The General Medical Council – GMC regulatory fitness to practise investigations
A GMC Fitness To Practice Guide For Families
From a families perspective, this process is legalistic, adversarial, costly on your health, mind and body. All families, patients and carers ever want is openness, transparency and the truth. Overwhelmingly, the wish and desire remain the same, to find answers to extremely traumatic situations which led to catastrophic outcomes for loved ones. We (the families) do not set out to destroy careers, get professionals struck off the medical register or bear malice.
Medical professionals spend many years qualifying
As the patients, Father, I have been far to busy caring for my daughter over four years to concentrate on someone else who may or may not have made a medical error. I am also mindful clinicians and nurses have studied and worked hard to achieve their status. I still have a great deal of respect for their profession, but also know they do make mistakes.
What led me to approach the GMC, NMC, CQC and PSA (the Regulators)
In the initial stages after the incident, I asked The Ipswich Hospital NHS Trust what had happened to my daughter and continued to ask the most obvious and pertinent questions any parent would ask after such a catastrophic incident. I had meetings with the Hospital staff multiple times. My concerns about my daughter’s treatment and care ‘patient safety’ were met with defensive denials, complete refusal and utter contempt. The suggestion that things had ‘gone wrong‘ or one of ‘their own had made a mistake‘ was not up for debate. Save for a few consultants who were very open and honest about ‘what they thought had happened.’
The first stage after any Serious Incident is an Investigation
Investigation one The Hospital concluded my daughter’s incident in A&E was a serious incident requiring investigation (SIRI). This was back in 2015, just two days after she attended on a Sunday evening. The Hospital failed to investigate my daughters incident properly and I had to go to the Ipswich and East Suffolk Clinical Commissioning Group (IESCCG) and make a formal complaint about the standard of the first investigation. The commissioners agreed to commission an independent review of the first investigation.
Investigation two The independent report said, “The Trust lacked the professional curiosity to further explore key lines of enquiry.” Whilst the SI may have uncovered some aspects of the medical management of the care of Jessica, a large number of areas remained unexplored. I then met a medical director at the trust after I wrote to their board of Directors. The review went on to say the investigation was ‘to narrow in focus.’ In the meantime, the Trust closed the first SIRI investigation on their system called STEIS, the commissioners also signed the first investigation report off and it was closed without anyone advising our family. I queried the commissioners, how had my daughter’s case been closed? “What quality assurance” mechanisms were in place? The CCG said they would review their process which was described as robust. The first investigation was later redacted by the Ipswich Hospital.
Dame Clare Marx (Council Chair of the GMC)
“Although there already a great many processes ongoing. As a Trust, we have not as yet done enough to understand this case which has had such a profound effect on the patient and her family. We should now express that to the family and explain what we intend to do to put that right.”
“l consider has not addressed the totality of the incident adequately. As such we have failed the family to date in their right to understand what happened to their daughter during her period in the A&E Department of the Ipswich Hospital. By failing to cover all aspects of this episode we have missed the opportunity to derive extremely valuable learning from this incident. I, therefore, recommend that the whole period should be reviewed afresh with outside experts along the lines of an investigation undertaken into maternal deaths.”
Investigation three Although another investigation after the review was conducted, we were still left asking “how had this happened to her?“ and how she had gone from a seemingly healthy young girl who walked into Accident & Emergency laughing and joking with her Mother aged 23, to a cardiac arrest, a coma in four hours. My family by now were left feeling isolated and excluded from all SI investigations and there was no transparency or sharing of SI panel members expert opinion. We were excluded from the first investigation and felt the Hospital chose whole their experts would be without our agreement.
Investigation Report Four (4) We quickly learnt, asking Ipswich Hospital staff to investigate their colleagues when things go wrong, was like asking a schoolchild “to mark their own homework.“ It was a miserable, frustrating and disastrous experience, full of denial and broken promises. Assurances about ‘the terms of reference’ and what they would actually investigate and report on never happened. Promises made by their Governance Director Denver Greenlaugh never happened. Fortunately, we recorded every meeting so we retained a record of all conversations.
