GMC register checks for locum doctors: a recruiter’s guide

Recruiters: GMC register checks for locum doctors: a recruiter's guide

A locum registrar can look perfect on paper and still be unable to work on the Monday you have booked them. The licence lapsed because a card payment failed, or the entry now carries a condition the doctor did not mention. A GMC register check takes two minutes and catches both, but only if you know which parts of the entry to read and you look again before each new booking.

This guide is for the recruiter or compliance lead at an agency placing locum doctors, from foundation doctors to consultants. Most of it applies whether you place one locum a month or forty.

Search by GMC number, not by name

The General Medical Council publishes the medical register on its website and anyone can search it free. Ask the doctor for their GMC reference number and search with that. A name search will return several doctors with the same surname, and the GMC itself tells employers to check that the number they were given matches the details on the register. Then confirm the person in front of you is the person on the entry by checking photo ID at the same time.

Save the result with the date and time showing. That record is what you show a client, or an auditor, when they ask how you knew the doctor was cleared on the day.

What a GMC register check actually tells you

The entry is short. Each line answers a question a client will ask you.

Registration status tells you whether the doctor is registered with a licence to practise. Registration without a licence is not enough. A doctor who has given up their licence can stay on the register, but they cannot practise medicine in the UK, and that includes a single locum shift.

The GP Register and Specialist Register lines say yes or no. The GMC says a doctor working as a GP in the UK health service must be on the GP Register and on the relevant performers list, which is a separate check we cover in our guide to hiring a locum GP. For a consultant post in the health service, the doctor must be on the Specialist Register. A registrar who is a few months from completing training is not, and should not be booked as a consultant however experienced they are.

Provisional registration is the one to watch with newly qualified doctors. A provisionally registered doctor can only work in an approved foundation year one post, so they cannot take agency locum work at all. Check the full registration date if the doctor graduated recently.

The entry also shows the registered qualification, the dates of provisional and full registration, and a registration history. Gaps in that history are worth a question at interview.

Conditions, warnings and restrictions

If the GMC has placed conditions, a warning or another restriction on a doctor, it shows on the register. The GMC’s guidance to employers is to check for these and make sure the registration allows the doctor to do the job you are offering.

A condition does not always stop a booking. A doctor may be allowed to work only under supervision, or not in a particular type of post. What matters is whether the client’s role fits inside it, and that is a decision for the client with full information, not one an agency makes quietly. Send the client the condition word for word before the doctor is confirmed, and keep the email.

Revalidation, the designated body and the responsible officer

Every licensed doctor revalidates, normally every five years, based on annual appraisals. The register shows each doctor’s designated body and their responsible officer, the senior doctor who makes the revalidation recommendation.

For locums this is where things get messy. Some locum agencies are designated bodies themselves under the Medical Profession (Responsible Officers) Regulations, as amended in 2013, and must appoint a responsible officer for the doctors connected to them. Others are not. Either way, find out who the doctor’s responsible officer is. The GMC points out that the responsible officer can give evidence for the doctor’s whole practice appraisal, and a doctor with no connection at all is a doctor whose revalidation may be at risk.

Why a check from last month is not enough

Doctors come off the register for plain administrative reasons. The GMC lists the common ones as not paying the annual retention fee and not keeping their address up to date. The register shows the date the next annual retention fee is due, so put it in your diary for every doctor you place and check the entry again in the week after.

A doctor who has been erased must not work until they are restored, even if a shift is already booked and the ward is short. The GMC asks doctors in that position to contact it urgently to apply for restoration. The practical answer for an agency is to check the register before each new assignment and at least monthly for doctors on long placements. Agencies with access can use the GMC’s medical register download service rather than searching one by one.

The GMC will also tell an organisation that employs or contracts with a doctor when it opens a fitness to practise investigation. If you raise a concern yourself, the GMC’s professional standards on raising concerns apply.

The rest of the file

The register check is one part of a wider set of checks. The GMC expects employers to satisfy themselves that a doctor’s English is good enough for the role, and refers them to the NHS Employers check standards, including the professional registration and qualification checks standard, for the rest. Where a doctor will work with patients who are vulnerable, regulation 20 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003 also requires the agency to obtain copies of relevant qualifications and two references, and to take all reasonable steps to confirm the doctor is suitable.

Right to work, an enhanced DBS check (we explain the DBS Update Service separately) and occupational health clearance sit alongside these. If you also place nurses, the same habits apply to NMC register checks.

Flamingo Workforce places locum doctors from foundation level to consultant across the UK, with the register check repeated before every booking. If you need cover, send us the details through our enquiry form.

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