The new guidance is designed to help practices draw a line in the sand on the services they should be providing, and comes after Pulse revealed in April that hospitals were using ambiguities in practice registration rules to pressure GPs to treat inpatients.
The GPC has raised concerns with the Department of Health over a series of incidents that blurred the boundaries of clinical responsibility, with one LMC reporting that GPs had been asked to treat severely ill patients in a privately-run rehabilitation centre.
The guidance says: ‘The GPC has been made aware of GPs being asked to provide services to patients residing in institutions or homes where the types of services expected do not fall under the responsibility of primary care.
‘There appears to have been an increase in the number of such cases recently, seemingly in part due to an increase in the number of privately-run secondary care institutions.
‘This is not in patients’ best interests as it results in confusion and lack of clarity over who is clinically responsible for patients’ care, as well as a risk to patient safety.’
It says that GPs are unlikely to be responsible for patient care if the institution is registered with the CQC as a hospital (in England), or if GPs are not responsible for the clinical care being provided by secondary care professionals.
It says GPs would also not be responsible if hospital medication or documentation is used in the institution, if the institution is secure and staffed by psychiatric nurses or if care has historically been provided by secondary services and funded out of a secondary care budget.
GPs are also told they should be responsible if the indemnity they have or are expected to have does not extend to the type of care in question, and are urged to consult their medical defence organisation if in any doubt.
The guidance adds GPs are likely to be responsible for patient care if‘the residents fall into the practice’s geographical area and,in England, the institution is registered as a care home by the CQC and is not registered as providing hospital services.’
In providing care, it says GPs must always ‘recognise and work within the limits of their professional competence, consult colleagues if they have any concerns (for example, LMC officers, colleagues in the practice or medical defence organisation advisers), be competent when making diagnoses and when giving or arranging treatment and ensure they are properly indemnified for the services provided’.
It concludes: ‘GPs should not allow themselves to feel morally blackmailed or contractually threatened to provide services beyond their level of competence.’
Dr Richard Vautrey, GPC deputy chair, said the guidance had been launched to try and establish firm ground rules for work being transferred to GPs.
He said: ‘We have had some situations where patients have actually been inpatients in long-stay or semi long-stay institutional arrangements, but have still been inpatients and have been seeking access to primary care or GP services as well.
‘It’s just being clear for patient safety reasons that GPs don’t get caught up in providing care in situations that would be inappropriate.’
Dr Vautrey said the guidance would also be useful in situations where patients are being looked after in the community, despite the situation requiring specialist input, and it is inappropriate for GPs to be providing that under GMS arrangements.
Indicators of whether GPs are responsible for patient care
Is there a consultant or other non-primary care doctor with clinical responsibility for the patients/residents?
Does any consultant or other hospital doctor act for the patients/residents, and is this at the GP’s sole invitation?
What are the historical care arrangements?
Are there often instances where the level of care required is above that which would normally be provided by GPs?