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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Using Temporary Staffing Agencies Policy

1. Purpose

This policy outlines how {{org_field_name}} safely and effectively utilises temporary staffing agencies to ensure continuity of high-quality care and support during staff shortages or unexpected absences. The use of agency staff is carefully managed to meet the standards set out in the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, particularly in line with Regulation 19 (Fit and Proper Persons Employed), Regulation 18 (Staffing), Regulation 12 (Safe Care and Treatment), and Regulation 17 (Good Governance). Our approach ensures that temporary staff are competent, safe, and appropriately supervised to deliver person-centred care in accordance with our values.

This policy also supports compliance with CQC’s Single Assessment Framework, particularly the quality statements relating to safe and effective staffing, safeguarding, involving people to manage risks, learning culture, governance, management and sustainability. It ensures that temporary agency workers are only used where their deployment is safe, properly authorised, risk assessed, recorded and monitored, and where the service can evidence that each worker is suitable, competent, appropriately trained and able to meet the needs of the people using the service.

2. Scope

This policy applies to the Registered Manager, all care staff, team leaders, and administrative staff involved in sourcing, inducting, supervising, or working alongside agency staff. It applies to any individual supplied by a third-party staffing agency or temporary staffing provider to work within or on behalf of the service, whether on a single shift, short-term, block-booked or longer-term basis. This includes care workers, nurses, senior care workers, support workers, domestic, catering, maintenance or administrative agency workers where their role may affect people’s care, safety, dignity, confidentiality, infection prevention and control, or the delivery of a regulated activity.

3. Related Policies

This policy should be read alongside the following:

• CH02 – Fit and Proper Persons: Employed Staff Policy
• CH04 – Good Governance Policy
• CH07 – Person-Centred Care Policy
• CH13 – Safeguarding Adults from Abuse and Improper Treatment Policy
• CH26 – Recruitment, Selection and Retention Policy
• CH27 – Staff Supervision, Training and Development Policy
• CH34 – Confidentiality and Data Protection (GDPR)-Service User Policy

4. Policy Details

4.1 Strategic Use of Agency Staff

The use of agency staff is a contingency measure to ensure safe staffing levels during staff absences, vacancies, or periods of increased demand. Permanent staffing remains our priority, and reliance on temporary staff is kept to a minimum. Before agency staff are requested, the Registered Manager or delegated senior must consider the current dependency, acuity, risks and preferences of people living at the service, the skill mix already on duty, any planned appointments or activities, infection prevention and control risks, safeguarding risks, medicines support needs and any known behavioural, communication, mobility, nutrition, hydration or end-of-life care needs. The decision to use agency staff must be recorded on the rota, staffing dependency tool, daily staffing record or other staffing governance record. Decisions to use agency staff are authorised only by the Registered Manager {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} or in their absence, a delegated senior. We maintain a list of pre-approved agencies that meet our strict compliance checks.

Wherever possible, the service will use regular agency workers who are familiar with the home, the people living at the service, care plans, communication needs, environmental risks and local procedures. Agency staff must not be used as a substitute for effective recruitment, retention, supervision, training or workforce planning.

4.2 Vetting and Due Diligence of Agencies

{{org_field_name}} will only use agencies that have been approved by the Registered Manager following documented due diligence. The service must be satisfied that the agency has robust recruitment, selection, training, supervision and disciplinary procedures that support compliance with Regulation 18 and Regulation 19 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.

