Sai Keerthana Sriperambuduru

Preliminary Matters

Service

1.    The Panel was satisfied that the Registrant had been properly served with notice of today’s hearing by email dated 28 October 2025 in accordance with the Health and Care (Investigating Committee) (Procedure) Rules 2003, as amended.

Proceeding in absence

2.    Ms Rawlings made an application for the hearing to proceed in the absence of the Registrant on the grounds that the Registrant had voluntarily absented herself and waived her right to attend.

3.    The Panel had regard to the HCPTS Practice Note on “Proceeding in the Absence of the Registrant” and accepted the advice of the Legal Assessor. The Panel noted the following:

•    By her Response to allegation form dated 13 February 2025 the Registrant informed the HCPC that she would not attend the hearing of this matter but intended to be represented;

•    The Registrant had not thereafter responded to requests from the HCPC to provide details of her proposed representative;

•    The Registrant was last in contact with the HCPC by email dated 21 August 2025 since when she had disengaged and not responded to numerous attempts by the HCPC to contact her up to and including 20 February 2026;

•    The Registrant had not applied for an adjournment or provided any reasons why the hearing should be adjourned.

4.    The Panel inferred that the Registrant had voluntarily absented herself and waived her right to attend. The Panel considered that the Registrant would be unlikely to attend if the hearing were adjourned to a later date and that no useful purpose would be served by an adjournment. The Panel decided that it was in the public interest to proceed with the hearing in the Registrant’s absence.

Background 

5.    On 01 February 2023 the registrant applied to join HCPC register as an international applicant and declared in the application form that English was her first language.

6.    On the basis of her completion of the application form, the Registrant was not required to provide any proof of her proficiency in the English language and was admitted to the HCPC register as a Speech and Language Therapist.

7.    On 23 October 2023, the Registrant joined York and Scarborough Teaching Hospitals NHS Foundation Trust (the Trust) as a Band 5 paediatric speech and language therapist (SALT). 

8.    Ms HR was the Registrant’s line manager for her whole period with the Trust. 

9.    From the Registrant’s first review meeting on 07 November 2023, there were issues with her English proficiency and its effect on her ability to work effectively. The Registrant was unable to communicate effectively with patients or colleagues and was unable to recognise patients' difficulties with matters of speech, including pronunciation, sentence structure and grammar.

10.    When these concerns were raised with the Registrant, she informed Ms HR that English was not her first language. 

11.    By the time of the Registrant’s second probationary review on 06 December 2023, she disclosed that she was having regular English lessons outside of work. Further, she disclosed that she was struggling particularly with writing and transcription during assessments due to children or parents speaking quickly.

12.    Following further reviews, the Registrant’s probationary period was extended on 06 February 2024.

13.     A fifth and final probation review took place in two parts on 21 May 2024 and 03 June 2024. Ms ZBW, who was the Associate Chief Allied Health Professional for the Family Heath Care Group at the Trust, attended both parts of the Registrant’s final probationary review meeting along with Ms HR. 

14.    After the meeting on 03 June 2024 Ms ZBW sent the Registrant an outcome letter, informing her that she was dismissed on grounds of capability, stating that the Trust “cannot sustain the levels of support without further compromising patient care and the existing team”. 

15.    The Registrant appealed the Trust’s decision to dismiss her. The appeal was heard on 10 July 2024 and was unsuccessful. 

16.    On 11 November 2024 the Registrant confirmed to the HCPC that she had not taken the IELTS exam prior to entering the UK. 

The Hearing 

17.    The HCPC provided the Panel with a hearing bundle which included the witness statements and exhibits of:

•    Ms HM, international registrations operations manager at the HCPC; 

•    Ms HR; 

•    Ms ZBW.

18.    The Panel heard oral evidence from each of the above witnesses who confirmed the contents of their witness statements as their evidence-in-chief and answered questions from the Panel.