In May 2017 we finally received an SI report. We were shocked at all the amendments and deletions that cleansed the report. 800 alterations including complete paragraphs and pages were removed. The Ipswich Hospital closed all opportunities for further investigation. Two days later the Ipswich and East Suffolk Clinical Commissioning Group sent a duplicate letter to explain, “If we had any further concerns to take them to the PHSO.”
We still hoped some good would come from recommendations
There was very specific ‘patient safety’ recommendations on the last page of the report that had been left in. We hoped at the very least Ipswich Hospital would disseminate these, in particular, a specific escalation process for pregnant and recently-pregnant patients presenting as an emergency to ED. This would help safeguard other young Mothers presenting to ED nationally and could lead to senior review earlier by a multidisciplinary team. This was promised to be reviewed against a sample of other hospitals ‘policies and procedures.’ The Norfolk and Norwich University Hospitals NHS Foundation Trust NNUH had offered to share their procedure as an example during the last investigation.
This ‘escalation process’ was a recommendation made by Dr Pam Chrispin’s report. There were 14 recommendations. We have no way of measuring the effectiveness of any recommendations and would rely on the Clinical Commissioning Group to update us on progress at a later date. To date, we have heard nothing that shows any measurable improvements were embedded or shared.
In November 2018, Jessica’s mother and I travelled to Addenbrookes Hospital in Cambridgeshire to meet the Care Quality Commission (CQC). We presented the Hospitals Directorate – East Anglia Area Team with the ‘Action Plan’ and ‘14 recommendations‘ from the Ipswich Hospital’s investigation. They later added twelve specific points of their own in 2019. They agreed they would raise our concerns with The Ipswich Hospital. Their own specific points would be raised with the Hospital before their Inspection in August 2019. Within our discussions, we discussed non-compliance with the duty of candour, mandatory training compliance, learning from incidents and equipment checks. The CQC response is here with a full list of actions. After May 2019 Laura Davidson apparently left the CQC, I waited five months for a response and finally contacted the CQC last month. To Date, I have no measurable evidence that is quantifiable or ever been published by the CQC or the Ipswich Hospital.
In 2016 I started to consider the option of reporting my concerns to the General Medical Council (GMC). As a regulatory authority, I knew if I reported my concerns to them they would investigate further. Given that the previous Hospital investigation was not thorough and could be sanitised before we ever get to see them. I decided the GMC Fitness to Practise (FTP) route was a better option if we were to ever find out what had happened to our daughter. This my GMC Investigation Process For Families Fitness To Practise guide.
|What you should know before you begin the GMC process||–||–||–|
|Filing your Fitness To Practice Complaint||2018||8,573||6,258|
|Get independent expert clinical advice and a report||–||–||–|
|GMC Case Examiners Dictionary and Language Guide||–||–||–|
|Initial preliminary stage and correspondence||2018||519||371|
|Triage and screening (in 2016, 74 % closed)||2016||456||158|
|Timetable for GMC full investigation and expectations||2016||–||2019|
|Full investigation (in 2016 only 1,454 cases)||2016||1,454||7,214|
|Closure (in 2018 74 % were closed with no further action)||2018||74%||6,258|
|Rule 12 Review (in 2016, only one case was reopened)||2016||*27||*26|
|Cases Proceeding to MPTS||2018||*388||–|
* The reason for the absence of Rule 12 Review numbers that actually resolved after 2016 is because the GMC and PSA have removed them from their performance reports. The same applies to the incorrect decision numbers and statistics, they have also been removed this regulators performance reports. This is hardly transparent and in my view indicates the GMC’s reluctance to make these numbers available for public scrutiny. Of the 388 MPTS tribunals, 247 had conditions imposed, 93 no order was made and 48 resulted in suspension.
General Medical Council (GMC) Fitness to practise statistics for 2018 GMC Statistics
The Gerard Cronin Investigation Report – A Review of the Ipswich Hospital SIRI
The Ipswich Hospital Dr Pam Chrispin SI investigation Last Page SIRI Recommendations
Care Quality Commission – Hospitals Directorate – East Anglia Area Team Action Document