Before an agency is approved, the agency must provide written assurance, and where requested evidence, that it completes and maintains appropriate checks for each worker supplied to the service. This includes:

• proof of identity, including photographic identification;
• evidence of the person’s right to work in the UK, checked in line with current Home Office requirements;
• an enhanced DBS check for the appropriate workforce and barred list check where the role is eligible and involves regulated activity;
• confirmation that the worker is not barred from carrying out regulated activity with adults;
• employment history, including a satisfactory written explanation of any gaps in employment where applicable;
• satisfactory evidence of conduct in previous employment involving health or social care, children or vulnerable adults, where applicable;
• two satisfactory references, including the most recent relevant employer where possible;
• evidence of qualifications, registration and professional indemnity where the role requires it, including NMC registration for agency nurses;
• evidence of current role-specific training and competence;
• evidence that the worker has received learning disability and autism training appropriate to their role;
• evidence of moving and handling competence, safeguarding adults training, infection prevention and control training, fire safety awareness, health and safety, basic life support or first aid awareness, food hygiene where relevant, medication training and assessed competence where medication duties are required;
• confirmation that the worker is physically and mentally able, with reasonable adjustments where required, to carry out the role safely;
• confirmation that the agency has a process for monitoring conduct, performance, training expiry dates, DBS status, right to work status and professional registration status;
• evidence of public liability, employer’s liability and professional indemnity insurance;
• confirmation that the agency complies with the Agency Workers Regulations 2010 and all relevant employment legislation.

The service will not rely solely on verbal assurances. The Registered Manager or delegated senior must ensure that an agency compliance profile or checklist is completed before the agency is added to the approved agency list. For each agency worker supplied, the service must obtain either a completed agency worker profile or written confirmation from the agency that all required checks have been completed and are satisfactory before the worker starts their shift.

Where there is any doubt about a worker’s identity, DBS status, right to work, professional registration, competence, training or suitability, the worker must not start work until the concern has been resolved and documented.

4.3 Agency Agreement and Approved Agency List

Each approved agency must have a current agreement, service level agreement or written terms of engagement with {{org_field_name}}. The agreement must clearly set out the responsibilities of the agency and the service, including:

• the checks and evidence required before any worker is supplied;
• the requirement for the agency to provide a worker profile before the shift starts;
• arrangements for confirming identity on arrival;
• arrangements for reporting safeguarding concerns, incidents, complaints, poor performance, misconduct or professional concerns;
• expectations for confidentiality, data protection and information security;
• requirements for role-specific training and assessed competence;
• arrangements for medication duties, including confirmation that no agency worker will administer or support medicines unless this has been specifically authorised and competence has been verified;
• responsibility for informing the service immediately if a worker’s DBS status, right to work, professional registration, training, conduct or fitness to work changes;
• arrangements for sharing feedback and learning;
• insurance and indemnity arrangements;
• compliance with the Agency Workers Regulations 2010.

The Registered Manager will maintain an approved agency list. Agencies will be reviewed at least annually, or earlier where concerns arise. Any agency that repeatedly fails to provide suitable, competent, punctual, properly checked or safe workers may be suspended or removed from the approved agency list.

4.4 Checks Before Each Shift

Before an agency worker starts each shift, the nurse in charge, senior carer, shift leader or delegated senior must:

• confirm the worker’s identity against photographic identification;
• confirm that the worker is the person named on the agency profile or booking confirmation;
• check that the role, shift time and duties match the booking;
• confirm that all required agency assurances have been received;
• confirm any restrictions on duties, including medication, moving and handling, lone working, complex care or clinical tasks;
• provide a local handover and allocate a named supervisor;
• ensure the worker signs in and out of the service;
• record any immediate concerns and escalate them to the Registered Manager or on-call manager.

If the worker cannot provide satisfactory identification, or if the service has not received the required assurance from the agency, the worker must not commence duty.

4.5 Induction and Orientation of Agency Staff

All agency staff must receive a localised induction before starting work. The induction must be proportionate to the role, the length of booking, the worker’s familiarity with the service and the level of risk attached to the duties being undertaken.

