protection and Confidentiality Policy.

The director(s) will liaise with hirers, the NMC and any other relevant statutory, safeguarding or enforcement body where notification or co-operation is required by law, professional regulation or the circumstances of the particular case.

12. Non-Compliance and Remedial Action

Professional registration or suitability concerns may arise where a Registered Nurse:

• Allows their NMC registration to lapse.
• Fails to complete revalidation in time and consequently ceases to hold effective registration.
• Becomes subject to conditions of practice or another restriction affecting the work they are permitted to undertake.
• Becomes subject to an interim suspension order or suspension order.
• Is removed or struck off the NMC register.
• Is found not to possess a qualification or professional authorisation required for the position.
• Provides information concerning professional registration, qualifications or authorisations that is false, misleading or cannot be verified.
• Becomes the subject of other information indicating that they may no longer be suitable for the assignment for which they are being supplied.

Where a nurse does not hold effective NMC registration and registration is required for the assignment, or where an NMC order prevents the nurse from undertaking the work concerned, {{org_field_name}} will cease supplying that nurse to the affected assignment without delay.

Where {{org_field_name}}, acting as an employment business, receives information indicating that a nurse may be unsuitable for a position but the matter has not yet been established, {{org_field_name}} will, without delay:

• Inform the relevant hirer of the information indicating possible unsuitability, subject to applicable data-protection and legal requirements.
• Make appropriate enquiries to establish the relevant facts and assess the nurse’s suitability.
• Keep the hirer appropriately informed of the enquiries made and relevant information obtained.
• Take any interim action necessary to protect patients, service users, the worker and the hirer while the matter is considered.

Where the enquiries establish that the nurse is unsuitable for the position, {{org_field_name}} will cease supplying the nurse to that position without delay.

Where appropriate, {{org_field_name}} will also:

• Record the concern, enquiries, decision and action taken.
• Notify any affected hirer where required.
• Consider whether the matter must or should be referred to the Nursing and Midwifery Council in accordance with the applicable NMC guidance.
• Make a referral to the Disclosure and Barring Service where the statutory referral conditions and duties are met.
• Notify the police, local authority safeguarding services or another statutory body where this is legally required or necessary in connection with a safeguarding or criminal matter.
• Co-operate with any lawful investigation or request for information from the Nursing and Midwifery Council, Fair Work Agency or another competent statutory authority.
• Support the nurse to address a registration or revalidation issue where appropriate, without permitting them to perform work for which they are not currently registered, authorised or suitable.

A referral or disclosure to an external organisation will only be made where there is an appropriate legal, regulatory, safeguarding or professional basis for doing so.

13. Training

All RNs engaged by {{org_field_name}} will receive:

• Induction covering professional registration expectations.
• Annual updates on NMC revalidation processes and changes to relevant standards.
• Ongoing support through supervision and reflective discussions.

Agency nurses are required to actively participate in CPD, and {{org_field_name}} will facilitate access to core training and additional learning when available.

14. Documentation and Record-Keeping

{{org_field_name}} will maintain appropriate records demonstrating compliance with its professional registration checking obligations.

These will include, where applicable:

• The nurse’s NMC PIN and verified registration status.
• The date and outcome of each NMC registration check.
• Relevant registration and revalidation dates used for compliance monitoring.
• Records of any conditions of practice, suspension orders, interim orders or other relevant NMC restrictions identified during a registration check.
• Evidence that professional qualifications or authorisations required for the position have been checked.
• Records demonstrating compliance with applicable requirements of the Conduct of Employment Agencies and Employment Businesses Regulations 2003 concerning qualifications and professional authorisations.
• Records of revalidation support provided by {{org_field_name}}, where applicable.
• Records of professional registration or suitability concerns, enquiries, risk assessments, decisions, notifications and actions taken.

Professional registration, revalidation and fitness-to-practise information constitutes personal data and may, depending on its content, include special category personal data or information requiring additional protection.

All such information will therefore be processed in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and {{org_field_name}}’s Data Protection and Confidentiality Policy.

{{org_field_name}} will ensure that:

• Only information that is necessary for a lawful and specified purpose is collected and retained.
• Access is restricted to persons who require the information for legitimate business, compliance or safeguarding purposes.
• Information is stored securely and protected against unauthorised access, disclosure, alteration, loss or destruction.
• Records are kept accurate and, where necessary, updated.
• Personal information is not retained for longer than required by applicable legislation, regulatory requirements, contractual requirements and the agency’s documented retention schedule.
• Information is shared with hirers, the NMC or other third parties only where there is an appropriate legal basis or other lawful justification for doing so.

15. Promoting Safe and Effective Practice

{{org_field_name}} promotes:

• High professional standards among all agency nurses.
• A positive culture of professional accountability.
• Proactive revalidation practices.
• Early identification of risks linked to registration or revalidation non-compliance.
• Supportive leadership by the director(s) to help RNs remain compliant with NMC requirements.

16. Governance, Audit, and Quality Assurance

The director(s) will:

• Audit professional registration and revalidation compliance quarterly.
• Monitor patterns, trends, and risks related to registration and fitness to practise.
• Report findings to stakeholders if necessary.
• Implement improvements when required.

All audits will be documented, and action plans will be developed where issues are identified.

17. Policy Review

This policy will be reviewed annually by the director(s) of {{org_field_name}}, or sooner if:

• There are changes in legislation, NMC guidance, or other regulatory frameworks.
• There is learning from incidents, audits, or inspections requiring procedural updates.
• There are changes to the agency’s structure, practices, or contractual obligations.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.