Patient registration

In recent months, we have become aware that some patients, such as those who are homeless, are struggling to become registered with a GP practice.  We know that as part of their recovery and restoration plans, practices and Primary Care Networks are looking at how they can address health inequalities within their local registered health populations and ensure all patients have equitable access to services.  We are therefore taking the opportunity to remind practices of their obligations when an individual or individuals approach them about registering as a patient.

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. In effect, therefore, anybody  in England may register and consult with a GP without charge.   It is important to note that there is no set length of time that a patient must reside in the country in order to become eligible to receive NHS primary medical care services.

Therefore, all asylum seekers and refugees, students, people on work visas and those who are homeless, overseas visitors, whether lawfully in the UK or not, are eligible to register with a GP practice even if those visitors are not eligible for secondary care (hospital care) services.   The length of time that a patient is intending to reside in an area normally dictates whether a patient is registered as a temporary or permanent patient.

General Practices are also under a duty to provide emergency or immediately necessary treatment, where clinically necessary, irrespective of nationality or immigration status. The practice is required to provide 14 days of further cover following provision of immediate and necessary treatment.

Registration should be available to all patients every day rather than on particular days and throughout the practice’s advertised opening hours.

Requesting documentary information from patients

Under the terms of their primary medical services contracts, GP practices cannot refuse an application to join its list of NHS patients on the grounds of race, gender, social class, age, religion, sexual orientation, appearance, disability or medical condition.

Practices can refuse an application to join a practice list if:

• the commissioner has agreed that they can close their list to new patients,
• the patient lives outside the practice boundary; or
• if they have other reasonable grounds.

In practice, this means that the GP practice’s discretion to refuse a patient is limited.

In addition, when applying to become a patient there is no regulatory requirement to prove identity, address, immigration status or the provision of an NHS number in order to register. However, there are practical reasons why a practice might need to be assured that people are who they say they are, or to check where they live. Seeing some form of ID will help to ensure the correct matching of a patient to the NHS central patient registry, thereby ensuring any previous medical notes are passed onto a new practice. It is legitimate therefore for the practice to apply a policy to ask for patient ID as part of their registration process.

Any practice that requests documentation regarding a patient’s identity or immigration status must apply the same process for all patients requesting registration equally. A practice policy should not routinely expect a patient to present a photograph as this could be discriminatory.

The majority of patients will not find it difficult to produce ID / residence documentation, however 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:

• People fleeing domestic abuse staying with friends, family or in a shelter.
• 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

Reasonable exceptions therefore need to be considered and the individual registered with sensitivity to their situation.

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. These circumstances would not be considered reasonable grounds to refuse to register a patient and neither should registration or access to appointments be withheld in these circumstances. If a patient cannot produce any supportive documentation but states that they reside within the practice boundary then practices should accept the registration.

People who are homeless have particular health needs and often suffer some of the worst outcomes. Both the BMA and NHS England are committed to ensuring homeless patients receive the same level of care as those with permanent addresses.  The same rules as above regarding identity and proof of address applies to homeless patients. 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 address may also be used to register them.

Practices may find the guidance published by the BMA about patient registration helpful to refer to https://www.bma.org.uk/advice-and-support/gp-practices/managing-your-practice-list/patient-registration

If a practice suspects a patient of fraud (such as using fake ID) then they should register and treat the patient but hand the matter over to the NHS Counter Fraud Authority (NHSCFA) who can be contacted on the Reporting Line: 0800 028 4060 or by email at: [email protected]

If a practice refuses any patient registration then they 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.

We would please ask all practices to remind all staff of the policy guidance set out above so that we can ensure that all individuals, including those who may be vulnerable, can access primary care services.