Registration and collaboration
Registration during the COVID-19 pandemic will require patients to complete the usual application process. NHS England and NHS Improvement’s latest standard operating procedure (SOP) in reminds practices that photo ID or proof of address are not required.
Recent NHS guidance also advises patients wishing to register with a GP on a temporary basis, that they should provide details of their current and past medical conditions, medications and allergies. Additionally, they should provide their NHS number and usual GP’s contact details.
The SOP requires GPs to adapt to new ways of working and managing demand during the COVID-19 crisis, whilst maintaining access and services for people who need care or support for pre-existing conditions. GPs are most likely needing to collaborate with other providers as part of the wider local health system, and working beyond traditional roles and boundaries.
Patients with symptoms of COVID-19 are being directed to NHS 111 and this will limit cases being treated by GPs to those who have been triaged as being suitable.
If patients do need to consult a GP, the current system for NHS primary care to provide immediately necessary and emergency treatment for up to 14 days will continue to apply, as will the facility for patients to register on a temporary or permanent basis if they require longer-term treatment. The scope to decline a new registration is very limited, and there must reasonable grounds to do so.
Remote contact with patients, confidentiality and consent
Current NICE guidance advises GPs to use remote consultations whenever possible to minimise direct contact with patients, including when triaging and planning their care. Ultimately, the clinician must weigh up the benefits and risks of remote and ‘face to face’ consultation in the circumstances of each case.
The GMC’s guidance on Confidentiality and Consent still applies during the COVID-19 outbreak. Doctors are expected to ensure they have the information they need to provide safe care that is of overall benefit to their patients, and to provide the information patients want or need to make healthcare decisions. It is advisable to document any difficulties encountered in obtaining information considered necessary.
Patients may be anxious about information-sharing between healthcare providers, particularly between those with whom they are not familiar. If a patient refuses consent for a doctor to access information they need, then the GMC’s latest COVID-19 guidance supports doctors to 'apply [their] professional judgement in deciding what to do in the best interests of the patient'.
The DHSC has also issued a notice to ensure doctors are confident that processing confidential patient information for healthcare purposes during COVID-19 is lawful.
Existing regulatory guidance for prescribing still applies, despite COVID-19 pressures and the drive to manage patients remotely whenever possible. This includes using electronic prescribing systems like Electronic Prescription Services (EPS).
GMC guidance makes clear that a doctor should prescribe medicines only if they have adequate knowledge of the patient’s health and are satisfied that treatment serves the patient’s needs. It also stresses the importance of good communication and a doctor-patient partnership, in which 'each person has a role to play in making decisions about treatment or care'.
In recent COVID-19-specific guidance, the GMC clarifies that a doctor, whose patient does not provide enough information, or prohibits information-sharing between healthcare professionals, should consider whether it is safe to prescribe.
Whilst supporting doctors to apply their professional judgment in deciding what is in a patient’s best interests, the GMC also advocates explaining to patients why it is unsafe to prescribe in the absence of enough information, and to consider referring the patient to other services for treatment. The GMC has also produced this information for patients about prescribing online.
Working outside usual area of practice
As a doctor, the GMC expects you to be competent in all aspects of your work, and to recognise and work within the limits of your competence. NHS England’s SOP for general practice acknowledges the need for flexibility and using new ways of working.
In its recent COVID-19 guidance the GMC states that doctors practising in an emergency should 'provide the safest care you can', outlining the primary requirement for all doctors to respond responsibly and reasonably to the circumstances they face.
The joint healthcare regulators have clarified their position, stating: 'In highly challenging circumstances, professionals may need to depart from established procedures in order to care for patients and people using health and social care services. Our regulatory standards are designed to be flexible and to provide a framework for decision-making in a wide range of situations.'
Of reassurance to doctors, any concerns arising during the pandemic would 'be considered on the specific facts of the case, taking into account the factors relevant to the environment in which the professional is working', and 'relevant information about resources, guidelines or protocols in place at the time'.
Healthcare professionals treating COVID-19 patients will be covered by state-backed indemnity against claims. Check with your medical defence organisation for information on the support they are offering for non-claims issues, such as complaints or disciplinary matters. Medical Protection has confirmed full non-claims support for current and retired members, including no charge for an increase in their work due to the COVID-19 response.
- Dr Ewen Ross is a medicolegal consultant at Medical Protection