The guidance has been in force since December 2025. Inspectors are asking the questions. Too many practices still do not have the answers regarding the Chaperone Compliance Gap.
It has been six months since NHS England published its updated chaperoning guidance. In that time, The Training Network has worked with practices across the country, and the picture that has emerged is not encouraging. The guidance is widely known. Compliance is not widespread. And CQC inspectors are beginning to arrive at practices with questions that many teams are not yet able to answer about the Chaperone Compliance Gap.
Understanding the nuances of the Chaperone Compliance Gap is essential for every practice to ensure they meet compliance requirements.
This is not a criticism of general practice. The requirements are demanding, the operational challenges are real, and the guidance is ambiguous in places that matter. But ambiguity is not a defence at inspection, and goodwill is not a substitute for documentation.
What CQC Are Actually Finding
The Chaperone Compliance Gap: An Urgent Concern
Inspectors are reporting three consistent findings across the practices they are visiting.
This highlights the importance of addressing the Chaperone Compliance Gap proactively and ensuring patient safety.
To mitigate risks, practices must confront the Chaperone Compliance Gap head-on and implement thorough training protocols.
This contributes to the overall challenge of the Chaperone Compliance Gap that practices face today.
Addressing the Chaperone Compliance Gap is crucial for maintaining patient trust and safety.
To navigate this, practices need to be aware of the Chaperone Compliance Gap and its implications.
Failing to acknowledge the Chaperone Compliance Gap can lead to significant legal and professional repercussions.
This may inadvertently contribute to the widening of the Chaperone Compliance Gap that we currently observe.
Ultimately, addressing the Chaperone Compliance Gap ensures that patients are treated with the utmost professionalism.
It is vital that practices take steps to bridge the Chaperone Compliance Gap effectively.
Without proper training, staff may not be equipped to deal with the challenges posed by the Chaperone Compliance Gap.
First, the offer is still reactive in most practices. Chaperones are available, but the proactive offer at the point of booking is not happening consistently. In many practices it is not happening at all. The guidance is clear that available on request is not sufficient. The offer must be made, recorded, and the patient decision documented.
This situation underscores the urgency to address the Chaperone Compliance Gap in all areas of practice.
Second, non-clinical staff are acting as chaperones without formal training. This is the finding that creates the greatest professional risk. A receptionist who steps in to act as a chaperone without training, without a DBS check, and without a clear understanding of their role and responsibilities is not fulfilling the function the guidance requires. They are also personally exposed if something goes wrong.
Third, documentation is insufficient. The minimum requirement is a record of the clinical indication, the offer, the patient decision, and the chaperone identity. Most practices are recording a fraction of this. Some are recording nothing beyond a note that a chaperone was present.
CQC’s attention to this matter highlights the critical nature of the Chaperone Compliance Gap in current healthcare practice.
The Ambiguity Problem
The guidance does not resolve every question it raises, and this is creating genuine risk for practices that are trying to comply in good faith.
The definition of an intimate examination extends to any examination where it is necessary to be close to the patient. This is broad enough to include dental examinations, ophthalmoscopy in a darkened room, and abdominal ultrasound, none of which most teams would instinctively consider intimate. If a clinician decides that a particular examination does not require a chaperone offer because they do not consider it intimate, and a patient later disagrees, the clinician has no documented reasoning to rely on. The safe default is always to offer.
The guidance requires a formal chaperone for intimate examinations of all children under 18, but it does not carve out baby checks or NIPE examinations. Several NHS trusts have created local policy exceptions for babies under one year old, but these are local decisions and do not reflect the national position. Practices that have not considered this point are already non-compliant for a proportion of their clinical activity.
The guidance requires chaperoning principles to apply to remote consultations and digital image requests, but it does not define what that means operationally at the point of image capture. A patient photographing an intimate area of their own body at home has no independent witness in that moment. Practices need a documented approach to this scenario, not just an acknowledgment that the principle applies.
| The cost of getting it wrong A chaperone complaint or safeguarding concern investigated against a background of incomplete training, absent DBS checks, and poor documentation does not just create a CQC finding. It creates personal professional risk for the clinician, reputational risk for the practice, and potential liability under data protection legislation if digital images have been mishandled. The guidance exists to protect patients. It also exists to protect staff. Both protections depend on the process being followed correctly. |
Why Online Training Is Not Enough
The market has responded to the guidance with a surge of online chaperone training modules. Some are well constructed. Most are not sufficient.
The chaperone role requires judgment under pressure. A chaperone who is inside a screened area during an intimate examination and becomes concerned about what they are witnessing needs to be able to act in that moment. That is not a skill that can be developed by clicking through a fifteen-minute online course. It requires practice, discussion, and the kind of scenario-based learning that only works in a room with other people.
CQC inspectors are beginning to ask about the content and format of chaperone training, not just whether training has been completed. An online module completed six months ago and never reviewed is unlikely to satisfy an inspector who is looking for evidence that staff are genuinely equipped for the role.
Face-to-face or live online training, delivered to the whole practice team, with space for real questions, real scenarios and real conversation, is what the guidance envisages and what inspection evidence is beginning to demand.
The Window Is Closing
CQC inspections are not evenly distributed. Many practices have not yet been inspected under the new framework. But the window during which a practice can say it is working on compliance is closing. The guidance has been in force for six months. Inspectors are arriving with it in hand.
The practices that act now, that train their whole team, audit their DBS status, update their documentation, and build the chaperone offer into their booking process, will be the ones that emerge from inspection with evidence rather than explanations.
The ones that do not will find that good intentions are not sufficient when the questions are being asked.
Mark Edwards | Director, The Training Network | thetrainingnet.com
The Training Network delivers whole-team chaperone training for GP practices and PCNs. Face-to-face and live online options available. Contact us at thetrainingnet.com to discuss your practice needs.
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