My emails to NHS England about the new GP boundary-free policy implementation


[Names have been redacted to protect the innocent]

From: Farrelly George (NHS TOWER HAMLETS CCG)
Sent: 09 January 2015 18:26
To: ***** (NHS ENGLAND)
Cc: Farrelly George (NHS TOWER HAMLETS CCG)
Subject: out of area patient registration

Dear ****,

I am a GP in Tower Hamlets. At present, on the NHS Choices website, there appears to be no clear guidance as to which practices are actually opting into this service. Unless I am missing something, patients have no way of knowing which practices are offering this without ringing practices one by one.

We are not offering this because we do not feel it is workable, but if patients approach us we would like to have something to offer them in the way of signposting participating practices.

Best wishes,


The Tredegar Practice
35 St Stephens Road
London E3 5JD


From: ****** (NHS ENGLAND)
Sent: 15 January 2015 09:33
To: Farrelly George (NHS TOWER HAMLETS CCG)
Cc: ****** (NHS ENGLAND); ***** (NHS ENGLAND)
Subject: FW: out of area patient registration


Dear George

Thank you for your e-mail and please accept my apologies for the delay in responding to your query.

We currently don’t hold a central list of those practices that have expressed an interest in delivering out of area registration for patients, however, area teams have been provided with information via the e-declaration of those practices that indicated an early interest in the scheme so you may wish to contact NHS London who should be able to provide you with further information of local practices who may register patients out of area.

If I can provide any further assistance please do not hesitate to contact me or one of my colleagues.

Best wishes


******NHS England | 4E60| Quarry House | Leeds | LS2 7UE

High quality care for all, now and for future generations



Email George Farrelly to NHS England, London; 23/1/15; 08:22


Dear NHS England London (North East Area Team),

I sent the following email (see above) to NHS England and you can see from this email thread that they have suggested, for the situation in London, that I contact you. I have a number of reasons for wanting to know how patients are to find practices that are signed up to registering patients who do not live locally (one is to direct patients who enquire).

“I am a GP in Tower Hamlets. At present, on the NHS Choices website there appears to be no clear guidance as to which practices are actually opting into this service. Unless I am missing something, patients have no way of knowing which practices are offering this without ringing practices one by one.

We are not offering this because we do not feel it is workable, but if patients approach us we would like to have something to offer them in the way of signposting participating practices.”

Do you have a list of London practices (or north east London practices) who have expressed an interest or have signed up to registering patients who live out of area?

You can reply to this email, or if you prefer my mobile is ***** *** ***.

Best wishes,



Email George Farrelly to NHS England, London; 23/1/15; 09:08

Dear NHS England London,

I now have an additional question which relates to the other side of the coin: that is, patients who are resident in Tower Hamlets but have registered with a practice in, say, Ealing near where they work.

If that patient gets ill and is stuck at home on Tower Hamlets, the new arrangement is that they access a Tower Hamlets GP who is providing an enhanced service to these sorts of patients. But who is providing this in Tower Hamlets? (A recent Pulse article has suggested that the Out of Hours service might be called upon to provide this service, but that would mean they would have to be operating In Hours as well….). I will be speaking to our out of hours service shortly….[I spoke to the Tower Hamlets out of hours service; they had not been approach to provide in hours cover]

My understanding is that NHS 111 would have that information.

I have just rung NHS 111 covering Tower Hamlets but the helpful nurse advisor I spoke to was unaware of the new policy; she could only suggest that a Tower Hamlets resident without a local GP would have to go to a walk in centre or to A+E. She spoke to her supervisor who was also unaware of the new policy and where such a patient might be directed.

Can you help? (Can I say I sympathise with your situation: you did not dream up this policy but you have been given the task of implementing it….).

Again, my contact number is ***** *** ***.

Best wishes,




15/2/15: I have not had a response from NHS England London.

I have since contacted NHS 111 for Islington where I live and they also did not know about the policy and they gave the same answer as NHS 111 for Tower Hamlets. I then rang NHS 111 for central London (this includes Chelsea and Westminster, Camden, Hammersmith, and others); they too are were unaware of the new policy and did not have a list of local GPs who could offer In Hours care for patients not registered locally.


12/6/15 update: I still have not had a reply from NHS England. I emailed Jeremy Hunt about this problem as well. The Department of Health gave a characteristically evasive and meaningless reply, but noted that I had written to NHS England.

A few days ago, I checked again with NHS 111 for Central London. The supervisor did not have an accurate understanding of the GP Choice Policy, and said there was no infrastructure in place to provide primary care services to local residents not registered with a local GP. They were not in a position to arrange visits to those requiring them, or consultations with local GPs. They would be advised to go to a Walk In Centre or to A+E.


A question for NHS England (London) on GP boundaries and patient access


I have read a draft version of your Primary Care Commissioning Intentions for London 2014/15 London Region (v 1.1) and the following caught my eye:

….access to primary care services continues to be problematic for many Londoners. We are sure that the reaction and response to Call to Action will enable us to develop plans to improve access and the patient’s experience of access. Already, as part of the GP contract settlement for 2014/15, we will see a number of changes designed to improve access:

  • Choice of GP practice. From October 2014, all GP practices will be able to register from outside their traditional boundary areas without a duty to provide home visits. This will give members of the public greater freedom to choose the GP practice that best meets their needs. Area Teams will need to arrange in-hours urgent medical care when needed at or near home for patients who register with a practice away from home.