19.    Following the close of the HCPC’s case and advice from the Legal Assessor, the Panel was informed by the Hearings Officer that an email had been received at about 1:00pm on 03 March 2026 by Blake Morgan from the Registrant together with written representations. Having heard submissions from Ms Rawlings as to the admissibility of this documentation, and after receiving advice from the Legal Assessor, the Panel decided to consider and to take into account this documentation which comprised:

•    An email dated 03 March 2026 from the Registrant stating that “I am writing to inform you that due to a personal emergency involving hospitalisation, I was unable to attend the meetings scheduled from 2nd to 4th March 2026 …. As previously communicated, I have attached my written representations for the Panel’s consideration. I respectfully request that the attached documentation be taken into account”.

•    The Registrant’s written representations dated March 2026.

20.    The Registrant was invited to submit further information if she wished to which no response was received. 

The evidence 

Ms HM

21.    Ms HM exhibited:

•    a screen shot of a page of the Registrant’s application for registration with the HCPC, which showed that the Registrant had ticked a box on the form to the effect that English was her first language;

•    A screen shot of the HCPC website showing English language requirements at the relevant time.

22.    At the Panel’s request, Ms HM further exhibited a complete application form dated February 2023 – not that of the Registrant – as illustrating the information provided to the Registrant on completing her application for registration.

23.    Ms HM accepted that, in addition to stating that English was her first language, the Registrant had indicated on the application form that she had proof of her English proficiency by selecting the box ‘other’. Ms HM stated that the Registrant had not provided any further details, as she could have done, by reference to a drop-down menu on the form.

Ms HR

24.    Ms HR gave evidence that on 23 October 2023 the Registrant joined York and Scarborough Teaching Hospitals NHS Foundation Trust (the Trust) as a Band 5 paediatric speech and language therapist. 

25.    Ms HR stated that at the Registrant’s request she had written questions for the purposes of the job interview into the chat-box, despite the fact that the Registrant was resident in the United Kingdom at the time. Ms HR said that this was very unusual.

26.    Ms HR was the Registrant’s line manager for her whole period with the Trust. 

27.    From the Registrant’s first review meeting on 07 November 2023, issues with her English proficiency and its effect on her ability to work effectively were noticed and noted.

28.    Ms HR became concerned as she observed deficiencies in the Registrant’s English, both in conversation and in written work. Ms HR said that this was important as the role of a Speech and Language Therapist requires clear communication and the ability to recognise patients' difficulties with matters of speech including pronunciation, sentence structure and grammar.

29.    Ms HR considered that the Registrant needed further support and considered how the Trust could provide this. The Registrant informed Ms HR that English was not her first language. 

30.    By the time of the Registrant’s second probationary review on 06 December 2023, she disclosed she was having regular English lessons outside of work. Further, she disclosed that she was struggling particularly with writing and transcription during assessments due to children or parents speaking quickly. Ms HR stated that “transcriptions” are how Speech and Language Therapists note down sounds made by a patient to enable the speech/ language difficulty to be adequately recorded.

31.     A third review took place on 02 January 2024. 

32.    A fourth review took place on 06 January 2024. At this review, the Registrant’s probationary period was extended. The Registrant stated again during this review that English was not her first language. 

33.    On 09 February 2024, the Registrant was sent a letter confirming matters discussed during the fourth review including "you said that as English isn't your first language it has been a huge transition". 

34.    A fifth and final probation review took place in two parts on 21 May 2024 and 03 June 2024. Part 1 of the review was adjourned to allow the Human Resources department to check English language requirements for Speech and Language Therapists with the HCPC. 

Ms ZBW

35.    Ms ZBW, as the Associate Chief Allied Health Professional for the Family Heath Care Group at the Trust, attended both parts of the Registrant’s final probationary review meeting along with Ms HR. 

36.    Ms ZBW stated that the Registrant had confirmed to her that she had self-declared on her application for registration that she was proficient in English or words to that effect.

37.    After the meeting on 03 June 2024, Ms ZBW sent the Registrant an outcome letter, informing her that she is dismissed on grounds of capability. It was noted the Trust “cannot sustain the levels of support without further compromising patient care and the existing team”. 

38.    The Registrant appealed the Trust’s decision to dismiss her. This appeal was heard on 10 July 2024. This was unsuccessful. 

39.    On 11 November 2024 the Registrant confirmed to the HCPC that she had not taken the IELTS exam prior to entering the UK.

