Pre-employment Checks and Vetting

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Identity checks? Right to work? Criminal records? Health? Have your employees undergone the necessary pre-employment checks?

Pre-employment checks for job applicants

What are the CQC looking for when it comes to pre-employment checks?

Before and as part of any inspection, the CQC will request copies of documents and examples of information that will give them advance insight into how well you meet the CQC standards. On top of the list of HR information will be your recruitment and training policies and procedures, including how staff are recruited and vetted before commencing work.

All NHS providers must have in place procedures for undertaking necessary and appropriate pre-employment checks on staff before they commence employment. You must demonstrate that you comply with the requirements of the CQC fundamental standards and relevant legislation.

The 6 key pre-employment checks are

  • Identity – to verify the identity of an applicant/employee
  • Right to work – to check their legal right to work in the UK
  • Work health assessments
  • Employment history and reference checks – for seeking references and verifying employment history and/or training in the NHS
  • Criminal record and barring check – when appointing staff into eligible positions under the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975.
  • Professional registration and qualification checks – specifically for healthcare professionals
  • Social media vetting

Pre-employment checks seek to verify that applicants meet the preconditions of employment. Reviews are most effective if they form an integral part of your policies, practices and procedures for the recruitment, hiring, and, where necessary, training of employees. The level and degree of checks carried out should be proportionate to the potential risk the post at hand may pose.

Particularly relevant for criminal record and barring checks, you must ensure you comply with the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 to provide risk assessment. Meaning that you may apply various levels of DBS checking to different roles.

Ensure your recruitment policies cover

  • Your pre-employment checks process
  • How you assess each role for risk
  • Which roles particular checks apply to
  • How you deal with exceptions
  • Who has authority for making decisions on, for example, a positive disclosure on a criminal record check or a health issue
  • How and when pre-employment checks will be undertaken
  • How this will be communicated to applicants and employees
  • How you will deal with queries or concerns arising from the checks

Temporary workers and contractors

Your policies must state how you ensure that temporary workers or contractors have undergone and comply with the relevant pre-employment checks.

While you will have processes in place that seek assurances from the third party employment agency or employer, you have overarching responsibility for auditing and monitoring all providers you choose to use. You must ensure that they operate to the same level of standards concerning undertaking employment checks.

Updating policies

Pre-employment checks may be referred to in a number of different HR policies and procedures, for example:

  • Recruitment and selection
  • Employing temporary workers
  • Professional registration
  • Secondment
  • Handling DBS disclosures
  • Data protection (employee records)
  • Recruitment of ex-offenders
  • Equality and diversity
  • Capability (in relation to health)
  • Disciplinary

Where you have multiple policies, do ensure that they all concur. Likewise, check that all documents and forms are up to date and legally compliant, for example, employment application forms, health questionnaires, reference requests, etc.

As you know, the CQC publishes guidance on what providers need to do to meet the regulations. The CQC provides detailed guides on the key lines of enquiry, prompts and rating characteristics for healthcare services.

HR management, training and development cut across all aspects of the CQC standards. As HR professionals in the primary care sector, our approach is to provide practical advice that you can act on.

Over the coming months, we’ll be sharing more advice on ensuring your HR practice, policies, and procedures are CQC compliant concerning Regulations 18 and 19.

To ensure you are CQC compliant, please contact us.