Guidance

Evidencing exception reports

Guidance detailing how to provide evidence for exception reports for additional hours worked replacing the previous supervisor sign-off requirement.

18 December 2025

Chapters

What is exception reporting and who it applies to

Exception reporting applies to all doctors and dentists in training (referred to collectively hereafter as ‘the doctor’) who are substantively employed under the Terms and Conditions of Service for NHS Doctors and Dentists in Training (England) 2016 (2016 TCS) and to those whom the provision has been extended locally. It is recognised that the 2016 TCS are widely mirrored in other employment contexts, and we encourage employers in England to make every effort to extend exception reporting where appropriate*.

The purpose of exception reporting is to ensure prompt resolution and / or remedial action to ensure safe working hours are maintained, secure patient safety, and safeguard the delivery of agreed educational opportunities. Exception reporting is also the mechanism used by doctors to ensure compensation for all work performed and uphold agreed educational opportunities.

This exception reporting guidance is intended to provide direction and advice on how to interpret and implement the changes to exception reporting being enacted via version 13 of the 2016 TCS. This guidance seeks to provide recommendations and best practice approaches to implementing and adhering to these changes.

The overriding principle of these changes is to trust doctors to conduct themselves professionally, and to remove previously existing barriers to exception reporting.

* For example: Academic trainees who hold a national training number/deanery number and are substantively employed by universities. For these doctors, it is encouraged that their exception reporting provision should be extended by clinical employers through a standardised contract. Armed forces trainees who hold a national training number/deanery number. Public health trainees. Locally employed doctors whose terms of employment substantively mirror the 2016 TCS. Locally employed doctors whose terms of employment do not substantively mirror the 2016 TCS, but to whom ER has already been extended at a local level by their employers.

The intention of evidencing

The intention of Annex D paragraphs 8-11, regarding evidencing, is not to create a significant evidential threshold for an exception report to be considered legitimate, which would act as a barrier to exception reporting. The overriding assumption is that doctors will behave in a professional manner, with integrity, and always in accordance with the requirements of the GMC’s Good Medical Practice.

When providing evidence of exception reports, the doctor must provide honest and current evidence to the authoriser. As per Schedule 5 paragraph 9, during the exception report submission the doctor will confirm via self-declaration that the information they are submitting adheres to the reasons for exception reporting as set out in Schedule 5, paragraph 12, and is accurate to the best of the doctor’s knowledge.

Employers will be required to submit to audits and justify that they are satisfied with the evidence of hours worked as there is an obligation upon employers to safeguard public money and its use (Annex D, paragraph 30).

Rationale for evidencing

Prior to the 2016 TCS version 13 (Feb 2026) every exception report required sign-off by clinical and/or educational supervisors, which allowed for sense checking and confirmation of accuracy by an individual with budgetary responsibility. This requirement has now been removed, in part recognising the professionalism required by doctors to behave and act with integrity and always in accordance with the requirements of the GMC's Good Medical Practice, and to remove barriers to exception reporting.

As exception reports will no longer be reviewed by a staff member in the immediate team, no sense checking can be performed, therefore supporting evidence is now required to ensure that public funds are being spent appropriately and exclusively for valid claims.

Access the Terms and Conditions of Service for NHS Doctors and Dentists in Training (England) 2016.

