Introduction
Patient registration is determined by legislation and the provisions of the practice GMS or PMS contract and terms of service.
Where a practice has an “open list” it is required to accept the registration of a new patient unless it has fair and reasonable grounds for not doing so. Where a list is open, the practice is also obliged to accept allocations by the ICB to its list.
Practices are assumed to have open lists unless they have complied with the procedures for list closure as detailed in the General Medical Services Contracts Regulations 2004 (Schedule 6, Part 2, paragraphs 29 to 31), see resources below.
Access to registration
To ensure there is equitable access for all patients who wish to register with us, registration should be available to all patients every day during our advertised opening hours.
To ease pressure we will let patients know the less busy times of the day when registration might be easier. This information will be included in our practice leaflet, in the reception area and on our website.
In addition to this pre-registration documentation will be available to download and complete prior to a patient attending to register in person.
Patients have the right to change practices if they wish. If a patient is registered at another local practice this is not a reason to refuse registration.
Patient choice of GP practices
All GP practices in England are free to register new patients who live outside their practice boundary area. This means patients can register with practices in more convenient locations, such as a practice near their work or closer to their children’s schools.
This provides them with greater choice and aims to improve the quality of access to GP services.
Who can register for free primary care services?
The practice recognises that a patient does not need to be “ordinarily resident” in the country to be eligible for NHS primary medical care, this only applies to secondary (hospital) care. Therefore, anybody in England may register with the practice and consult with a GP without charge, this includes (but is not limited to):
- UK residents
- All asylum seekers and refugees
- Students
- People on work visas
- Those who are homeless
- Overseas visitors (whether lawfully in the UK or not)
It is important to note that there is no set length of time that a patient must reside in the UK in order to become eligible to receive NHS primary medical care services. However, the length of time that a patient is intending to reside in an area dictates whether they are registered as a temporary or permanent patient. Patients should be offered the option of registering as a temporary resident if they are residing in the practice area for more than 24 hours but less than 3 months.
Immediately necessary treatment
Like all general practices we are also under a duty to provide emergency or immediately necessary treatment, where clinically necessary, irrespective of nationality or immigration status.
In addition, we are required to provide 14 days of further cover following provision of immediate and necessary treatment.
Determining if the patient lives in the practice area
As with all practices, we have agreed an “inner” boundary with the commissioners. Anyone who resides within the practice’s inner boundary is entitled to apply to register with us.
In addition, we have also agreed an “outer” practice boundary. Patients who move out of our inner boundary area but still reside in the outer boundary area may be able to remain registered with the practice if they wish, and the partners agree.
Details of our boundaries are on our website.
All GP practices are able to register new patients who live outside the practice area without any obligation to provide home visits or services out of hours when the patient is unable to attend their registered practice. It should be made clear to anyone applying for such a registration that it is for the practice to decide, whether it is clinically appropriate and practical to register the individual patient/s in that way.
Requesting information from patients
When a person applies to become a patient, the practice understands and accepts that in order to register here there is no regulatory requirement for the individual to prove:
- Identity
- Address
- Immigration status
- The provision of an NHS number
Whilst there are practical reasons why we might wish to be assured that people are who they say they are, or to check where they live, there is however, no contractual requirement to request this, and nor is establishing an individual’s identity the role of general practice.
The practice currently requests documentation regarding a patient’s identity or immigration status, and this process must be applied for all patients requesting registration. Identification can include a driving license or passport. The practice will accept other forms of photo ID.
As there is no requirement under the regulations to produce identity or residence information, the patient MUST be registered on application unless the practice has reasonable grounds to decline. Registration and appointments should not be withheld because a patient does not have the requested proof of residence or personal identification.
Inability by a patient to provide identification or proof of address will not be considered reasonable grounds to refuse to register a patient.
If a staff member suspects a patient of fraud (such as using fake ID) then they should register and treat the patient but alert the practice manager who will hand the matter over to their local NHS Counter Fraud specialist or report online at www.reportnhsfraud.nhs.uk.
Assessing patient ID at registration
We ask for some form of ID at the point of registration as this will help to ensure the correct matching of a patient to the NHS central patient registry, and help to ensure previous medical notes are passed onto the practice. This is a legitimate part of our registration process and applies to all prospective patients applying to register with the practice. Staff should note that photographic evidence is not required as this could be regarded as discriminatory.
If a patient cannot produce any supportive documentation but states that they reside within the practice boundary, then we will accept this and register the patient.
Homeless patients are entitled to register with a GP using a temporary address which may be a friend’s address or a day centre. The practice may also use the practice address to register them if they wish. If possible, practices should try to ensure they have a way of contacting the patient if they need to (for example with test results).
Patients should also be asked to complete and submit a new patient registration/health questionnaire either online or by hard copy. Inability to undertake this prior to/at the time of registration will not be deemed a reason to refuse to register the patient.
Patients must complete the new style GMS1 form and those who are not ordinarily resident in the UK must complete the supplementary questions section on the reverse of the GMS1. These supplementary questions help determine an overseas patient’s eligibility for free NHS secondary healthcare but do not affect the provision of GP services.
For patients who self declare that they hold either a non-UK issued EHIC, PRC or S1 form, the practice is required to manually record this information in the patient’s medical record and then send a copy of the GMS1 for to NHS Digital, NHSDigital-EHIC@nhs.net (for non-UK issued EHIC/PRC details) or the Department of Work and Pensions (DWP), overseas.healthcare@dwp.gsi.gov.uk (for S1 forms). This should be done as soon as possible after the registration application is received.
