My Submission to the Health Select Committee on GP practice boundaries

[I sent this Submission to the Health Select Committee in May 2013. I have not heard from them.]


Submission by Dr George A. Farrelly, General Practitioner, regarding the Government policy intending to abolish GP practice boundaries. This submission is made in a personal capacity, though I believe I represent the views of many GP colleagues.


  • The Government and Department of Health wish to abolish GP practice boundaries, saying that it will increase patient choice, drive up quality, and remove anachronistic constraints.
  • From my perspective as a GP with 25 years’ experience of trying to provide good quality general practice to a local community, this policy may sound attractive on the surface, but in reality will simply not work and will cause general practice to malfunction; in some cases it will be unsafe.
  • The Government and Department of Health are either remarkably stupid, or they have a hidden agenda and are engaged in an elaborate deception.


1. I am a GP in Tower Hamlets. My wife and I have run a small practice in Bow for 22 years (I had worked in Islington before that). The practice has grown, and we have two part-time salaried GPs and a GP registrar. Our aim has always been to provide good quality, evidence-based family medicine with a human touch. We are part of a local network of 5 practices in Bow (practices in Tower Hamlets are all part of a Network; there are 8 Networks). We are a training practice; we teach medical students.

Before studying medicine at St Bartholomew’s Hospital Medical College, I did an undergraduate degree in history (Harvard University, Magna cum laude), and a postgraduate degree in International Relations (LSE, MSc, Distinction).

In addition to my core job as a GP, I was Medical Director of the Tower Hamlets Out of Hours GP Co-Operative from 1997 to 2004. THEDOC, as it was called, provided out of hours GP cover for the Tower Hamlets population.

I feel very fortunate and privileged to be working as a GP. I feel very fortunate to be working in Tower Hamlets which has a tradition of committed GPs working collaboratively to provide good quality primary care for our population, and we have had the support of a forward-thinking PCT.

Good quality UK general practice is a national treasure, something to be nurtured, protected, sustained.

2. As GPs we serve a local community. Over the years, in our practice, we have had much experience looking after patients who have moved away, even only a few miles away in Tower Hamlets or Hackney, and who have wanted to remain registered with us.

We have found that living at a distance from the practice creates a barrier to care. We have found that these patients tend to delay being seen; that it is more difficult and time-consuming to manage their illnesses; sometimes they are too ill to travel to see us, and we are unable to visit them. At times it is unsafe.

As a result, we are firm with patients who move out of our practice area and ask them to register with a local GP.

And so when in 2009 politicians began to say that they wished to abolish practice boundaries, we were bewildered.

3. There are two main reasons why this proposal makes no sense:

a. first, because looking after patients at a distance does not work (for many reasons) and is at times unsafe; this becomes increasingly significant in proportion to the severity of the patient’s health problems. (1)

b. two, because GPs are all currently working at full capacity (indeed, in some cases, beyond their capacity). The ‘good’ practices are already ‘full’ and cannot accommodate a significant increase in demand. There is a risk that ‘outliers’ will take the place of local residents, or impact negatively on the services of local residents (further discuss in paragraph 5 below).

So there is a very serious design fault at the heart of this policy. For over two years I have been attempting to draw attention to the problems inherent in this policy by blogging, writing to MPs, and to journalists. Last Autumn I wrote 6 articles for the GP publication Pulse on this issue (2). And I published these articles on a separate self-contained blog. (3)

4. At first I thought the politicians and the policy makers were just uninformed, unaware of just how misguided the policy was. But the replies I received from the Department of Health simply did not make sense. (4) And so over time I have gradually come to the view that the evidence (evidence that is in the public domain) points towards a more disturbing process at work: that there is a hidden agenda behind this policy. My hypothesis is that the real aim here is to de-regulate general practice. At present, because it is geographically defined, it limits the type of business model that can be used to gain access to general practice. By removing the geographical element in primary care, you change significantly the business models and frameworks that can be applied.

But in order to abolish GP practice geographical boundaries, it has been necessary to create a pretext, or a series of pretexts. A narrative has been created and it has these elements: most people are happy with their GP; but some are not, and they should be able to have choice; GP practice boundaries constrain choice, they are old fashioned, anachronistic; there are a number of reasons why patients might want choice: to have a GP close to work, to register with a GP near their child’s school, to remain registered with their trusted GP should they move away; there might be a GP skilled in a disease in a practice outside their area; the only thing that is needed to make it all work is to sort out how visits will be done should the patient need one.

What this narrative leaves out are the two areas mentioned in paragraph 3 above: the systemic problems of patients living at a distance from their GP, and the problem of capacity. It also fails to mention the problems inherent in providing visits for people registered at a distance from their practice (see paragraph 9 below).

5. Some additional notes on the issue of capacity.

a. In our practice we have struggled with this. Because we are popular, people have wanted to register with us. This has driven us to a list size beyond our capacity which has a negative impact on the quality of the service we provide for our patients, and we have a workload which is unsustainable. The only way we have had to cope with this was to shrink our practice area further a few months ago. So there is no way we could cope with an additional influx of patients from Tower Hamlets (let alone anywhere in England as Andy Burnham promised in 2010); we are drowning as it is.

b. I came across an example recently which illustrates this problem quite eloquently. There is a practice in Kentish Town with a long established reputation; just the sort of practice that people for several miles around might want to join (if I did not know better, I would consider joining as they are less than 2 miles from where I live). If you go to their practice website you will see the issues they are wrestling with as raised by their patient representation group: they are having trouble providing access to their own patients to the GP of their choice. And those are their currently registered patients, all of whom reside within their practice boundary. (5)

c. Another example illustrates this in a farcical way. The Department of Health chose City and Hackney PCT as one of their pilot sites. The City of London is served by one practice, which has a list size of under 10,000. As it happens, the City of London Corporation and NHS Northeast London had commissioned a study into the practicalities of providing primary care services to the commuter population of the City and this was published. The conclusion was that something like 120,000 of the 360,000 commuters were likely to want to register with a GP practice in the City, which would require 50 more GPs, and additional practice nurses and infrastructure (6). So there was really no way that the sole City practice was going to be able to cater to commuters interested in taking part in the pilot.

