Summary
Two regulations sit behind the question and they ask for different things. Regulation 18 requires sufficient numbers of suitably qualified, competent, skilled and experienced persons deployed, and deployed means what happened rather than what was planned. Regulation 19 requires staff to be of good character with the necessary qualifications and competence, evidenced before and during employment, which makes it a standing check rather than an onboarding one. A rota system answers the first badly if it records only intentions, and answers the second not at all unless it holds a date of last verification per person.
Staff availability sounds like a scheduling problem and is assessed as a safety one. The question an inspector reaches is rarely whether you have a rota. It is who was actually working on a particular afternoon, and whether they were qualified for what they did.
Most clinics can produce the plan instantly and the reality slowly. That is the wrong way round, because only one of the two is evidence.
Part of the CQC hub, with the framework explained, a readiness checklist and 10 guides.
See it in your clinicWho was booked, who worked, who covered and what each of them was registered to do, from the same record the clinic runs on.
Request a demo| Question | Regulation | Where systems fall short |
|---|---|---|
| Were there enough suitably qualified people on this date | 18, staffing | The rota shows the plan. Sickness, swaps and no-shows are recorded elsewhere or not at all |
| Was the person who covered qualified for what they covered | 18, staffing | Cover is recorded as a name rather than against a scope of practice |
| Is this clinician currently registered | 19, fit and proper persons | Checked at onboarding and never again, so the record proves one day |
| What happened when a registration lapsed | 19, fit and proper persons | Nothing links a registration status to the ability to be rostered |
Deployed is not rostered
Regulation 18 requires sufficient numbers of suitably qualified, competent, skilled and experienced persons to be deployed. A rota is a statement of intention made in advance, and intention is not what the word deployed describes, so the rota on its own answers a different question from the one being asked.
The difference shows up the moment somebody calls in sick. A clinic that swapped a session, brought in a locum and carried on has done nothing wrong, and will struggle to show it if the swap lived in a message thread. The evidence that survives is a record of the day as worked, held in the same place as the plan so the two can be compared without anybody reconstructing them.
Cover, and scope of practice
The follow up question after who covered is almost always whether that person could do what they covered. A nurse covering a clinic list is a different fact from a nurse covering a clinic list that included procedures outside their competence, and a name in a rota slot does not distinguish them.
This is where most scheduling products stop being useful, because they model people and times rather than people, times and what each person is permitted to do. A clinic that holds scope of practice somewhere other than the rota will answer this question from two systems and a memory.
Registration checks lapse quietly, and nobody is told
Regulation 19 asks for staff of good character with the qualifications, competence, skills and experience necessary for the work, and it is not satisfied by a check performed once. A professional registration can lapse, be suspended or acquire conditions at any point, and none of those events notifies the clinic that employs the person.
The practical control is a date of last verification held per person, somewhere a human looks at rather than a folder nobody opens. The stronger control, which very few clinics have, is that the registration status and the ability to be rostered are connected, so that an expired check is visible when somebody tries to schedule rather than months later.
The test worth running before you buy
Pick a week three months ago and request four things from the system. Who was planned, who actually worked, who covered any gap, and the registration status of each of them on that date. The answer tells you more than a demo, because a demo shows the happy path and this question lands on the joins between modules.
Most systems answer the first instantly, the second with an export, the third from somebody's memory and the fourth from a spreadsheet. That is not a disqualification. It is a map of how long the evidence takes to assemble, and assembling it under time pressure is the thing worth avoiding.
What we are not claiming
This page describes what the regulations require and what systems can evidence. It is not legal advice and does not substitute for your registered manager's judgement or for CQC's own guidance. Where a decision turns on detail, the legislation linked below governs rather than this summary of it.
wai is not CQC registered and makes no claim to be. CQC registers providers of regulated activities rather than software suppliers, so the registration and the duty stay with the clinic.
Where wai sits
wai holds the clinic's diary, the clinicians and the record in one place, so what was booked, what happened and who was in the room are facts from the same system rather than three. Every read of a patient record is logged against a named role.
What that buys is that the planned against worked comparison is a report rather than a reconstruction. We are not a human resources system and do not claim to replace one, and the wider map of which regulations a clinic's systems answer is in software and CQC, what is actually being assessed.
Run the four part test above on us with a real past week. If the answer takes us longer than it should, we would rather you found out before buying. Clinicians still decide what enters the record.
Request the report that shows planned against worked for one past week. Most systems cannot produce it.
Request a demoFrequently asked questions
What does Regulation 18 require for staffing?
Sufficient numbers of suitably qualified, competent, skilled and experienced persons deployed to meet the needs of service users. Deployed describes what happened rather than what was planned, which is why a rota alone answers a different question from the one being asked.
Is a rota enough evidence of safe staffing?
No. A rota records an intention made in advance. The evidence that survives a follow up covers the day as worked, including sickness, swaps and cover, held in the same place as the plan so the two can be compared without reconstructing either.
What does Regulation 19 require about professional registration?
That staff are of good character and hold the qualifications, competence, skills and experience necessary, evidenced before and during employment. A registration can lapse, be suspended or carry conditions without the employing clinic being told, so a check performed once at onboarding evidences one day rather than a duty.
How should a clinic track registration expiry?
A date of last verification per person, held where somebody looks at it rather than filed. The stronger control is to connect registration status to the ability to be rostered, so an expired check surfaces when somebody tries to schedule rather than at the next assessment.
What is the single best question to put to a rota vendor?
Pick a week three months ago and request who was planned, who actually worked, who covered any gap, and each person's registration status on that date. A demo shows the happy path. That question lands on the joins between modules, which is where the time goes.
Does wai replace a rostering or HR system?
No. wai holds the diary, the clinicians and the record together so planned against worked is a report rather than a reconstruction, but it is not a human resources system and does not claim to be one.
Sources
Planned against worked, for a real week
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