The induction must include, as applicable:

• introduction to the person in charge, the team and the worker’s named supervisor;
• fire procedures, evacuation arrangements and personal emergency evacuation plans;
• emergency call bell systems, nurse call systems and escalation arrangements;
• safeguarding adults procedures, including how to report abuse, neglect, discrimination, closed cultures, poor practice or whistleblowing concerns;
• infection prevention and control arrangements, including PPE, hand hygiene, outbreak procedures and waste disposal;
• confidentiality, UK GDPR and secure handling of personal information;
• incident, accident, near miss and concern reporting;
• medicines procedures and clear confirmation of whether the worker is authorised to support or administer medicines;
• moving and handling arrangements, equipment safety and individual moving and handling plans;
• nutrition, hydration, choking risks, modified diets and food allergy information where relevant;
• mental capacity, consent, deprivation of liberty safeguards and restrictive practice escalation where relevant;
• the needs, preferences, communication requirements and risks of people the worker will support;
• equality, dignity, privacy, cultural needs and person-centred care expectations;
• visiting arrangements and how to support people to maintain relationships with family, friends and representatives;
• end-of-life care needs where relevant;
• how to access policies, care plans, risk assessments and emergency contacts.

Agency workers must confirm that they understand the induction and must sign the agency induction record before commencing care or support duties. No agency worker may provide care, support, nursing care, medicines support or other regulated activity until the induction, identity check and required agency assurances have been completed.

4.6 Learning Disability and Autism Training

{{org_field_name}} will ensure that agency staff working for the purpose of the regulated activity have received learning disability and autism training appropriate to their role. The agency must provide assurance that the worker has completed suitable training, or the service must ensure that the worker receives appropriate information, guidance and supervision before undertaking duties.

Where an agency worker is supporting a person with a learning disability or an autistic person, the person in charge must ensure that the worker receives specific handover information about the person’s communication needs, sensory needs, reasonable adjustments, distress triggers, preferred support, health inequalities, risks and care plan guidance.

Agency staff must not be allocated to support people with complex learning disability, autism, communication or sensory needs unless the Registered Manager or delegated senior is satisfied that the worker has the necessary competence, confidence and supervision to provide safe, person-centred care.

4.7 Supervision and Oversight

Agency staff will be supervised according to their role, experience, familiarity with the service, competence, duties and the needs and risks of the people they support. A named senior member of staff will be responsible for overseeing agency workers on each shift.

Agency workers must not be allocated to lone working, medication administration, nursing tasks, complex moving and handling, complex behavioural support, end-of-life care, one-to-one observations, community access or any high-risk task unless their competence has been verified and the Registered Manager, nurse in charge or delegated senior has authorised this.

The person in charge of the shift must complete proportionate checks during the shift to confirm that agency staff:

• follow care plans and risk assessments;
• communicate respectfully and effectively with people;
• maintain dignity, privacy and choice;
• follow infection prevention and control procedures;
• report concerns, incidents or changes in people’s needs promptly;
• document care accurately and promptly where this is part of their role;
• work within their competence and do not undertake unauthorised tasks.

Any concern about competence, conduct, attitude, punctuality, documentation, safeguarding, confidentiality or safety must be recorded and escalated to the Registered Manager or on-call manager. The agency must be informed promptly, and the worker may be removed from duty where this is necessary to protect people from risk of harm.

4.8 Medicines, Nursing and High-Risk Tasks

Agency staff must only administer, prompt, support or record medicines where this has been specifically authorised by the Registered Manager, nurse in charge or delegated senior and where evidence of current training and assessed competence has been received. Agency staff must follow the service’s Medicines Management Policy, the person’s care plan, MAR chart and any medicines risk assessment.

Agency nurses must provide evidence of current professional registration and must work within the NMC Code and their own competence. The service will confirm any restrictions, supervision needs or local procedures before the nurse undertakes nursing duties.

Agency care staff must not undertake nursing tasks, delegated healthcare tasks, catheter care, wound care, diabetes care, controlled drug procedures, covert medicines support, thickened fluids, modified diet support or other specialist tasks unless the service has confirmed that the task is within their role, training and competence, and that the person’s care plan authorises the support.

4.9 Person-Centred and Safe Care Delivery

All care delivered by agency staff must align with the individual’s care plan and risk assessments. Temporary staff are provided with a handover sheet detailing the needs, preferences, and risks of each person they support. They are expected to respect the dignity, choice, and independence of individuals at all times, in accordance with Regulation 9 (Person-centred care) and Regulation 10 (Dignity and Respect).

