While a framework audit tells you a supplier's processes were sound when someone inspected them, it cannot tell you whether the nurse walking onto your ward tonight is cleared to work. Ashling Coyle on what trusts should be asking this winter.
The NHS has just had its busiest September on record, and winter hasn't started yet. NHS England recorded 2.44 million A&E attendances and 806,707 ambulance incidents last month, and the national medical director, Professor Frankie Swords, says staff are already seeing “ominous early signs of pressure”, with more flu and other respiratory viruses than usual for this time of year.
A framework audit answers one question: were this supplier's processes sound when someone inspected them? At seven o’clock on a Friday evening in December, the ward needs an answer to a different one: Is the nurse due on this shift cleared to work it tonight?
Whether a shift is filled by an agency or a trust's own bank, the checks behind every temporary worker need to keep pace with that demand. When they don't, it's the trust's ward and the trust's patients who feel it. Most of that work needs doing before January.
Software will not fix a rota that is short of people, but what it can do is make sure the person who does turn up is cleared for the work in front of them, every time, without someone checking by hand at the worst hour of the week.
The staffing mix is changing. The checking does not shrink with it
Last winter was the busiest the NHS has ever recorded. January alone brought 2.32 million A&E attendances and 837,464 ambulance incidents, both records for the month. Planning started early and it showed: more patients were admitted, transferred or discharged within four hours than the winter before.
Normally, this planning work is done during summer, when wards are typically quieter before the winter pressures kick in. This year they haven't had that quiet spell to plan in, because summer demand caused by high temperatures has run straight into winter. And the way they cover these shifts is changing as well. The medium-term planning framework sets a 30% cut in agency use for 2026/27 and a 10% year-on-year cut in bank spend and zero agency spend by 2029/30. So this winter's shifts will be filled by a new mix of permanent staff, trusts' own banks and agencies, and next winter's mix will be different again.
None of that changes the checking. The work behind each temporary shift does not disappear; it moves to your own bank office. In most trusts that office is doing it by hand, on the same rota, under the same pressure. For the ward and the patient it doesn't matter which route a nurse arrives by. The requirement is identical: cleared, current and safe to work tonight.
When the winter pressures begin, that job can't be done by hand.
Why a check at onboarding is not a check
The first thing people underestimate is how much the rules vary between hospitals, and even between wards. One hospital might need thirty compliance documents in place for a single nurse. Another might need fifteen of those and fifteen completely different ones. Change the ward or grade of the nurse and the compliance requirements can change again.
That's why checks done once at onboarding aren't enough. A nurse's registration or mandatory training can lapse between onboarding and a shift. Someone can have every document in order and still be on their seventh night in a row, which isn't safe for anyone.
That’s why it’s also important to have hours and fatigue monitoring. These rules are already built into rail standards for example. At Panther we apply the same logic to healthcare shifts, where the rules have not yet caught up. A worker whose paperwork is perfect and whose seventh night it is remains a risk to themselves and to the patient in front of them.
Checking all of that by hand, at volume, puts a heavy admin load on whoever is filling the shifts, in the staff bank or on the agency desk, and it's exactly when people are busiest that things get missed. Not through carelessness. Because the volume beats the person doing the checking, and the only thing that reliably beats the volume is a system that runs the rules before the shift is confirmed.
Four questions to put to everyone who staffs your wards
Trusts buy agency staff through approved frameworks, and the framework operators audit suppliers against the NHS Employment Check Standards. Those standards matter and the audit is worth having. It is still an audit of a process, carried out periodically, and that is why trusts are expected to do their own due diligence on top of it. The same applies to your own bank.
The checks for this need to run automatically, against each site's rules, before every shift. Here are four questions a trust can put to its own bank office and its temp agency suppliers this month:
1. Are checks repeated before every shift, against what this site requires, or done once at onboarding?
2. Can you show, for any shift, that the worker's registration and mandatory training were current on the day?
3. Do you track hours across all of a worker's shifts and provide reports for visibility?
4. When we ask for the record behind a placement, does it already exist, or does it have to be built from spreadsheets?
It’s even more important to ask now, too, because the rules are about to make it harder. Guaranteed-hours rights arrive in 2027 and agency workers are in scope. Who qualifies is worked out from the hours people actually work, over a reference period expected to run to twelve weeks. Which means the shifts you offer, move and cancel this winter are the record you will be judged on in a year’s time. It’s better to have that record built now rather than have someone rebuild it from spreadsheets in 2027.