Operation of provision

In addition to those mandatory fields outlined in Schedule 05 paragraph 14, a submitted exception report must contain, or be associated with the doctors live rota, To make the assessment that the doctor is not exception reporting for hours for which they are already rostered to work, HR will need access to the doctor’s live rota to cross-reference the hours reported against the live rota.
The name of the rota used for exception reporting purposes, must match the unique name of the rota when it was issued as part of the work schedule, as required by Schedule 4, paragraph 11.
The best method would be for HR and the doctor to have access to a live rostering system which shows the planned and actual activity and clearly shows any swaps or changes to the duty or rota that day. This is the most effective method as it will also inform the report actioner of where there will be a need to mandate TOIL.
Where this is not yet possible, other options are available such as, in most cases, the rota pattern is associated within the software platform where the doctor reports against a shift. The doctor will provide any additional evidence or explanation required to supplement that, such as swaps or educational opportunity information relevant to the report. It is the responsibility of the doctor to upload relevant evidence.
An inaccurate rota may not necessarily invalidate the exception report; instead, it may indicate a rota governance issue that the employer should explore further to provide the necessary clarity to support a claim. Where the doctor has been unable to provide the necessary evidence for approval following the HR clarification stage, but maintains that the report is accurate, this can then be escalated to the guardian of safe working hours (GoSWH) by HR.
Following submitting an exception report the doctor will need to share evidence of the time, date and location of the event. This could take the form of the doctor screenshotting their location on a map platform on their phone before they leave, or on arrival at work, if commencing work earlier than scheduled.
If an employer is using an exception reporting software platform, then it is not a requirement that evidencing of time, date and location is uploaded to that software platform. The process of this functionality should not create an obstacle to reporting for the doctor and evidencing will need to submitted separately, outside of the platform if it lacks functionality to do so.
As per Annex D paragraph 10, the doctor can submit evidence to a fallback option, such as a designated, dedicated evidencing email inbox, accessible only by HR, the GoSWH and the director of medical education (DME). This submission needs to be associated with the exception report, as per Annex D paragraph 8, so this should reference the unique report identifier code for the exception report. It is recommended that all employers have this fallback ready. The inbox can be used to submit exception reports in the event the employer does not have an ER software, or if this software fails, this should be monitored often in order to avoid any possible access and completion fine.
Further guidance will be produced to display scenarios and a suggested checking process for evidencing.
The report actioner will assess the accuracy of the evidence, if they believe there are inaccuracies or the evidence is incomplete, they can contact the doctor to clarify the inaccuracies. Following the HR clarification stage, if the doctor maintains the accuracy of the exception report, but if HR questions the evidence is inaccurate or insufficient to approve the report, then they may escalate to the GoSWH (Annex D, paragraph 13).
For doctors working on NROC shifts, the requirement for them to evidence the location of the occurrence that necessitated the exception report does not apply (as per Annex D paragraph 9). This is reflective of how actual work performed during an non resident on-call (NROC) shift may not occur on an NHS site and could instead be remote (that is, via phone call providing advice) or on a non-typical work site (that is a public health registrar responding to a public health emergency).
Instead, the doctor should evidence the time and date of the work undertaken on NROC shifts. This could take the form of: the call log, showing the call where the doctor provided advice, or which prompted the doctor to undertake work; non-confidential, or redacted, emails demonstrating the doctor’s undertaking of work during the NROC shift; if available and applicable, the organisational switchboard call log; screenshots of a bleep app demonstrating the doctor being notified of the need to undertake work.
Due to the highly variable nature of how NROC work occurs and is initiated, it is likely that local agreements will need to be reached on what evidence will be used to evidence exception reports for NROC shifts. Due to the variable nature of NROC work, different forms of evidence may need to be agreed for different specialties. These discussions should happen at the relevant LNC, and there should be representation from the relevant specialties / departments when these discussions occur.
For exception reports relating to NROC shifts, the work schedule displaying the predicted hours needs to be evidenced, either as a function of the software, accessible by the reviewer, or through a local mechanism and uploaded as evidence.

Corroboration by another regulated professional (Annex D, paragraph 11)

It may not always be possible for a doctor to evidence the time, date or location of the occurrence that necessitated an exception report. This could be for a multitude of reasons such as: a GP registrar on a home visit would not be able to reveal the location of a patient’s home, a doctor’s phone had run out of battery at the point they were leaving work, or the relevant shift was simply too busy that the doctor forgot to make a record of their time, date and location.

To satisfy the evidencing requirement in these circumstances, a doctor can have their exception report corroborated by another regulated clinical professional (as per Annex D paragraph 11). This must be a healthcare professional who is on a statutory professional register (for example, the General Medical Council, Nursing and Midwifery Council, The Health and Care Professional Council), and is able to confirm the accuracy of the reported event. For example, a nurse, physiotherapist, midwife, pharmacist, or another doctor.

This corroboration should be an electronic record of communication (for example an email from their NHS email account), confirming that the doctor did undertake the work that necessitated the exception report. This is required so that the evidence is available for auditing purposes.

Where possible, the evidence should be uploaded to the software platform in retrospect.
Corroboration cannot be made a default requirement but provides some flexibility to allow exception reports to be submitted for action.

Corroboration requests made by the doctor will not result in an information breach.