The Registrant’s written representations dated March 2026

40.    The Registrant made the following assertions:

•    “I did not act dishonestly when completing my HCPC application. I did not intend to mislead the HCPC. If my declaration regarding English being my first language was incorrect, it was made based on my genuine understanding at the time.”

•    “Throughout my career in India, English has been the language of instruction for my education from childhood through university. My professional training, textbooks, clinical discussions, and written examinations were conducted in English. English is also widely used in professional and daily communication in my community”.

•    “Based on this background, I genuinely believed that English could reasonably be considered my first language in the context of my education and professional practice.

I did not understand that the HCPC definition required English to be the primary language used in all day-to-day life circumstances as understood in the UK regulatory context”.

•    The Registrant referred to difficulties which she encountered in adjusting to life and professional practice in the UK. She asserted that she received no formal complaints about her care of patients and much appreciation. She complained that she lacked constructive feedback and guidance.

•    She asserted that she had been unable to afford the IELTS examination.

Submissions on behalf of the HCPC

41.    Ms Rawlings reminded the Panel that international applicants are required to meet the HCPC's English language requirements. At the relevant time, applicants for whom English was not their first language were required to submit a language test meeting the HCPC's requirements. As the Registrant declared that English was her first language, no further enquiries were made and no English language tests were required. 

42.    Clear guidance highlighting the importance of English language proficiency was set out on the international applications page of the HCPC's website at the time of the registrant’s application. The same page set out the circumstances in which an international applicant might declare that English is their first language i.e. if it is the main or only language used on a day-to-day basis.

43.    Ms Rawlings submitted that the Panel could be satisfied that the Registrant knowingly made a false declaration that English was her first language and that, accordingly, she fraudulently procured her entry onto the HCPC register as a Speech and Language Therapist for the following reasons:

•    The Registrant had made a clear and unequivocal declaration that English was her first language. By making that declaration, she avoided having to provide proof of her proficiency in English, which she would have been unable to provide;

•    Clear guidance was provided by the HCPC as to the standards of proficiency required. The Registrant must have been aware that the ability to communicate in the English language was crucial to being able to practise as a Speech and Language Therapist in the UK. The Registrant knew that she was unable to provide proof of her proficiency and was plainly dishonest in declaring that English was her first language;

•    The Registrant had everything to gain by declaring that English was her first language because she thereby secured entry to the register without having to provide any evidence of her proficiency in the English language or pass a test which she would undoubtedly have failed.

•    When applying for employment with the Trust, the Registrant  requested the chat-box facility to be used for the typing of questions from the interviewers, thereby concealing her lack of proficiency in English and further indicating her dishonesty.

•    The Registrant told Ms ZBW that she self-declared her English proficiency, thereby impliedly admitting that she was aware of what she had declared.

44.    With regard to the Registrant’s email and written representations received on 03 March 2026, Ms Rawlings made the following submissions:

•    The Registrant had provided no evidence in support of her assertion that she was unable to attend the hearing “due to a personal emergency involving hospitalisation.”

•    The Registrant was disingenuous when stating in her email “As previously communicated, I have attached my written representations…”. The Registrant had not communicated with the HCPC or Blake Morgan since her email dated 21 August 2025, despite numerous attempts to contact her. At no time previously had she referred to making written representations.

•    The Registrant had given no explanation for providing her representations at such a late stage, when she had known of the date of this hearing since October 2025. The Panel could infer that her previous non-engagement and last-minute communication was calculated and disingenuous.

•    As a result of the lateness of providing her submissions, Ms Rawlings had been unable to put the Registrant’s assertions to any of the witnesses called on behalf of the HCPC to test their veracity nor did Ms Rawlings have the opportunity to cross-examine her.

•    The Registrant’s assertion that her entire education and professional training had been conducted in English did not, as the HCPC guidance made clear, justify her declaration on the application form that English was her first language.

•    The Registrant gave no explanation for having indicated in the relevant section of the application form that she had some “other” proof of her proficiency in English. Her assertion that she had not yet been able to afford the IELTS examination due to financial hardship demonstrated that she had not prioritised it. Her submission was that accordingly limited weight should be attached to the Registrant’s submissions.

Decision

45.    The Panel took account of the evidence in the case alongside the Registrant’s written representations and Ms Rawlings’s submissions on behalf of the HCPC.

