Department of Health response to my second email to Jeremy Hunt

24/01/2014

This is the Department of Health’s ‘response’ to my second email to Jeremy Hunt:

Our ref: DE00000813924

Dear Dr Farrelly,

Thank you for your further correspondence of 13 October to health ministers about the removal of GP boundaries in six primary care trust (PCT) areas .  I have been asked to reply.

I am sorry that you were dissatisfied with the Department’s previous response (our ref: DE00000807059).  However, there is little I can add on the matter.

With many people working some distance from home, it is not always convenient for them to see a GP in the area in which they live.  The piloting arrangements were introduced to allow patients, who wished to do so, to register with a practice away from the area where they live, perhaps closer to where they work.  Arrangements are in place to ensure that, should patients wish to register away from home, they are still able to access primary medical services should they need them when at home.

The arrangements were trialled in a limited number of areas and the results have been evaluated and passed to NHS England.  It will be for that body to decide whether they wish to roll out the arrangements on a wider basis.  Should you wish to raise your concerns with NHS England, you can do so at the following address:

NHS England

PO Box 16738

Redditch B97 9PT

Tel: 0300 311 22 33

Email: england.contactus@nhs.net

I am sorry I cannot be more helpful on this occasion.

Yours sincerely,

Lindsey Cox
Ministerial Correspondence and Public Enquiries
Department of Health


Third ‘reply’ by Department of Health to my warnings about problems with abolishing GP boundaries

24/01/2014

In my last email to Jeremy Hunt and health ministers, copied to the Health Select Committee, I wrote:

So far you have evaded the issues I have raised in my previous emails. I am saying that this policy is unworkable, that in some cases it is unsafe; overall, it will impact negatively on the functioning of general practice. If harm comes to patients because of this policy and you and others have wilfully neglected a proper risk assessment, will you be accountable?

I require the following by way of response:

A. I challenge you and your officials at the Department of Health to respond, point by point, to my Submission to the Health Select Committee.

B. In the Department of Health’s media launch of the so-called ‘pilot’ in December 2011, we read: “The pilot, which will begin in April 2012 and last for one year, will also come as a relief to people who are moving home and wish to remain with their preferred practice, and families who would like a practice near to their children’s school.”

This detail of families registering at a practice near their children’s school is repeated in the evaluation Proposal submitted by Professor Mays in May 2012.

So you think this is a good idea? I challenge you and your associates at the Department of Health to answer the following questions about this particular idea:

1. What benefit accrues to a family if they register with a practice near their children’s school? Why would they want to do it?

2. How would this work practically? (Details please, full details of the mechanics of this).

3. Are there any risks or problems with this proposal?

*

This is the ‘reply’:

Our ref: DE00000834110
Dear Dr Farrelly,Thank you for your further correspondence of 13 January to the ministers of the Department of Health about the removal of GP boundaries.  I have been asked to reply.I am afraid that there is nothing that I can add to my colleague’s previous replies of 20 September and 23 October (our refs: DE00000807059 and DE00000813924).It is not always convenient for people to see a GP in the area in which they live.  Alternative arrangements were trialled in a limited number of areas and the results have been evaluated and passed to NHS England.  It is for NHS England to decide whether to implement the arrangements on a wider basis.  NHS England can be contacted at:NHS England
PO Box 16738
Redditch B97 9PT

Tel: 0300 311 22 33
Email: england.contactus@nhs.net

I note that you have contacted the Department of Health previously on a number of occasions about this issue.  The information given to you by my colleagues is the most up-to-date and accurate available, and there is nothing further I can add to this.  The Government’s position remains as set out in previous letters.I am sorry if this is not the reply that you were hoping for, but as there is nothing further that the Department can add, we must now consider this matter to be closed.  Unless you raise a new question, any further letters sent to the Department will be logged but may not receive a reply.Yours sincerely,Charles Podschies
Ministerial Correspondence and Public Enquiries
Department of Health
*

My concerns about the ‘independent evaluation’ of the choose your GP practice pilot

11/01/2014

I have written to the current Secretary of State for Health, Jeremy Hunt, about my concerns about the proposed policy to abolish GP geographical boundaries. To my first email, I received a non-reply masquerading as a reply and so I sent a second email. The reply to this second email was no better than the first and in fact covered much the same ground as the first reply. So I have emailed him again today. (I have sent similar emails to NHS England and the CQC; NHS England’s reply was wholly inadequate so I have written to them again).

The replies I have received so far have limited themselves to describing the structure and process of the Pilot (which ran from April 2012 to April 2013), and the fact that an ‘independent evaluation’ would be made, and sent to the relevant bodies, including the GPC and NHS England (who have inherited the responsibility for implementing (or not) this policy).

