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CRB Checks for Dental Practices
Since registration with the Care Quality Commission came into effect on the 1st April 2011 for primary dental services in England which carry out regulated activities, there has been some confusion over who needs to hold an enhanced CRB check. Some of this is due to an earlier lack of clarity from the regulator and the process is still less than transparent in one particular respect.
As part of the registration process the CQC recognises that some employees of a Dental Practice must have a CRB check carried out, whilst others may need one, but it has been suggested that this is primarily down to the practice itself to decide if this is or is not strictly necessary. CRB checks can take two forms: Enhanced and Standard. The primary distinction is that a Standard CRB check will not reveal if an employee is registered with the Independent Safeguarding Authority (ISA) or if they are barred from working with children or vulnerable adults.
This is an important distinction, as the Vetting and Barring Scheme (formerly the POVA scheme - Protection of Vulnerable Adults) which applied to the adult social care sector, lists those care professionals who should not be working with vulnerable adults. Sadly the future of this scheme is in doubt following a review from the Coalition Government, but the essential element of being ISA registered still stands and applies directly to primary dental services. Questions need to be asked within the practice about whether it would therefore be wise to carry out an Enhanced CRB check for certain employees, even where there is no specific requirement from the CQC to do this, as the employee(s) are likely to come into contact with children and/or vulnerable adults. The question should not really be one of cost, but one of responsibility and good practice ethics. The enhanced CRB check will contain pertinent and proportionate information held by local police forces and also a check of the Children and/or Vulnerable Adults barred lists upon request.
So who is actually required to have an enhanced CRB check? Well there are three categories of employee/owners who must have an enhanced CRB check:
- Nominated Individuals;
- Registered Managers;
Much discussion has been held about considering all other employees on a case-by-case basis. We have spoken to the CQC who confirmed that all employees within a dental practice should have an Enhanced CRB check carried out, including reception staff. This is at odds with advice seemingly provided to other organisations. You need to therefore consider the risks present to the public in not carrying out an Enhanced CRB check for other dental professionals and employees, e.g. hygienists, therapists, dental nurses, reception staff etc. The CQC do state on their website that they feel that “most people employed to work in a health or social care service” should have a CRB check carried out. This may not exactly be clear guidance, so it is our strong recommendation that when considering the need for such a check on a case-by-case basis, you should err on the side of caution and get one completed. If there is doubt about a particular situation, then you should contact the CQC for further guidance.
Obtaining a CRB check is relatively straightforward, if a little time consuming, but full details can be found by clicking here.
When completing your CRB check, it is worth remembering that the only application forms to go direct to the CQC are those for the Nominated Individual, Registered Managers and Partners. Anyone else needs to apply through an umbrella company, for example through a Dental Recruitment Agency. If you send them direct to the CQC, then it may just be returned to you.
CRB checking is just one aspect of the registration criteria, it is a daunting task to understand all of the CQC regulatory requirements, which is why Quality Compliance Systems Ltd provide all the policies and procedures you could possibly need in order to achieve and maintain CQC compliance.