46.    The Panel had regard to the HCPTS Practice Note on “Making decisions on a registrant’s state of mind” and accepted the advice of the Legal Assessor.

47.    The Panel noted that the standard of proof required is on the balance of probabilities. In other words, the Panel must be satisfied that any act alleged is more likely than not to have occurred before it can find it proved. The burden of proof is on the HCPC in respect of the factual particulars.

Particular 1 - Proved

48.    The Panel noted that the Registrant admitted Particular 2 of the Allegation in that her entry was incorrectly made in declaring that English was her first language. Therefore, the only issue is whether she was dishonest in so declaring and thereby fraudulently procured her entry onto the HCPC register.

49.    The Panel was satisfied that, when applying for entry to the HCPC as a Speech and Language Therapist, the Registrant would have been aware of the importance of proficiency in the English language. She must also have been aware that English was neither her first nor her main language. 

50.    Section 5 of the application form is headed “English language proficiency”. It continues:

“Please refer to the standards of proficiency. Every registrant must ensure that they can communicate effectively with patients, clients, carers and other professionals.

Is English your first language? You should only indicate that English is your first language if it is the main or only language you use on a day-to-day basis. Having studied English or undertaken education or training at an institution where the medium of instruction is English does not necessarily mean that English is your first language.

If no, you must provide proof of your English proficiency. Please refer to guidance notes for details of recognised language tests and the minimum acceptable scores”.

51.    The Registrant ticked the relevant box to indicate that English was her first language and was therefore not required to provide proof of her English language proficiency.

52.    In her written representations, she sought to justify this by stating that “my entire education was delivered in English, my professional degree and training were in English, and English is widely used in my daily and professional communication in India”. The Panel noted that, at the interim order hearing on 24 November 2024 the Registrant stated that “In India I used to speak Telegu so that is my native language”. 

53.    Although the Registrant also indicated in the relevant section of the application form that she had some “other” proof of her English proficiency, she did not indicate what other proof she had and has not subsequently provided any such proof.

54.    Section 7 of the application form contained declarations, which the Registrant signed, including the following:

“I confirm that the information I have provided in this application is correct and understand that fraudulently procuring an entry in the HCPC register is a criminal offence”.

55.    Section 7 also contained a checklist to be completed before submission of the application, including requiring the applicant to confirm that they had “read the guidance notes to this application form”. The relevant guidance on “Certificate of English language proficiency” at the time set out that,

“Every international applicant must provide a certificate with their application, unless they are

•    A native English speaker for whom English is their first language.”

56.    In the Panel’s judgement, the information provided by the application form, and by the HCPC’s guidance on the website for international applicants, was clear as to what was being asked of the Registrant. She could not have been in any doubt that she was being asked whether English was her first language, in other words her native language. She indicated that it was and made a declaration that the information provided was correct. In fact, the information which she provided was false and she must have realised that it was untrue, when signing the declaration.

57.    The Panel accepted the evidence of Ms ZBW that the Registrant had told her that she had self-declared that she was proficient in the English language.

58.    The Panel considered that it could attach very little weight to the Registrant’s written representations for the following reasons:

•    She had provided no explanation for submitting her representations at such a late stage in the proceedings and after closure of the HCPC’s case;

•    She had provided no evidence in support of her assertion that she was unable to participate in the hearing due to “a personal emergency involving hospitalisation”;

•    Her representations were not supported by a statement of truth, nor could they be tested in cross-examination;

•    Her assertion that she thought English was her first language because it was the language of her education and professional training was contrary to the clear guidance contained in the application form which she completed and to her assertion at the review hearing on 12 November 2024 that Telegu was her native language.

•    The unchallenged evidence of Ms Rossol was that the Registrant’s proficiency in English was of such a standard that she was unable to communicate effectively with patients and colleagues

•    The Registrant’s lack of proficiency in English resulted in her dismissal on grounds of capability, given that the Trust “cannot sustain the levels of support without further compromising patient care and the existing team”.

