Routes to Registration DBS Requirements

All routes to Health and Care Professions Council (HCPC) registration as a biomedical scientist require that an enhanced Disclosure and Barring Service (DBS) check is completed as part of the education provider’s application process (regardless of whether the registrant will work with patients). 

Section 2.4 of the HCPC Standards of Education and Training (SETs) state that the education provider must ask about criminal convictions as part of the admission to a programme of study.

The IBMS, as the approved HCPC education provider for the four routes to registration as a biomedical scientist, is required to ask about criminal convictions as part of the admission to its HCPC approved programmes of study. These include the IBMS Certificate of Competence (registration training portfolio) and the IBMS Certificate of Competence by Equivalence (Biomedical Scientist) programmes. Therefore, the applicant’s training officer or training manager must ensure that the applicant undertakes an enhanced DBS check as part of the application and admission process for the IBMS Registration Portfolio and IBMS Certificate of Competence by Equivalence (Biomedical Scientist) programmes.

When the enhanced DBS certificate has been issued, the applicant must confirm with the training officer as part of their application that this has been completed. The applicant will also sign off the following self-declaration statement on the application form: “I understand that failure to disclose full information or any deliberate misrepresentation of information can be a serious matter and will invalidate my application. I understand the need for criminal conviction assessment and, to the best of my knowledge, there is no barrier to prevent me from being eligible to register once I have met the HCPC standards of proficiency.”

All applicants must have completed a current enhanced DBS check that has been shared with their training officer when they apply for the registration training portfolio, whether they are a placement student, apprentice or a member of staff.

At the point of registration, after the Certificate of Competence has been issued by the IBMS, only a self-declaration form is required by the HCPC - as they know that, as an approved education provider, the IBMS have already ensured the enhanced DBS check has been completed.

Frequently asked questions

1. As a university that delivers an IBMS accredited degree (without the IBMS portfolio), ie students have only competed the degree not the certificate of competence, are we supposed to ask all applicants about criminal records and ask them for a DBS check?
   
   No – only those students who are starting a programme with an integrated placement (eg Healthcare Science PTP programme or apprenticeship) are required to have a DBS check at the point of entry. Students starting a 3 year BSc do not.
   
   The enhanced DBS check is required as part of an application for the IBMS Registration Training Portfolio which can only be applied for when the candidate is going to be working in an IBMS approved training laboratory (and once the laboratory has agreed to support their application). The check is therefore the only other occasion a student will require a DBS check once on programme is if they transfer to a sandwich placement route. A DBS check will then be required before they commence the portfolio.
   
   
2. Does the applicant have to cover the cost of the DBS?
   
   Enhanced DBS checks can only be applied for through an employer or organisation as individuals cannot apply for an enhanced DBS check on themselves. However, the responsibility of who pays for the check is for the employer to decide.
   
   
3. What are the rules for the Scottish Disclosure system?
   
   Health boards in Scotland only require a PVG not an Enhanced Disclosure. 
   
   
4. How does this impact on anyone who already has their portfolios? Do they need to complete an enhanced DBS in advance of applying for their verification?
   
   Trainees who have already been issued an IBMS Registration Training Portfolio are not required to undergo an enhanced DBS check, however they must sign the declaration on the verification request form which asks them to raise any issues that could affect their eligibility to subsequently register with the HCPC.
   
   Anyone already in the workforce who did not have a DBS check done but is now registered with the HCPC will have completed the self-declaration form at the point of registration. These colleagues are not required to now have a DBS check done.
   
   
5. Are DBS checks required for undergraduate enrolment, or is this required at the point of registration for HCPC application?
   
   For IBMS accredited degree programmes without a placement year, we do not require DBS checks for the undergraduate enrolment (as this is done later when the portfolio is applied for instead). 
   
   

6. Do all students entering a BSc Biomedical Science programme require an enhanced DBS check?
   
   3 year BSc Biomedical Science programme – no requirement for a DBS check at the point of admission or throughout if the student does not do a clinical pathology placement.

7. Do all students undertaking a sandwich placement during their BSc Biomedical Science programme require an enhanced DBS check?

   For 3 year BSc Biomedical Science programmes with a sandwich route, there are no requirements for a DBS check at the point of admission to the programme, but an enhanced DBS check is required when transferring to the placement year.
   
   If a student sources a placement year in an IBMS approved training laboratory to complete the registration training portfolio, the DBS check is carried out and paid for by the university at the point at which the student transfers to the placement route.

8. Do all students entering a BSc Biomedical Science programme containing an integrated placement require an enhanced DBS check?

   For a 4 year integrated placement programme, a DBS check is required at the point of admission to the programme (ie before commencing year 1). Students have their enhanced DBS check prior to admission which is paid for by the university.
   
   If a student transfers to the integrated placement route during the programme, an enhanced DBS check is completed before transfer (ie not prior to overall admission), carried out and paid for by the university.

9. Will this need to be completed for students already on the course, or just new students entering the programme and applying for their portfolio?
   

   For apprentices, the enhanced DBS check should be carried out by the employer at the point of admission to the apprenticeship programme and they need this for all current cohorts of apprentices.

   For students, they do not need a DBS check unless they transfer to a placement route as outlined in my previous answers.

10.  Do currently registered biomedical scientists require DBS checks, will we need to retrospectively DBS check all staff now or just new starters/trainees?

    Once colleagues are registered with the HCPC, they do not need to complete a further DBS check, just complete the annual self-declaration for the HCPC. It is only at the point of application for the registration training portfolio that we are required to ask for an enhanced DBS check, as the education provider of the portfolio. 

    Information from the HCPC -
    Biomedical scientists must make a professional declaration once every two years in order to stay HCPC registered, which involves them declaring any change to their good character (including any convictions or cautions that they are required to disclose).
    
    Making your professional declaration | (hcpc-uk.org)