Agency staff must also follow the service’s procedures on consent, mental capacity, deprivation of liberty safeguards, equality, diversity and human rights. They must not assume consent, apply restrictions, use restraint, change care routines, alter diet or fluid arrangements, or provide care in a way that is contrary to the person’s care plan unless this has been authorised by the person in charge and is necessary to prevent immediate harm.

Reasonable adjustments must be made where a person has communication needs, sensory needs, cognitive impairment, dementia, a learning disability, autism, mental health needs or any protected characteristic. Agency workers must be given enough information to communicate effectively and provide care in a way that is respectful, lawful and person-centred. Where communication barriers exist, support is provided to ensure understanding of how to deliver care safely and appropriately.

4.10 Safeguarding, Whistleblowing and Closed Cultures

Agency staff have the same responsibility as permanent staff to report safeguarding concerns, poor practice, abuse, neglect, discrimination, degrading treatment, unexplained injuries, medication errors, unsafe staffing, closed cultures or any conduct that places people at risk of harm.

Safeguarding concerns involving agency staff must be acted upon immediately in line with the Safeguarding Adults from Abuse and Improper Treatment Policy. The Registered Manager or delegated senior must consider whether to:

• protect the person from immediate risk;
• remove the agency worker from duty;
• notify the agency;
• report the concern to the local authority safeguarding team;
• notify CQC where the notification threshold is met;
• notify the police where a criminal offence may have occurred;
• make or request a DBS barring referral where the legal criteria are met;
• record actions, decisions and outcomes clearly.

Agency staff must be informed that they can raise concerns directly with the person in charge, Registered Manager, provider, local authority safeguarding team, CQC or other appropriate external body.

4.11 Feedback, Complaints and Performance Management
Any concern, complaint or compliment relating to agency staff must be recorded and reviewed. Feedback may be obtained from people using the service, relatives, representatives, visiting professionals, permanent staff and managers.

Concerns about an agency worker’s conduct, competence, attitude, punctuality, documentation, confidentiality, safeguarding practice, medicines practice, infection prevention and control, moving and handling, communication or person-centred care must be reported immediately to the person in charge and escalated to the Registered Manager or on-call manager.

The Registered Manager or delegated senior will decide whether the worker can safely continue the shift, requires closer supervision, must be moved to lower-risk duties, or must be removed from duty. Where a worker is removed from duty, the agency must be informed promptly and the reason must be documented.

Where concerns may amount to abuse, neglect, professional misconduct, unsafe practice, a criminal offence or a risk of harm, the Registered Manager must consider safeguarding referral, CQC notification, police referral, professional regulator referral and DBS barring referral in line with legal and local safeguarding requirements.

Repeated concerns about a worker or agency must be reviewed as part of governance monitoring. Persistent failure by an agency to provide suitable, competent, safe or properly checked workers will result in suspension or removal from the approved agency list.

4.12 Compliance Monitoring and Governance

The use of agency staff will be monitored through the service’s governance and quality assurance systems. The Registered Manager will review agency use at least monthly, or more frequently where agency use is high, risks have increased or concerns have been identified.

Monitoring records will include:

• number of agency shifts used;
• reasons for agency use;
• agency name and worker name;
• role and shift worked;
• whether the worker was new or familiar with the service;
• confirmation that pre-shift checks and induction were completed;
• any restrictions on duties;
• incidents, accidents, safeguarding concerns, complaints or compliments involving agency staff;
• feedback from people, relatives, staff and professionals;
• spot checks and supervision findings;
• impact on continuity of care;
• impact on people’s outcomes, dignity, safety and experience;
• actions taken to reduce avoidable agency dependency.

Agency staffing data will be used to identify themes, risks and learning. Where monitoring identifies unsafe staffing, excessive agency reliance, lack of continuity, poor agency performance or increased incidents, the Registered Manager must complete an action plan. This may include recruitment activity, rota review, dependency analysis, additional supervision, agency suspension, increased permanent staffing or escalation to the provider.