59.    The Panel was satisfied that the Registrant knowingly made a false declaration on the application form that English was her first language and that she intended to deceive the HCPC in order to procure registration. The Panel was satisfied that, taking account of the Registrant’s understanding of the circumstances, an ordinary, decent person would find the Registrant’s conduct to have been dishonest. The Panel thereby determined that the Registrant fraudulently procured her entry onto the HCPC as a Speech and Language Therapist. 

60.    Having found Particular 1 proved, the Panel did not go onto consider Particular 2 as this was in the alternative.

Decision on order

61.    The Panel took into account the written representations of the Registrant and the submissions of Ms Rawlings.

62.    The Panel had regard to the HCPTS. Practice Note on “Fraudulent and Incorrect entry”. The Panel also took into account the HCPC’s Sanctions Policy in respect of its guidance in identifying the nature and seriousness of regulatory concerns.

63.    The Panel was aware that, by way of disposal, it could:

•    make no order;

•    amend the register: or

•    remove the Registrant’s entry from the register.

64.    In determining the appropriate option for disposal, the Panel had regard to the HCPC’s statutory objective to protect the public, which included promoting and maintaining public confidence in the profession and maintaining proper professional standards and conduct on the part of the profession.

65.    With regard to public protection, the Panel concluded that the Registrant was not safe to practise as a Speech and Language Therapist because she lacked the necessary proficiency in the English language. This was demonstrated by the evidence of Ms HR, who stated that, during the 8 months’ probationary period of the Registrant’s employment with the Trust, she was unable to communicate effectively with patients, their families and professional colleagues. This had a negative impact on service users, who asked not to be seen by the Registrant. It was also noted that the Registrant was unable to transcribe correctly and recorded incorrect information. The ability to communicate effectively with service users and colleagues is a fundamental requirement of a Speech and Language Therapist, the absence of which had the potential to result in significant harm to service users in not receiving correct or timely care and treatment. 

66.    In the absence of any evidence that the Registrant had subsequently acquired the necessary proficiency in English, the associated risks must inevitably continue. It follows that making no order would fail to address the need to protect the public. In these circumstances, the only appropriate order was to remove the Registrant from the register.

67.    The Panel also considered that public confidence would be seriously undermined if the Registrant remained on the register for the following reasons:

•    Her entry on the register was fraudulent and procured by a dishonest declaration to the effect that English was her first language. Dishonesty on the part of a registrant is a breach of a fundamental tenet of the profession and must inevitably undermine public trust. 

•    The Registrant has continued to maintain her protestations of having made an innocent mistake, which the Panel has rejected. In the Panel’s judgement, the Registrant remains untrustworthy.

•    The Registrant did not have the essential proficiency in the English language to merit entry onto the register as a Speech and Language Therapist. For an unqualified person to be permitted to practise in that capacity would further undermine public confidence in the register and the profession.

•    The absence of any evidence that the Registrant has done anything to acquire proficiency in English since the termination of her employment by the Trust in November 2024 demonstrates an absence of commitment to practise as a safe an effective member of the profession.

68.    The Panel therefore determined that the necessary and proportionate order was the removal of the Registrant’s entry from the register. 

ORDER: The Registrar is directed to remove the name of Ms Sai Keerthana Sriperambuduru from the Register on the date this order comes into effect.

Interim Order

1.    Ms Rawlings on behalf of the HCPC made an application for an Interim Suspension Order for a period of 18 months to cover the appeal period or until any appeal lodged has been determined. 

2.    The Panel accepted the advice of the Legal Assessor.

3.   Given the Panel’s findings that the Registrant’s fraudulent conduct in procuring registration and her lack of proficiency are fundamentally at variance with remaining on the Register and an order has been made for her removal from the register, it would be inconsistent with the need for public protection and the wider public interest not to impose some form of interim order. Given that the Registrant lacks the necessary proficiency to be on the register interim conditions of practice would not be appropriate or relevant.

4.   The Panel therefore makes an Interim Suspension Order under Article 31(2) of the Health Professions Order 2001, the same being necessary for public protection and otherwise in the public interest.

This Order will expire: (if no appeal is made against the Panel’s decision and Order) upon the expiry of the period during which such an appeal could be made; (if an appeal is made against the Panel’s decision and Order) on the final determination of that appeal. This Interim Suspension is for a period of 18 months.

History of Hearings for Sai Keerthana Sriperambuduru