Short-notice cover is when checks are most likely to slip. CQC is clear that practices must only engage people who are fit for the role, and that this applies to temporary staff as well as permanent staff.
This guide sets out what to confirm before a locum GP’s first session and how to keep a record you can produce at an inspection. It is not legal advice, and your practice’s own recruitment policy still applies.
Start with the four checks CQC names
CQC’s guidance on GP locums says the practice is responsible for checking four things before the locum works. Record who checked each one and on what date.
- The locum is a GP.
- They are registered with the GMC.
- They are on the performers list.
- They have professional indemnity.
Sources: CQC: GP mythbuster 50, GP locums
Check the GMC register and the performers list yourself
Use the GMC’s online register to confirm registration, a licence to practise and an entry on the GP Register. Note any conditions or undertakings and whether they affect the work you are booking.
In England, search the National Performers List. Wales, Scotland and Northern Ireland have their own lists, so check the one for the country where the work takes place. A number written on a CV is not a completed check: look it up and record the date.
Sources: GMC: the GP Register · NHS England: Performers List search
Confirm indemnity for the work you are booking
In England, the Clinical Negligence Scheme for General Practice (CNSGP), run by NHS Resolution, covers clinical negligence in NHS general practice for incidents on or after 1 April 2019. It extends to GPs, including locums, carrying out that work.
CQC notes that the scheme does not cover activities outside the NHS contract. If the booking includes anything else, ask the locum to confirm their own indemnity for it. Wales has a separate state scheme, so check the arrangement for your country.
Sources: NHS Resolution: Clinical Negligence Scheme for General Practice · CQC: GP mythbuster 50, GP locums
Make the Schedule 3 information available
CQC’s Regulation 19 (fit and proper persons employed) applies to locums. Schedule 3 lists the information a practice must be able to make available, including:
- proof of identity with a recent photograph
- evidence of conduct in previous health or social care work
- documentary evidence of relevant qualifications
- a full employment history, with a written explanation of any gaps
Sources: CQC: GP mythbuster 50, GP locums
Booking through an agency does not remove your responsibility
CQC says a practice using an agency must decide how far it can rely on the agency’s checks. That depends on your agreement with the agency and how it would provide the Schedule 3 information if asked. You must be confident the agency holds the documents, and you can ask to see copies before accepting a locum.
Ask the agency in writing which checks it has completed, when, and how you would get the evidence during an inspection. If you book through FindALocum, agree in writing which checks each side completes before the first session. Receiving a CV or a registration number is not a completed check.
Sources: CQC: GP mythbuster 50, GP locums
Keep a record you can find during an inspection
Use the free record template: one copy per locum, showing what was checked, by whom, when, where the evidence is held and when it is next due. Store the evidence securely under your practice’s data protection policy. Email threads are not a safe place for it.
Registration and performers-list status can change between bookings. Set a re-check point in your policy, for example before each new block of sessions, and record the date each time.
Common questions
Can we rely on the agency’s checks?
Partly, depending on your agreement with the agency. CQC expects you to be assured that the checks have been done, by you or the agency, and that the information can be produced if asked.
How often should we re-check a regular locum?
Your recruitment policy should say. Registration and performers-list status can change, so set a re-check point, such as before each new block of sessions, and record the date.
What if a check is still outstanding on the day?
Do not start work that depends on it. Decide in advance who can authorise a delay and how affected appointments will be handled.
Official sources
Sources checked . Requirements can differ by country, employer and role; use the current guidance relevant to the work.
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