Health commissioners ‘failed’ to assess risks of closing homeless GP practice

Health commissioners failed to properly assess risk when closing a homeless GP practice, an independent whistleblowing review has found.

The Hunter Street homeless practice, which was run by the local health board as part of a homelessness health service, was closed by the Glasgow City Health and Social Care Partnership (HSCP) in 2023.

Following the closure, a representative group for GPs working in deprived areas of Scotland raised concerns about the decision and called for the practice to be reinstated.

Now the Independent National Whistleblowing Officer (INWO) – the final reviewer for concerns raised about the NHS in Scotland – has announced its decision to uphold a whistleblowing complaint about the GP practice closure. 

Its independent report found that local health commissioners ‘failed to follow a meaningful process of engagement’ with staff and ‘failed to undertake meaningful stakeholder consultation’. 

The investigation revealed the move to close the practice was a ‘unilateral decision’ rolled out ‘hastily’ by the HSCP as a result of pressured finances rather than based on feedback from staff. 

It criticised the lack of external engagement about the potential of the practice closing, noting that local GP practices and the third sector ‘expressed their shock and concern’ when the closure was announced.

On risk, the INWO also upheld the whistleblower’s concern that the HSCP ‘failed to perform a full and timely’ risk and equalities impact assessment, or to ‘address the long term risks’ associated with closing the homeless GP practice.

The independent investigator said: ‘I agree with [the complainant] that by the end of the staff engagement workshops it was difficult to take the view that it was a meaningful process. 

‘The final decision was rushed and rolled out hastily, apparently as a result of the change to the financial position, rather than in the context of the output of the [GP engagement] workshops.’

The first announcement to staff about plans to close the homeless GP practice was made in March 2022, and it was eventually closed in April the following year, after HSCP had held three workshops with GPs working at the practice just weeks before.

Prior to this, there had also been a wider review of the entire homelessness service in Glasgow which resulted in the formation of a single, interdisciplinary team operating across the patch. 

The INWO also said they had ‘not been convinced that any further consideration was given to exploring an alternative beyond the HSCP’s preferred option’.

In response to the whistleblower’s concerns about proper impact assessment, the INWO found that both the equalities impact assessment (EQIA) and the risk assessment were completed only after the decision to close the GP practice had already been made. In the case of the EQIA, this approach runs counter to both national and the HSCP’s own internal guidance. 

The investigator said: ‘The complaint I have investigated is that the HSCP unreasonably failed to perform a full and timely assessment of risk and equalities impact prior to the decision to reduce specialist GP service provision for people experiencing homelessness.

‘In relation to risk assessment, it appears that the only documented risk assessment that took place was completed after the decision was taken to close the practice. 

‘This was only a matter of days before the practice closed. Although this risk assessment did inform mitigation of the immediate challenges and risks posed by the imminent closure, there does not appear to be evidence of any thorough or systematic consideration of the risks prior to the decision.’

The investigation also raised concerns about the lack of impact assessment on other NHS services, since all patients registered at the homeless practice were moved to local practices.

It accepted advice from an expert who said that local GP practices ‘might not be ready to accommodate the volume or intensity of care that homeless persons require’, since many of these patients ‘will likely have chronic conditions, mental illnesses, and substance use disorders’.

At the time of the practice’s closure, there were 167 registered patients, but GPs at the practice also dealt with a larger number of patients on a temporary basis, with annual patient contacts reaching around 600.

Following the closure of the practice, the GP staffing requirement across the service was supposed to reduce from 1.4 whole-time equivalent (WTE) to 0.2 WTE – but the INWO noted that as of April this year, this time has still not been allocated to a GP. 

HSCP told Pulse that it has agreed with the recommendations within the INWO report.  

A spokesperson said: ‘We note the findings of this report and as a continuous learning and improving organisation will take time to consider the recommendations.  

‘In terms of our current homelessness provision, we have in place well-established governance arrangements and continue to develop services for those impacted by homelessness despite increased demand and a challenging financial climate.’