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Complaints; The PCT; NCAS; GMC; Revalidation


Complaints; The PCT; NCAS; GMC; Revalidation Dr Eric Saunderson Medical Director, NHS Barking and Dagenham Objectives for today Understand the roles of the following ... – PowerPoint PPT presentation

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Title: Complaints; The PCT; NCAS; GMC; Revalidation

Complaints The PCT NCAS GMC Revalidation
  • Dr Eric Saunderson
  • Medical Director, NHS Barking and Dagenham

Objectives for today
  • Understand the roles of the following
    organisations in complaints against GPs
  • The Medical Director the PCT NCAS the GMC
  • Have a clearer understanding of the new agenda of
    revalidation enhanced appraisal 360 degree
    appraisal the Responsible Officer
  • Discuss complaints and their management consider
    how to minimise complaints or deal with them in a
    professional manner

The PCT Complaints procedure
  • Patients complain directly to the PCT Complaints
  • The PCT receives between 30 - 50 complaints
  • Complaints about staff attitudes are common
  • Complaints about quality of GP treatment are the
    most common
  • Some complaints involve several issues e.g.
    clinical treatment, pharmacy, attitude, delayed
    referral, etc

What happens in the Complaints Dept?
  • Sympathetic acknowledgements are sent to
    complainants explaining the PCT/NHS Complaints
  • The complainant is asked to agree to the PCT
    contacting the doctor
  • The doctor is asked for his side
  • The doctors response is made available to the
    complainant this may resolve the issue
  • If not, the complainant is offered conciliation
    or referral to the NHS Ombudsman

The Complaints Dept
  • The Medical Director acts as an advisor to the
    department, usually for clinical grounds but also
    if there are several complaints against one
    particular practice
  • Anonymous complaints arise from time to time.
    The PCT has an agreed policy with the LMC in
    dealing with these
  • Sometimes, the Medical Director will write
    directly to the GP or may visit

The Ombudsman
  • Undertakes an independent investigation into the
    complaint using letters
  • Both sides are asked to produce statements
  • The Ombudsman is advised by appropriately
    qualified clinicians
  • The findings are made known to the complainant
    and GP
  • Many complaints are not upheld against GPs
  • Note keeping is a common identified issue lets

Complaints and the Medical Director
  • Tend to be more serious
  • Arise from the Complaints Dept directly from
    patients or relatives may arise from the local
    MPs are communicated from colleagues both
    specialists and GPs may be brought to the
    attention of the PCT from the GMC or other
    agencies e.g. Adult or Child Safeguarding
  • The Medical Director has a range of options from
    a quiet word to something more coercive!

The Performance Decision-making Group
  • A subcommittee of the Governance Group
  • Has a NED Chair, CE, MD, solicitor, CG, GP
  • Considers all serious complaints
  • Provides guidance to the MD for investigations
  • Investigations tend to be undertaken by an
    outside agency for more serious complaints

Example 1
  • A single handed GP with a list of 2,000 visited
    an elderly patient with abdominal pain. He did
    not take notes with him. He had only recently
    been employed in the practice. The patient had a
    PH of AAA. The doctor was told this by the
    patients daughter. The doctors diagnosis was
    constipation. The patient died shortly after the
    visit. The daughter complained to the Healthcare
    Commission. Their investigation showed poor
    record keeping. The PCT was informed.
  • What would you do?

Example 2
  • A mother complained to the PCT that her doctor
    had seen her one year old son with otalgia. At
    the end of the consultation, the patient asked
    the doctor to look at the childs BCG vaccination
    site as it seemed swollen. The doctor looked at
    the childs arm from some distance and stated it
    was fine. The next morning the childs arm was
    discharging. The patient took her child to a WiC
    and was prescribed appropriate antibiotics. The
    mother made a complaint to the PCT stating the
    doctor was uncaring, had a poor attitude and had
    not taken the complaint seriously and
  • How would you manage this scenario?

