From baby checks to blank records, the implementation picture is more complicated than the guidance anticipated.
Three months have passed since NHS England published its updated chaperoning guidance, the New Chaperone Guidance. In that time, The Training Network has delivered chaperone training to teams across general practice, and the conversations in those rooms have been illuminating. What GPs, nurses, receptionists and practice managers are wrestling with is not the principle of the guidance. Most people accept that chaperoning matters and that the bar needed to be raised. What they are struggling with is the detail, particularly the places where the New Chaperone Guidance either does not go far enough or leaves practices without a clear answer.
Understanding the New Chaperone Guidance
Understanding the implications of the New Chaperone Guidance is crucial for all involved in patient care.
This is what we are hearing.
The Baby Check Problem
Adhering to the New Chaperone Guidance is essential to ensure patient safety and trust.
The question that has generated the most discussion, by some margin, is this: does a six-week baby check require a formal chaperone?
It’s important for practices to regularly review the New Chaperone Guidance to remain compliant.
Implementing the New Chaperone Guidance can improve overall patient experience during consultations.
Understanding the New Chaperone Guidance helps mitigate potential risks during examinations.
Under the guidance as written, yes. A six-week check that includes examination of the genitalia falls within the GMC definition of an intimate examination of a child under 18. The guidance requires a formal independent chaperone, with the parent present separately for reassurance rather than as the chaperone.
The British Medical Association raised this exact scenario when the guidance was published. The General Practitioners Committee pointed out that requiring a chaperone separate from the parent for a nappy rash assessment or a baby check creates capacity problems that many practices, particularly small or single-handed practices, simply cannot resolve on a routine basis. The guidance has not been updated to address this, and practices are left navigating it for themselves.
| What we are telling practices Where a formal chaperone cannot be provided for a baby check, the practice must document that the requirement was known, why it could not be met on this occasion, what safeguards were in place, and that the parent was present. Proceeding without documentation leaves the clinician unprotected. Watch for updated national guidance on this specific point. |
The DBS Confusion
Practices must ensure all staff are familiar with the New Chaperone Guidance to uphold standards.
Many practices believed that DBS checks for non-clinical chaperones were already in place, or were not their responsibility to arrange. The reality is more complicated.
The guidance requires non-clinical staff acting as formal chaperones to be trained and strongly recommends DBS checks at minimum standard level, with individual eligibility assessed by context. What this means in practice is that a receptionist who has occasionally stepped in to act as a chaperone, but who has never been formally trained for the role and has no DBS check, is not compliant with the current guidance. And there are many such receptionists across general practice.
Practices are also asking who is responsible for the DBS check where staff have been transferred from another employer. The answer is that the current employing practice is responsible for ensuring appropriate DBS checks are in place for anyone they ask to fulfil the formal chaperone role.
The Documentation Gap
The documentation requirement is where the largest gap currently sits. The guidance requires practices to record the clinical indication for the examination, that the chaperone offer was made at booking and before the examination, the patient decision, and the full name and role of the chaperone present. Where possible, the chaperone should co-sign the record.
What most practices are currently recording is significantly less than this. Many clinicians note that a chaperone was present but do not record the offer, the patient decision, or the chaperone identity. Some record nothing at all unless the patient declined, on the basis that absence of a record is taken to indicate a chaperone was present.
Feedback from patients about their experiences under the New Chaperone Guidance is vital for ongoing improvements.
By embracing the New Chaperone Guidance, practices can foster a culture of safety and respect.
Regular training on the New Chaperone Guidance is essential for maintaining compliance.
This approach does not satisfy the 2025 requirements and will not withstand CQC scrutiny. There is also no dedicated SNOMED CT code for chaperone offered, which means the offer itself must be recorded in free text alongside the outcome code. That free text entry is carrying evidential weight that many clinicians do not currently recognise.
Collaborative discussions about the New Chaperone Guidance can lead to better practice outcomes.
For clarification on the New Chaperone Guidance, practices should consult relevant resources.
The Online Training Trap
We have spoken to a number of practices that have responded to the new guidance by purchasing an online chaperone training module for their teams. The intention is right. The approach carries a significant risk.
Online training can convey information. It cannot develop the judgment, confidence and communication skills that the chaperone role actually requires. A receptionist who completes an online module knows what a chaperone is supposed to do. A receptionist who has worked through real scenarios in a facilitated session, practiced the language for making the offer, discussed what to do when a patient declines, and considered what it would actually feel like to raise a concern during an examination, knows how to do it.
The distinction matters because the guidance requires chaperones to be trained, not just informed. CQC inspectors are asking about the nature and content of training, not just whether training has been completed. An online module that takes twelve minutes to click through is unlikely to satisfy that scrutiny, particularly in the event of a complaint or safeguarding concern.
What Practices Are Getting Right
It would be unfair to present only the challenges. There are practices that have responded to the guidance with genuine seriousness, and the difference in team confidence and documentation quality is already visible.
The practices that are doing this well have treated it as a whole-team priority rather than a clinical one. They have brought receptionists, HCAs, nurses, GPs and managers into the same room, worked through the same scenarios, and left with a shared understanding of what the policy means for each role. They have updated their booking systems to include the chaperone offer. They have started maintaining a training register. And they have had the difficult conversation about which staff members do not yet have a DBS check and what to do about it.
These are the practices that will be ready when the inspector arrives.
Mark Edwards | Director, The Training Network | thetrainingnet.com
If your practice has questions about chaperone compliance or would like to discuss training options, contact The Training Network at thetrainingnet.com
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