6. Andy Burnham, then Secretary of State for Health, went to The King’s Fund in September 2009; in his speech he announced his Government’s intention to abolish GP boundaries within a year. He said this move would make a ‘good’ NHS ‘great’ (at least this is what the press reported; I have asked the DH to show me the press release for this occasion; thus far they have been unable to produce it). But what he said about this in his speech really amounted to nothing, it was meaningless to anyone who understands how general practice works (and does not work). (7)

7. The (Labour) Government’s ‘consultation’ on the issue of choice of GP practice was launched in March 2010. If you look at this ‘consultation’ with a critical eye it is clear that it steered the readers towards responding in certain ways to the questionnaire. It used the narrative outlined in paragraph 4 above.

When it published the results of the consultation, the DH claimed it showed that the public backed the idea of choosing your GP practice and doing away with practice boundaries. Of course it showed that, it was designed to show that. Had they been honest about the reality of general practice, the respondents would have said: given what you have told us, why are you even proposing this policy? (8)

8. The Department of Health agreed with the GPC to hold a pilot around this policy. (9) The pilot is in progress. The present Government went so far as to say, in their Mid-Term Review, that this pilot was evidence that the Government had improved the NHS. “We have improved the NHS by …..—allowing patients in six trial primary care trusts to register with a GP practice of their choice.” (10) What the report omitted to say was that GPs in two of the six PCT areas opted to boycott the pilot because of concerns of the impact on resources of the local health economy (one of the many problems inherent in this policy).(11) What they also failed to say was that out of a possible 345 practices in the pilot areas, only 42 practices had opted into the pilot, and that as of the beginning of the 2013, only 514 patients had registered with a practice under the scheme. (12)

This ‘pilot’ in no true sense tests this policy. The Government and DH say that there will be an independent evaluation of the pilot. Given their behaviour so far, my concern is that the ‘evaluation’ will somehow avoid scrutinising the policy itself, and deliver a favourable verdict. One way would be to focus on the patient experience, which will no doubt be positive.

9. The problem of visiting. People on all sides of the debate have acknowledged that the issue of visits would need to be addressed. But what most people have failed to grasp is the magnitude and breadth of this issue. At present, all patients are visited by their own GPs within working hours (8am to 6pm [or is it 6:30?]), Monday to Friday. And if the call is outside these hours, then there is a local arrangement for how these visits are covered. There have been problems with out of hours provision, with some high profile cases where patients have died due to not being assessed properly.

If this policy is enacted, then every area in England will require a structure to provide care for those who live at a distance from their registered GP. This provision will have to cover not only the out of hours time slots, but will of necessity be 24 hours a day, 7 days a week (because they will not have the cover of ‘their’ GP during working hours).

It is also important to understand that when a patient is seen out of hours, the notes from the encounter are sent to the registered GP. Almost always the notes contain a message that says something like this: ‘If not improving, for review by own GP.’ The trouble with the boundary free model is that there will be no local GP to manage the patient while unwell during working hours and at home. The out of hours service does not provide continuity of care, and does not arrange further investigation and referral where this is warranted.

10. There are a number of issues I have not mentioned in this submission, and this is by no means a complete critique of the proposed policy.

11. I think there is a case for finding a way to make good quality primary care accessible to people who work long hours at some distance from their homes. But the people designing a solution would have to adopt a sound methodology which would include honesty, common sense, and truly taking into account the ecology and practicalities of general practice.

12. Normally, if politicians or Government departments make unrealistic promises the media often provides a valuable corrective by scrutinising and challenging the claims. In the case of this policy, however, mainstream media have failed in this role, I think mainly due to ignorance of how general practice works. There have been three main waves of (limited) airing of the GP boundary issue in mainstream media: at the time of Burnham’s visit to the King’s Fund in September 2009, the launch of the Consultation in March 2010, and the press launch on 30/12/11. The mainstream press articles which appeared on those occasions essentially took the claims of the Department of Health (often misleading) and merely repeated them, as though they were ‘true’ and based in reality. (13) The mainstream press may at some stage wake up and review this issue.

13. I am making what is a serious and unsettling charge. The people involved in promoting this policy (ministers from both Labour and Conservative parties, and policy makers at the Department of Health) are trying to implement a policy which by its very design will cause primary care services to malfunction and cause real harm. These people have not done an honest risk assessment. They have promoted the policy in a very biased and misleading way. The result is that they have misled Parliament, journalists, and the citizens of England. If this policy were a financial product, it would be deemed mis-selling. In some senses, it is fraudulent.

14. I am writing as what some might call a ‘whistleblower’. That a busy GP, in a private capacity, should have to spend all this time in trying to get this message through to the politicians and those handling the levers of power seems to indicate that something is wrong. I am writing in the hope that you will listen and scrutinise this policy.

I am also writing so at least at a future date, should the policy be implemented and  the inevitable problems surface, politicians and the Department of Health will not be able to say ‘Nobody warned us.’


George Farrelly

The Tredegar Practice
35 St Stephens Road
London E3 5JD

1. For an article which illustrates aspects of the problem, see an article by an inner city GP ; for some examples from our own practice.

5. Difficulties of a high quality practice providing access for their patients. This is a very common problem; essentially, most practices are looking after too many patients. This is a capacity issue.

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