Example 3
  • A single handed GP had an adverse sickness
    record. He had various periods of sickness,
    including prolonged periods when a locum
    allowance was claimed. He employed various
    locums to run his practice and a series of
    complaints gradually built up due to the lack of
    continuity. He returned to work for a short
    period then went off sick again. He was aged 62.
  • What thoughts do you have for managing this

National Clinical Assessment Service
  • Set up in 1995 to provide information and
    investigation of doctors
  • Provides a guidance service for PCTs
  • Suspension of a doctor must be discussed with
    NCAS first
  • Have specially trained clinical advisors
  • A doctor can be referred to NCAS for further
    investigation in three parts occupational
    health psychological assessment clinical
  • Detailed reports provided to the PCT support,
    action planning, remediation

  • The national regulator
  • gt80 of complaints referred to it are returned
    to the PCT for further management
  • Of the several thousands of complaints, lt 20 per
    year are career threatening
  • Of those referred by PCTs, or the more serious
    complaints, screening occurs first. A large
    proportion are rejected.
  • The remainder are referred to the Fitness to
    Practise committee

  • Full investigation includes MCG simulated
    surgery. Then,
  • 2 days observation of practise similar to NCAS
  • Detailed report written following GMC guidance
    in Good Medical Practise Patient welcome,
    history taking, problem solving, treatment and
    management probity
  • Appearance at the Panel. Legal representation.
  • Most doctors found with impairment will have
    conditions placed on their registration and
    will undergo remediation

  • Tailored to the doctors individual needs
  • Reappearance at the FTP following an appropriate
  • Removal of conditions
  • Other sanctions
  • Good time for tea?

  • Why?
  • Shipman
  • Dame Janet Smith
  • Liam Donaldsons report Good doctors, safer
    patients 2005
  • Much discussion between the GMC, BMA and Royal
  • RCGP is the responsible College for GPs,
    regardless of membership
  • Look at the RCGP website for more information
  • Starts 2011

What does the legislation say?
  • In order to remain on the Medical Register, each
    doctor must revalidate every 5 years. This
  • Annual appraisal this is to be enhanced
  • Multi source feedback (360 degree appraisal) x 2
    in 5 years
  • Statement from PCT MD that there are no
    unresolved performance issues

What is the evidence portfolio?
  • See for the current
    appraisal portfolio this will be developed and
  • Evidence will be the most important development,
    moving appraisal away from rhetoric and anecdote.
    It will comprise
  • Professional roles and basic details
  • Statement of exceptional circumstances
  • Evidence of annual appraisal
  • PDP each year
  • MSF x 2
  • Patient feedback

Portfolio contd
  • Causes of concern and/or formal complaints
  • Significant event audit
  • Clinical audit 2 completed cycles in each 5
    yearly cycle
  • Probity and health
  • Extended practice eg. GPwSI, VTS, teaching,
    research, medical management
  • The non standard portfolio

The non-standard portfolio
  • This could apply to locums or those working less
    that FT
  • Doctors with no clinical practise for 5 years
    will not be recertified
  • The doctors working environment provides the
    revalidation context
  • Minimum standards
  • Annual appraisal and PDP in at least 3 out of 5
  • 50 learning credits in each of the 3 to 5 years
  • Documentation of at least 200 clinical half day
    sessions (1 day weekly)
  • Registrars The MRCGP will satisfy revalidation

Learning credits
  • Each doctor will require a minimum of 50 annual
    learning credits, 250 for the 5 yearly
    revalidation cycle
  • 1 credit 1 hour of learning lecture, reading,
  • If learning leads to changes for patients, the
    doctor or the practice, the GP can claim 2
  • These credits will be challenged by the appraiser
    or Responsible Officer and will need defending.
    The challenge could be due to too many credits
    claimed or too little

The Responsible Officer
  • A new role. Likely to be the MD
  • Has responsibility to the GMC
  • The annual appraiser informs the RO that a
    particular doctors annual appraisal is
    satisfactory. Every 5 years, this would be
    satisfactory for revalidation provided the other
    components are satisfactory too
  • The RO will have access to the appraisees/appraise
    rs confidential appraisal documents

Key personal responsibilities
  • The appraisee must demonstrate to the appraiser
    that he/she is fit to practise
  • The appraiser has the responsibility to approve
    the appraisal, or not
  • Appraisees who are in difficulty must communicate
    with their appraiser or RO and seek help and
  • The GMC recertifies the doctor for the next 5
    yearly cycle
  • Finally, there are nationwide pilots at present.
    These will report to the National Revalidation
    Board in order to determine best practise