Further to earlier communications from the LMC on 24 April and 7th May, as copied below, we have now received a message from Dr Patel stating that the Area Team medical directorate will no longer be requesting that practices send in details of all their complaints. We have asked Dr Patel to write directly to all practices confirming the change in position.
Other concerns in respect of appraisal and revalidation processes will be discussed in a meeting with the medical directorate.
Further to my email to Dr Patel as copied below in respect of the attached letter a meeting will now take place between the Area Team and the area’s LMCs in order to discuss the issues involved.
In the meantime however the position remains that there is no requirement under the complaints regulations to send in details of all complaints and responses to the Area Team, nor does the LMC believe that this is information that can be reasonably required to be provided under the GP contractual regulations, and it is most certainly over and above normal appraisal and revalidation requirements.
From: Lmc Birmingham (NHS MIDLANDS AND LANCASHIRE COMMISSIONING SUPPORT UNIT) [mailto:firstname.lastname@example.org]
Sent: 24 April 2015 10:38
Subject: Important - GP Appraisal and Revalidation - INFORMATION FROM THE LMC
Please see below email sent to Dr Kiran Patel Medical Director NHS England, from Dr Morley for your information.
I gather that you have sent the attached letter to all GPs in the new merged area team.
I have a couple of major concerns.
Firstly in respect of Significant Event Analyses - you are stating that GPs must analyse two significant events each year and discuss them in detail at appraisal. Whilst the GMC guidance states that all significant events on which the doctor was involved should be recorded at appraisal it does not specify any arbitrary number of SEAs and indeed states “You may not have logged any events regarding you or your team in a given appraisal period.” Whilst not having any relevant significant events since the previous appraisal might be an exceptional situation, it cannot be appropriate that your requirements conflict those of GMC. It may be that there has been conflation with the RCGP guidance which states: “At least two quality improvement activities are required each year. These can be significant event analyses/individual case reviews in which you have had a personal involvement.”
I’d appreciate your clarification of this.
Secondly you are requesting that GPs send you details of ALL complaints and responses to complaints. Practices are, of course, obliged to send NHS England an annual return of complaints numbers; as this is specified in the NHS complaints regulations then it is a contractual obligation. However I am not aware of any legislation or regulation which obliges GPs to send full details of all complaints and responses to their responsible officer, and if there is anything I am not aware of that makes this a requirement then I’d be most grateful if you could let me know, otherwise, whilst I appreciate the rationale behind it, it does strike me as being an excessive and unreasonable request. There are also enormous practical difficulties in terms of redacting patient ID (or obtaining consent to share of course) and the vast majority of complaints tend to relate to issues of a managerial or administrative nature of no relevance to professional performance. I would therefore request that you reconsider this matter. As you do point out, it is appropriate for GPs to discuss their complaints with their appraisers.
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