The CQC has issued interim guidance in response to temporary changes being made by the Disclosure and Barring Service (DBS) to DBS applications and processes. It will be in operation for the period the Coronavirus Act 2020 remains in force. We will review it on a regular basis.
This guidance applies to individuals (paid staff and volunteers) being recruited as a consequence of and during the coronavirus pandemic, and where the following three things apply:
- providers need to start staff urgently
- waiting for a full DBS check could cause undue delay
- this delay could lead to risks to the continuity of service, impacting the safety and wellbeing of people using the service.
Providers are offered a fast, free Barred List DBS check for emergency roles being recruited in response to a provider risk assessment. Enhanced DBS check information will still be processed, but will be issued afterwards.
The barred list check applies to staff working with children and adults.
Providers should exercise diligence around all aspects of safe recruitment, including other recruitment checks they might carry out. Providers are responsible for risk assessing their situation and making decisions based on the needs of their service and people using that service during this emergency.
If providers take reasonable steps to ensure new staff are recruited in line with new DBS guidance, staff are adequately supported and sufficiently supervised so that people are safe, the CQC will not take a punitive approach. Providers should record the decisions they have made, and any risks identified along with the mitigations they will put in place. For example, providers might consider accepting a relevant DBS check from a previous employer provided it is less than three years old and for a similar role.
The CQC takes a pragmatic view on the portability of certificates for those being employed in emergency roles, recognising that some providers may have to consider this as part of their risk assessment.
All other appointments and applications for DBS checks that are not linked to coronavirus must be processed according to existing DBS and CQC guidance.