Amendment to rules relating to lapse of registration

Between 19th May and 29th June 2017, UKPHR consulted on a proposed amendment to its rules on lapse of registration and restoration to the register.

The single point at issue in the amendment and the consultation was whether UKPHR should in future notify registrants’ employers when registration becomes lapsed by more than 15 working days.

There were 14 responses to the consultation, of which 13 answered the key question whether UKPHR should in future notify registrants’ employers when registration becomes lapsed as follows:

            Strongly agree                        1

            Agree                                      7

            Neither agree nor disagree     1

            Disagree                                  3

            Strongly disagree                    1

Helpful additional comments made by respondents in response to this consultation question included:

• The registration is fundamentally about public protection. If lapsed the employer may find themselves in trouble if the registrant is involved in a challenging situation, that may lead to any forms of public scrutiny.

• I see no reason why this should not happen although I do think this should only happen after 15 days. I don’t think employers need to be informed when a lapse under 15 days is simply down to administrative error or the registrant.

• This undermines the ‘professional’ status of registrants i.e. a person who is able to manage their own work arrangements. Additionally, this registration is voluntary, not statutory therefore is appears to be an unnecessary step, which may be off putting for some, given that many people working in public health are not registered at all. understanding registration body, not a regulatory one.

• Yes, this way the employer is informed of the situation and can offer support as applicable to ensure restoration of registration.

Asked if they agreed that no other changes to the lapse and restoration policies were required, 2 respondents neither agreed nor disagreed, 6 respondents agreed and 6 respondents disagreed, with two respondents suggesting an option to suspend registration without penalty for a voluntary suspension of practice or career break, perhaps subject to revalidation for re-entry.

Asked what, if anything, UKPHR should do if the registrant whose registration has lapsed has no employer or UKPHR does not have a record of an employer, the following comments were provided by respondents:

• It might be useful to remind them that if they are still working in PH fields then registration not only helps them in getting work but also may protect them in case of any work leading to an external review.

• Voluntary suspension if not working or seeking work should be permitted without penalty.

• I don’t think there is any action UKPHR can take if there is no recorded employer.

At its meeting on 18th July 2017, The Board approved the proposed amendment. This means that in future UKPHR will notify a known employer of a registrant in employment if the registrant’s registration were to become lapsed, and not restored under the existing “slip rule” within 15 working days.

To read the 2nd edition of our lapsed policy, click here.