1. Routine data sharing
2. Emerging and urgent concerns
3. Local regulatory alignment
4. Risk and quality summits
5. Strategic collaboration
Annex 2: Information sharing with the GMC
Annex 3: Information sharing with CQC
Annex 4: Potential illegal practice
A number of issues may arise within a healthcare environment which indicate potential fitness to practise concerns or have adverse effects on the education and training that takes place there.
Some examples with outcomes intended as guidance are presented below. Professional judgment and consideration of the broader situation should be applied at all times:
Concerns in this case were sufficient to warrant a responsive inspection.
Concerns include:
- lack of confidentiality for patients
- poor recruitment of staff
- repeat prescriptions being written with
- no review
- potential fraud.
Rationale
This raises potential fitness to practise concerns regarding the doctor.
What will information be used for?
To inform the GMC investigation process.
It finds the provider is below the required standards in a number of areas and requires improvements. Warning notices are issued.
Concerns include:
- inadequate records
- failure to refer when urgent referral was indicated
- out of date vaccines
- poor hygiene.
Rationale
Possible referral as these issues may signify poor practice.
What will information be used for?
To inform the GMC investigation process and notify the local NHS area team.
During the course of an inspection, the team is told by several members of staff that one of the doctors is persistently very late for work - making weak excuses but expecting others to cover. They believe this is because she has a chaotic home life with no fixed child-minding arrangements.
Rationale
This is unlikely to be a GMC referral issue as the doctor’s fitness to practise is not significantly impaired. Nevertheless some action should be taken as behaviour is disruptive to the department. The medical director should initiate appropriate action.
What will information be used for?
If initial action by medical director does not resolve issues, the concern could be referred to the GMC.
After a focus group of doctors in training, one of them requests a 1–1 meeting. At this meeting he mentions his concerns about the performance of one of his consultants. He says that he has witnessed him operating in a way that he has never seen before, being aggressive with instruments and panicking at the resultant blood loss.
Rationale
This requires urgent action by the trust medical director. Patient safety is at risk. If there is sufficient evidence to support the concern then an interview with the surgeon may result in suspension from operating pending further investigation. If he fails to engage then GMC referral may be needed.
What will information be used for?
If initial action does not resolve issues, this concern could be referred to the GMC.
During an interview a midwife says she has concerns about an obstetrician who is carrying out exposure prone procedures and whom she believes has a chronic viral infection that could be transmitted to patients. She is concerned that the obstetrician realises he has been recognised and he is looking to move on to another job elsewhere.
Rationale
The medical director needs to interview the doctor to establish the facts. Did they make a false declaration on their occupational health questionnaire? The concern here is that if this doctor persistently moves on then they may present a risk to other patients.
What will information be used for?
In such cases, referral to the GMC should be considered to inform the investigation process.
An approved mental health practitioner (AMPH) raises a concern in a focus group relating to a section 12 doctor not employed by the trust who is repeatedly rude to both service users and other members of the assessing team. There have been several incidents when the doctor has shouted at the assessing AMPH if his clinical judgement is questioned or errors in his paperwork are pointed out.
Rationale
This should initially be referred to the medical director of the trust for initial investigation and consideration of referral to the GMC. CQC does have a more direct role here however as it has a statutory role in the review of the performance of the Mental Health Act.
What will information be used for?
If there were sufficient concerns that weren’t being directly addressed by the trust medical director after referral then there is a need for CQC to share with the GMC.
A GP practice has been put into special measures by the CQC after being rated as inadequate for 'being safe, effective, caring, responsive and well-led.' There may be medical students and doctors in training who are on placements at this practice.
Rationale
This raises potential education and training concerns.
What will information be used for?
To help us work with the local education and training board (LETB) and the medical school to determine whether the practice remains an appropriate environment for education.
On a CQC visit, the inspectors identify the following: Foundation doctors in surgery described signing discharge letters that have been written by other doctors and relate to patients they have never examined. One foundation doctor has also prescribed antibiotics for a patient they have not examined because of pressure placed on them by a nurse.
Rationale
This raises potential patient safety and undermining and bullying concerns.
What will information be used for?
To take immediate action to ensure Foundation doctors are not pressured to work beyond their competence.
On a CQC visit the inspectors identify that adequate checks to ensure staff are properly qualified and able to do their job are not being carried out before employing staff, including locum doctors who may have to fulfil a supervisory role for doctors in training.
Rationale
This raises potential education and training concerns, including supervision and patient safety.
What will information be used for?
To take immediate action to ensure supervision of doctors in training is safe and effective.
On a CQC visit the inspectors identify the following: doctors in training are not being provided with learning opportunities that are required in order for them to progress. They are often charged with taking blood samples and catheterising patients because there is no phlebotomy service and nursing staff are not able to undertake basic clinical skills.
Rationale
This raises potential concerns of trainee progression and patient safety concerns.
What will information be used for?
To work with HEE to ensure that doctors in training are undertaking tasks with educational value.
CQC inspects an online primary care provider. It finds that standards are below the required standards in a number of areas. Concerns include:
- lack of identity checks for patients
- no system or process to contact the patient’s regular GP / Inadequate steps taken to seek consent to share information
- inadequate steps for ensuring that patients understand and consent to their prescribing treatment/medical advice
- inadequate steps for taking a patient’s medical history to inform appropriate prescribing through their online questionnaire.
There is also limited evidence that large numbers of prescriptions are being processed in a short time, raising cause for concern.
Rationale
The inspectors raise concerns about the fitness to practise of the GMC-registered doctors involved due to a pattern of prescribing opioids where they did not have sufficient verified information to do so safely.
What will information be used for?
The GMC will need the names of the GMC-registered doctors involved and medical records for each doctor and patient encounter of concern to inform its investigation process.
Snippet for joint working with GMC
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Joint operational protocol between CQC and the General Medical Council