Our response to COVID-19 (Coronavirus)

22 April 2020

At UKPHR, our number one priority is the protection of the public. During this time of great public health concern, it is more important than ever that we remain committed to ensuring compliance with all our regulatory requirements.

Here at the register, we are proud of all for the work our registrants are doing to keep communities safe. 

We understand that all our registrants are currently working flat out to contain and/or slow the spread of the virus and to advise, guide and reassure the public, so we are doing all we can to ensure that meeting these registration requirements does not interfere with their vital work.

We appreciate the tremendous impact that the current situation is having on all our registrants and we will do whatever it takes to support them in terms of relaxing our regulatory requirements during this crisis.

Our response will continue to be reviewed as the situation develops, our current position on key matters is as follows:

We have written to all UKPHR registrants, however if you have any further questions, please email us at register@ukphr.org

“The times we are in are unprecedented. Together we will, with determination, goodwill and invention, overcome the threats and rise to future challenges.”

Your work is more important now than ever before. We will do whatever it takes to ensure that your response to this crisis is not hindered by our regulatory requirements.

We have already outlined our position on CPD as being broadly in line with that taken by the FPH, however given the tremendous speed with which this situation is developing, we want to give all our registrants further clarification on this matter.

All registrants are immediately released from their obligation to fulfil any CPD requirements between March and September 2020, in the first instance.

We will review this position in the summer, with a view to extending the exemption period if the COVID-19 crisis continues.

When we are clearer about the duration of the emergency, we will notify registrants of the amended figures for the CPD hours they will need to demonstrate for annual renewal, re-registration, professional appraisal and revalidation.

For any CPD undertaken between April 2019 and March 2021, we will accept self-certification of hours completed in lieu of a certificate of completion from FPH. A self-declaration form will be provided for those who need it.

As always, our priority during this crisis remains protecting the safety of the public. We hope that our position on CPD strikes a fair balance between upholding the standards of public health practice while facilitating the vital work of all our registrants during this difficult time.

Statutory regulators are likely to soon be accepting recently retired health professionals back onto their registers, to help with the fight against the virus. UKPHR is introducing its own emergency rule to allow the Registrar to do the same for retired public health professionals. We are emailing former registrants who may be affected.

Anyone currently applying for specialist registration by portfolio assessment can contact us directly to put the process on hold without penalty.

We are as grateful as ever for all those who take on volunteer roles as assessors, verifiers and mentors. Those affected should contact us directly to discuss how we can help manage and postpone (where necessary) their valuable contribution to our registration processes.

As you would expect, we have now moved to home working at the register. Our website is operating normally, and we remain active on Twitter. Please use email as the preferred and most reliable means of communication: we are monitoring emails to all inboxes every day.

We are not in the office, so telephone calls and mail sent to the office will not reach us. If you need to make an urgent call to us, please call David Kidney on: mobile 07966 378844. If you need to post something to UKPHR, please email us first to check where to mail it to.

We operate a policy of equivalence, so far as possible, with the General Medical Council (GMC) in relation to professional appraisal and this will continue.

In line with the guidance from NHSE, and in response from requests from registrants engaged in the fight against COVID-19 throughout the UK, we have decided that the requirement to undertake an annual professional appraisal is suspended for the months of April to September 2020 inclusive. Appraisals due to be completed during these months will count as “approved missed appraisals”.

The GMC has stated that all doctors due to revalidate over the next six months will have their revalidation deferred for one year and we have stated that we will do the same.  This means that revalidation dates falling within the period April – September will be put back until next year.

For revalidations due in October or later, we are maintaining these revalidation dates for the time being. We will review the situation in the summer when hopefully we will be clearer about the duration of the current crisis.

We will make the same arrangements for five-yearly re-registration of practitioner registrants.

We ask that no-one initiates a 360-degree colleague feedback exercise at this time.  The exercise can be run once the appraisal system has returned to normal.

Currently, practitioner registrants undergo re-registration once every five years.

Just as we have decided that all specialists due to revalidate over the next six months will have their revalidation deferred for one year, we will treat practitioners due for re-registration over the next six months the same.  This means that re-registration dates falling within the period April – September will be put back until next year.

For re-registrations due in October or later, we propose to maintain these re-registration dates for the time being. We will review the situation in the summer when hopefully we will be clearer about the duration of the current crisis.

Other issues are being raised about aspects of practitioner registration, especially about practitioners who are currently preparing their portfolios for assessment and the processes around assessment and verification. We will discuss these with scheme coordinators next month (Wednesday 08 April) and make further announcements afterwards.

The work of the public health profession is more important now than ever before. We are doing all we can to ensure that practitioners and local practitioner registration schemes can respond to the COVID-19 emergency without being hindered by our regulatory requirements.

As a result of concerns expressed to us by scheme coordinators, and after consulting with out team of Moderators, we recognise that we can and we must respond to the challenges facing practitioner registration due to COVID-19.

UKPHR has agreed to make the following reasonable responses to this exceptional situation:

  • Verifiers

Verifiers perform a key role in verifying assessments of practitioners’ portfolios. They are senior public health professionals and due to responding to COVID-19, they currently have limited to no time available to verify portfolio assessments.

UKPHR has designated some Moderators to be verifiers while others continue to fulfil their Moderator role. If a scheme does not have access to a verifier, the designated verifiers will be made available. The Moderators who offer the verification service will seek to recruit existing verifiers and retired verifiers to help them and augment their number.  If required, UKPHR will also help coordinators to arrange quorate Verification Panel meetings. This alternative arrangement for verification is only on offer for the duration of the COVID-19 emergency.

  • Currency of evidence

Some practitioners are experiencing longer than anticipated waits for verification, with the risk that evidence that was assessed as meeting the currency rule will become out of date. In addition, some practitioners have paused work on their portfolio and some schemes have paused their current cohorts. Again there is risk that evidence that would have met the currency requirement will become out of date.

There are currently two sets of currency rules; one for the original standards and another for the amended standards. It has been agreed that both sets will be amended by adding a period of 7 months to the 3-year and 5-year time limits respectively. The length of these extensions will be revisited later this year if the current emergency continues for longer than envisaged.

Whilst the time limits for the currency of evidence have been changed, this does not affect the roles of verifiers, Verification Panels and Moderators in checking that the appropriate currency rule has been properly applied and assessed in any individual portfolio. In other words, normal QA standards continue to apply.

Practitioners continuing towards registration under the original practitioner standards have previously been allocated a time limit of 2 years to complete their registration. This time limit has been amended to 2 years and 7 months.

All of us at the register thank all of you who work in the devolved arrangements for practitioner registration for your tireless and selfless work. The practitioners joining our register must be assured to have the competence to undertake public health practice safely. This has never been so compelling as now during this COVID-19 emergency. Colleagues are working flat out to save lives, protect the NHS and address health and wellbeing issues that are caused or exacerbated by the restrictions that are in place to stem the flow of infections. Thank you for playing your part.