Can you explain how boundary-free general practice is going to improve patient access? Here in Tower Hamlets we cannot see how this will help.

Please leave a comment below.

My complaint to NHS England about abolishing GP boundaries, second attempt


Dear NHS England,

On 10 September 2013 I sent you a complaint, and have received your reply (see below).

I do not feel that this reply in any way addresses the substance of my complaint [my complaint was a copy of my first email to Jeremy Hunt]. The reply is largely a description of the structure of the choice of GP practice pilot. Whilst I did mention this pilot in my complaint, the substance of the complaint relates to the policy that the pilot is allegedly testing. I have criticisms of the pilot itself, but these are just part of an overall critique.

You mention the evaluation of the pilot carried out by Professor Nicholas Mays and his team. I have been in touch with Professor Mays and have seen his Proposal regarding the evaluation (but not the report which I am told is confidential). The scope of the evaluation does not include an evaluation of the policy itself; the rationale of the evaluation contains some quite questionable assumptions. I will return to this at another time [click here for my post on this issue]. I hope I will be able to see the report.

I would like you to try again with my complaint. I would suggest that you read my Submission to the Health Select Committee (reference number 5 in my email to Jeremy Hunt below; I am attaching it as a document to this email).

In summary, my complaint is as follows:

1. Good quality British general practice is a complex technology which delivers service to a local population. Its ecology is a local one. In our experience, people who move away and live at a distance from the practice receive poorer care; moreover, attempts to deliver care to people who live at a distance is inefficient, and at times unsafe. Distance is a barrier to care.

2. Much of what we do on a daily basis works because it is local. Were it not local, it would not work.

3. There is then an added problem, that of capacity. Our practice is unable to register all the patients who want to register with us from within a relatively small practice area. We are currently working beyond our capacity, and this drives down the quality of our service in terms of access and the time we can spend with patients, especially those with complex needs. We are not alone in this: almost all practices are working beyond their capacity limit. They simply will not have the space to look after additional patients (who would then bring with them the added problems of living at a distance from the practice mentioned above).

4. The politicians who have promoted this policy have simply ignored what I have outline in nos. 1-3 above. They have not undertaken an honest risk assessment.

5. Worse still, the Department of Health has not undertaken an honest risk assessment. They too have presented this policy in an idealised ‘rose tinted’ way, glossing over the very real problems inherent in a geography-free model. I am saying that they have been very misleading and dishonest.

So I would ask for a robust response to the issues I am raising, not written by some ‘customer relations’ worker who clearly does not have an understanding of the issues.

1. Please deal with the issue of distance from the practice. Does NHS England understand the risks of distance from the practice? (see my submission to the Health Select Committee, with back up documentation in the form of references).

2. Please respond to the issue of capacity. (Again, see my Submission to the Health Select Committee).

3. The Department of Health mentioned the ability for a child to be registered with a GP practice near his/her school (in the press release of December 2011 announcing the pilot, and it appears again in Professor Mays’ Proposal, as one of the rationales for the policy). Can you please tell me a. what benefit accrues to a child and parents with such an arrangement?; b. how would this work from a practical point of view? (yes, please spell it out); c. what are the possible risks or problems with this arrangement?

4. Please respond to the problems with visiting patients who are not registered with a local practice. Again, see the relevant paragraph in my Submission to the Health Select Committee.

Many thanks for your help.

Yours faithfully,

George Farrelly
The Tredegar Practice
35 St Stephens Road
E3 5JD

[26/8/14: The above was sent to NHS England in December 2013; I have received no reply at all.]


Reply from NHS England 26/11/13

Dear Dr Farrelly,

Re: Complaint reference SDR136238

Thank you for your e-mail of the 10th September 2013 raising your concerns regarding the choice of GP practice pilots.

I have been in touch with the GP contracting team in the NHS England Commissioning Development directorate who have provided me with some expert advice on this matter in order to enable me to provide you with an appropriate response to your concerns.

As you will know In April 2012, the Department of Health agreed a 12 month variation to general practice contracts giving patients a right to choose to register with any GP practice participating in the pilot without being restricted by the practice boundaries previously agreed with Primary Care Trusts. The pilot allowed patients to access GP practices beyond the areas in which they lived, in four participating PCTs (Westminster, Salford, Manchester and Nottingham City). It was expected that the pilot would benefit patients by giving them more freedom, choice and control over where they accessed care. It also included an option for patients to be seen as ‘day patients’ without registering.

The pilot scheme operated until the end of March 2013 although patients who have registered with a participating practice have been able to remain with that practice while the scheme is being evaluated in order to ensure that continuity of care is provided.

The scheme is being evaluated by the Policy Innovation Research Unit at the London School of Hygiene and Tropical Medicine and their final report is due during November 2013. Any proposals for changes to the GP contract to extend patient choice following consideration of the evaluation report would be need to be discussed with the BMA’s General Practitioners’ Committee.

We are anticipating that any issues relating to home visiting and access to community services will be highlighted from the evaluation and can then be addressed while considering the evaluation in its entirety.

I hope that this has answered your questions with regards to this matter. If you have any further concerns or questions relating to this matter please do not hesitate to contact us at, or by calling 0300 3 11 22 33. Please do not reply directly to this email.

Yours sincerely,

Jane Doe (name changed to protect the innocent)

Customer Contact Centre Case Officer
NHS England
PO Box 16738, Redditch, B97 9PT
0300 3 11 22 33