Whilst the majority of prospective patients will not find it difficult to produce ID/residence documentation, there will be some patients who do live in the practice area but are legitimately unable to produce any of the listed documentation. Examples of this may be (but not limited to):
- People fleeing domestic violence staying with friends or family
- People living on a boat, in unstable accommodation or street homeless
- People staying long term with friends but who aren’t receiving bills
- People working in exploitative situations whose employer has taken their documents
- People who have submitted their documents to the Home Office as part of an application
- People trafficked into the country who had their documents taken on arrival
- Children born in the UK to parents without documentation
When registering such patients, staff should ensure that the individual is registered with sensitivity to their situation. It is important that these people have equitable access to primary care services.
Registering children
As a minimum requirement the registration arrangements set out above in respect of the registration of any patient with our surgery should be followed when the person registering is a child. However, there are circumstances that staff should be aware of, in relation to safeguarding guidance.
The legal definition of a child is 0 to 18 years of age; however, young people may be able to make independent decisions from as young as 12, depending on the circumstances.
Under Section 11 of the Children Act 2004 places the NHS has a statutory duty to safeguard and promote the welfare of children. Therefore, the following points are extremely important:
- Having a GP registration for every child
- Knowing the identity of those individuals registering the child
- Knowing their relationship to that child
If a child under 16 attempts to register alone or with an adult that does not have parental responsibility, then staff should alert the practice child safeguarding lead and/or the practice manager.
For purposes of safeguarding children, the following should be considered whilst recognising that patients must still be registered in the absence of documentation and policies must be applied in a non-discriminatory manner.
The practice should seek assurance through:
- Proof of identity and address for every child, supported by official documentation such as a birth certificate, (This helps to identify children who may have been trafficked or who are privately fostered.)
- An adult with parental responsibility should normally be registered at the practice with the child and/or be registering at the same time. The ID of the adult is useful as it can be matched to the birth certificate details. However, staff should not refuse to register a child if there is no-one with parental responsibility who can register, as it is generally safer to register first and then seek advice from the practice child safeguarding lead, health visitor or practice manager. (This situation may alert you to a private fostering arrangement which constitutes a safeguarding concern).
- Offering each child, a new patient registration health check as soon as possible after registration
- Seeking collaborative information (supported by official documentation) relating to:
- Current carers and relationship to the child
- Previous GP registration history
- Whether the child is registered with a school and previous education history
- Previous contact with other professionals such as health visitors and social workers
- Children who have been temporarily registered with the practice should be reviewed regularly and proceed to permanent registration as soon as possible, and ideally within three months of initial registration. Likely length of stay should be determined by staff at the initial registration, recorded and the patient registered as temp/permanent as appropriate
- Where parents or carers have been removed from the list due to aggressive and/or violent behaviour a risk assessment should be completed to identify any risk to their children and the appropriate referrals made. Additionally, children of parents or carers, who have been removed from the list for any reason, must not be left without access to primary care services
Staff should be alert to potential risks such as those described above when young people aged between 16 to 18 years of age register alone. These patients should be dealt with in line with the practice’s safeguarding procedures and escalated outside of the practice through the local procedures, if appropriate.
Registration of those previously registered with Defence Medical Services (DMS) and Priority NHS care for Veterans
DMS have their own GP services that look after serving personnel, mobilised reservists, and some families. These primary care services are commissioned separately by NHS England.
When servicemen and women leave the armed forces, their primary healthcare reverts to the responsibility of the local NHS. As a minimum requirement the arrangements set out above in respect of the registration of any patient with our practice should be followed when the person registering is a veteran. Prior service should be recorded on registration and allocated the correct Read/Snomed Code. This should enable access to specialist care or charity support as necessary for such patients.
A veteran is an ex-service person or reservist who has served in the armed forces for at least one day. All veterans are entitled to priority access to NHS hospital care for any condition as long as it’s related to their service (subject to clinical need), regardless of whether or not they receive a war pension.
All people leaving the armed forces are given a summary of their medical records, which they are advised to give to their new GP when they register. The practice will also be advised of prior registration with Defence Medical Services and with a summary of their in-service care.
More information on the duty of care owed to service personnel is contained in the armed forces covenant (PDF).
Persons released from prison and/or in contact with the criminal justice system
As a minimum requirement the arrangements set out above in respect of the registration of any patient with a GP surgery should be followed when the person registering has just been released from prison, or young offenders institute, and/or is in contact with the criminal justice system. It is important that these patients have equitable access to primary medical care services.
This patient group may produce a letter from either the youth offending team or Community Rehabilitation Companies (CRC) stating that they have a place to stay, this letter should suffice for registration purposes under the category ‘documentation from a reputable source’ where the practice has a policy of requiring documentation at registration.
If any staff member is unsure about registering a patient from this cohort, then they should speak with the practice manager.
Refusing registration
Under the terms of our primary medical services contracts, the practice cannot refuse an application to join its list of NHS patients on the grounds of:
- Age
- Appearance or lifestyle
- Disability
- Gender
- Medical condition
- Political beliefs
- Race
- Religion
- Sexual orientation
- Social class
Other than that, we can only turn down an application if:
- The commissioner has agreed that they can close their list to new patients
- The patient lives outside the practice boundary
- We have other reasonable grounds, such as previous known history of abuse against practice staff
Refusing a registration will always be subject to the partners’ discussion and agreement. If we refuse any patient registration then we must record the name, date and reason for the refusal and write to the patient explaining why they have been refused, within a period of 14 days of the refusal.
This information should be made available to commissioners on request. Commissioners may ask practices to submit the numbers of registration refusals, age, ethnicity, and reasons as part of their quality assurance process.
For purposes of clarity, it is not acceptable to refuse to register a patient because they are registered with another local practice.