Policy responses and statements
Background: The GMC's core guidance booklet, Good Medical Practice, sets out the principles of good practice and the standards of professional conduct expected of doctors. While addressed to doctors, it is also intended to give the public an understanding of the standards they can expect of doctors. As part of the revision of the current Good Medical Practice, an extensive consultation process was conducted. Following the consultation process, the principles to be in the new edition of Good Medical Practice have been identified and the text of Good Medical Practice is currently being redrafted to reflect this. The purpose of consulting on supplementary guidance is primarily to test its clarity, accuracy, practicality and relevance, rather than to revisit the questions of principle covered in the consultation on Good Medical Practice. This consultation is about new pieces of supplementary guidance for doctors to be published with the new edition of Good Medical Practice, as follows: - Raising concerns about patient safety COMMENTS ON The Royal College of Physicians of Edinburgh is pleased to respond to the General Medical Council on its consultation of the Good Medical Practice SupplementaryGuidance. RAISING CONCERNS ABOUT PATIENT SAFETY Q.1 How clear is the Guidance? Clear. Q.2 Is the guidance helpful in explaining the relevant paragraphs in Good Medical Practice? Yes. Q.3 Are the other issues on raising concerns you think the guidance should cover? No. Q.4 Are you aware of information published by other organisations on raising concerns? Local healthcare organisations will have adverse incident and “whistle blowing” policies, and it would be helpful to remind doctors to be aware of their local arrangements. Other organisations are listed in the guidance and should include the different agencies in the devolved administrations. Q.5 As other organisations publish information on raising concerns, is it helpful for the GMC to also publish guidance on this? Yes, providing it is cross-referenced to other sources and any contradictions are removed or highlighted. Q.6 Do you have other suggestions for who is the best person to approach within an organisation when raising concerns? It may be helpful to have more specific guidance for doctors in training, advising them to approach education or clinical supervisors first and then move up the line through their Head of departments, Medical Director and, if appropriate, the Postgraduate Dean. Trainees may also find it helpful to alert senior nursing colleagues to issues. Q.7 Any other comments The guidance emphasises the importance of taking these difficult decisions despite personal feelings of guilt or concerns about victimisation. Patient safety is paramount. MAINTAINING BOUNDARIES Q.1 How clear is the Guidance? Clear. Q.2 Is the guidance helpful in explaining the relevant paragraphs in Good Medical Practice? Yes. Q.3 Do you agree with the statement that “Pursuing a sexual relationship with any former patient will usually be inappropriate” No. As a bold statement, applicable to all patient groups, this will be difficult for some doctors, particularly when the full sentence in the guidance is considered: Pursing a sexual relationship with any former patient will usually be inappropriate, regardless of the length of time elapsed since the therapeutic relationship ended. There will be circumstances, particularly perhaps for doctors practising in primary care and living in more remote communities, where relationships are established with potential or former patients. However, it is vital that these doctors consider carefully the implications of such a relationship, particularly where the patient may vulnerable through dependence or (previous) psychiatric illness. Q.4 Is the guidance on offering chaperones reasonable? No. The definition of a “trained chaperone” is unclear - is this a clinically trained person or someone with awareness of the duties of a chaperone? Some doctors are concerned that the presence of a chaperone may on occasions damage the patient-doctor relationship Also, the practicalities of delivering this are of concern within busy clinics and GP surgeries. Once published, this becomes an expectation of patients and may give rise to complaints against individual doctors who may be unable to arrange necessary staff to provide a suitable chaperone. Q.5 Do you have any suggestions on arrangements other than chaperones that could provide adequate protection for patients and doctors? Reinforcing the importance of informed consent for intimate examinations and making more information available generally to patients about normal practice may help alert patients to inappropriate contact and protect doctors from inappropriate complaints about conduct. CONFLICTS OF INTEREST Q.1 How clear is the Guidance? Clear. Q.2 Is the guidance helpful in explaining the relevant paragraphs in Good Medical Practice? Yes. Q.3 Are there other potential conflicts of interest for doctors for which guidance from the GMC would be helpful? Yes. Doctors in private practice must be able to justify all diagnostic tests and procedures undertaken in a private facility. Q4. Do you have any further comments about the guidelines? Further explanation may be helpful about ownership of unit trusts where the level of investment in specific companies may not be known. Paragraph 6 could be interpreted as excluding some patient referrals inadvertently eg referrals for staff, and the section might be improved by linking it specifically to private specialist practice. Paragraph 12 makes a statement without advising doctors on their responsibilities whether as a meeting organiser, speaker or delegate. It may be useful to insert a new heading before paragraph 17 to separate the issues of “Sexualised Behaviour” and “Duty to Report”. Also, paragraph 17 would be strengthened by reminding doctors of their duty to report sexualised or other otherwise inappropriate behaviour. REPORTING CRIMINAL AND REGULATORY PROCEEDINGS WITHIN AND OUTSIDE THE UK Q.1 How clear is the Guidance? Unclear (in places). Q.2 Is the guidance helpful in explaining the relevant paragraphs in Good Medical Practice? No. The definition of a minor driving offence would be useful eg what would be the reaction be to a fine for careless driving? Motoring offences involving driving under the influence of drugs should specify illicit and prescription drugs. Confirm that fixed penalty fines need not be reported. Q.3 Do you have any other comments about this guidance? Typo in paragraph 2 - the word “is” is missing
Copies of this response are available from: Lesley Lockhart, Tel: 0131 225 7324 ext 608 [17 July 2006]
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