Agency staff records, agency due diligence records, induction records, feedback, incident records and approved agency reviews must be available for audit and CQC inspection.

4.13 Record Keeping and Schedule 3 Evidence

{{org_field_name}} must be able to demonstrate that agency workers supplied to the service are fit and proper for the role they perform. The service will keep an agency staffing file or electronic record containing:

• approved agency due diligence checks;
• agency agreements or terms of engagement;
• agency insurance evidence;
• agency worker profiles or compliance confirmations;
• identity checks completed on arrival;
• induction records;
• training and competence assurances;
• professional registration checks where applicable;
• supervision, spot check and feedback records;
• incident, complaint, safeguarding and performance records;
• evidence of action taken where concerns are identified.

Records must be accurate, up to date, securely stored and accessible to authorised managers and inspectors where required. Personal information must be processed in line with UK GDPR, the Data Protection Act 2018 and the service’s confidentiality and data protection policies.

4.14 Confidentiality and Data Protection

Agency staff are required to sign confidentiality declarations and follow all requirements under the UK GDPR and our CH34 Confidentiality and Data Protection Policy. They are made aware of their responsibility to report data breaches or security concerns and only access information relevant to the care they are providing.

Agency staff must only access information that is necessary for the safe delivery of their allocated duties. Where electronic care planning, medication or record systems are used, access must be role-based, time-limited where possible, and removed when the booking ends. Agency staff must not use personal devices to photograph, record, store or share information about people using the service, staff or the organisation unless this has been expressly authorised for a lawful care purpose and in line with policy.

Any suspected or actual data breach involving agency staff must be reported immediately to the person in charge and managed in line with the service’s data breach procedure.

4.15 Right to Work and Immigration Compliance

The agency is responsible for carrying out right to work checks for workers it employs or supplies. However, {{org_field_name}} must obtain written assurance from the agency that each worker supplied has the right to work in the UK and is permitted to undertake the duties for which they are supplied.

Where {{org_field_name}} has any reason to doubt a worker’s right to work, identity, documentation, employment status or permitted duties, the worker must not commence duty until the concern has been resolved. Any concerns must be escalated to the Registered Manager or provider.

4.16 Equality, Diversity and Fair Treatment of Agency Workers

Agency staff will be treated fairly, respectfully and without discrimination. The service will make reasonable adjustments where required and where this does not compromise the safety of people using the service. Concerns about an agency worker’s performance or conduct must be managed fairly, factually and without discrimination.

Agency workers must also treat people using the service, relatives, staff and professionals with dignity, respect and fairness. Discrimination, harassment, bullying, victimisation or disrespectful conduct by agency staff will not be tolerated and will be reported to the agency and managed in line with safeguarding, disciplinary, complaints or regulatory procedures as appropriate.

4.17 Business Continuity and Emergency Staffing

Where agency staff are required due to emergency staffing pressures, outbreak, severe weather, unexpected absence, evacuation, major incident or other business continuity event, the Registered Manager or delegated senior must ensure that staffing decisions remain safe, proportionate and based on people’s needs.

Emergency use of agency staff must not remove the requirement for identity checks, agency assurance, local induction, supervision and safe allocation of duties. Where full assurance cannot be obtained immediately, the agency worker must only be allocated low-risk duties under close supervision until all required checks are confirmed.

5. Policy Review

This policy will be reviewed at least annually, or earlier where required due to:

• changes in legislation, statutory guidance or CQC guidance;
• changes to the CQC assessment framework or quality statements;
• safeguarding concerns, incidents, complaints or lessons learnt involving agency staff;
• repeated concerns about an agency or agency worker;
• changes in workforce risks, dependency levels or agency usage;
• audit findings or feedback from people using the service, relatives, staff, professionals or commissioners.

All relevant staff will be informed of changes to this policy. Additional briefing, supervision or training will be provided where changes affect staff responsibilities, agency booking, induction, supervision, safeguarding, medicines, governance or record keeping.

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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}}
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