I have been sceptical about this policy from the beginning, and my scepticism has if anything grown over time. The policy sounds attractive at first sight, but to anyone who knows how general practice in the UK works (its ecology), the policy does not make sense. The Department of Health so far have promoted this policy assiduously, ignoring the problems and risks. The 2010 ‘consultation’ was a PR exercise, structured in such a way so as to get the desired result, a New Labour ‘dodgy dossier’. The politicians and Department of Health have since used the ‘results’ of this rigged consultation to continue to push for this policy.

The Pilot structure did not actually test the policy itself in any true sense. I wondered how the evaluation would be structured: I thought it likely that it would avoid evaluating the policy itself.

I contacted Professor Nicholas Mays of The London School of Hygiene and Tropical Medicine, and Director of the Policy Research Unit in Policy Innovation Research who were commissioned to carry out the evaluation. I asked Professor Mays if I could see the ‘spec’ the Department of Health had sent them; he did not have such a document, but sent me the Evaluation of GP practice choice pilots, Proposal, 14 May 12 that he had submitted to the Department of Health in response to their request. He suggested I contact the Department of Health about the specification and so on. What I found out was that the Proposal was the result of a meeting between Department of Health officials (I do not know how many) and Professor Mays (I do not know if other members of the Policy Research Unit were present). The Pilot was discussed at this meeting, and the Proposal resulted from this discussion. The meeting was not minuted. So no written ‘spec’.

I read through the Proposal and it confirmed my fears. The evaluation was designed to assess the Pilot rather than the policy. This sentence is from the first paragraph, under the heading ‘Rationale’:

“According to the Department of Health, 75% of patients who responded to a recent consultation on GP choice made it clear that they wanted greater ability to register with a practice of their choice irrespective of its location.”

This is the ‘consultation’ which I say is rigged. Has Professor Mays read the consultation documents and assessed how this ‘75% of patients’ was engineered?

Further along in the Rationale section is the following:

“People able to access GP services in the pilot areas will have greater choice and flexibility about the GP practice that provides their personal care. It will mean patients are able to register close to work, close to a relative they care for or even close to a child’s school.”

This detail, ‘even close to a child’s school’, bears further scrutiny. It was one of the avowed benefits of the pilot (and therefore the policy) in the Department of Health’s media launch in December 2011. I wonder if the evaluation will scrutinise this detail. Will it ask if this detail, registering with a practice near a child’s school, actually makes sense? What benefit accrues from this? How does it work? Are there any risks? Did Professor Mays’ team ask these questions, or did they just take this as a given?

I replied to Professor Mays as follows (19/10/13):

“I have now read through your Proposal for the Evaluation of GP practice choice pilots. It confirms what I feared. Your evaluation does not actually scrutinise the policy itself. I am not criticising you or your team but I think the DH has given you a brief which means that you avoid asking some very basic questions. I am sure that you have done good, thorough work, and I am sure you will come up with some interesting and useful insights; but it is likely that your ‘evaluation’ will miss the basic, fundamental flaws of this policy. These flaws are not exposed, revealed, by the ‘pilot’.

I attach my Submission the the Health Select Committee of May 2013. It outlines what I see as the main problems, I hope in a clear way. I suggest you and your team read this document.

What I am saying is that this policy has been promoted without taking into account the problems, the side effects, the unintended consequences, and it would appear that this has been done intentionally, wilfully. When thalidomide was launched in the late 50’s, it was marketed as a wonder drug, and there were real benefits. But there were also very considerable problems, which emerged with time.

Your evaluation will, by its very design, concentrate on the benefits of thalidomide, the marketing and distribution strategies of thalidomide, but not with the unwanted side effects.

I know what the problems are with this policy, I deal with them on a daily basis, and what I have outlined in my Submission is just the tip of a large iceberg.

I would be happy to meet with you to discuss this further, if you think that would be constructive. I am copying this to the GPC.”

*

I have not yet been able to see the final report that was sent to NHS England and the GPC. Professor Mays has told me it is being peer reviewed and then will be available, perhaps in the next month or so. Once I have read it, I hope then to meet with Professor Mays to discuss this further.


My email to Stephen Dorrell, Chairman of Health Select Committee, on GP practice boundaries

20/10/2013

Dear Stephen Dorrell,

I sent a submission to the Health Select Committee in May 2013 raising concerns about the Government proposal to abolish GP practice boundaries (1).

A concluding paragraph read as follows:

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.

I sent an email to Jeremy Hunt on 8/9/13 raising my concerns (copied to you) (2); in response I received an evasive and irrelevant reply from the Department of Health (3); I sent a second email to Jeremy Hunt a week ago (again, copied to you) (4).

You were contacted by Pulse following my submission in May (5), and the article suggested that the Health Select Committee were going to investigate the policy. Has it done so? If yes, why was I not called to elaborate on, and to substantiate, my charges? If you have not investigated this matter, do you intend to and when? If you do not intend to examine it, why not?

I am aware that there is a glaring conflict of interest here, both for you personally and for your entire committee. Were you to investigate this policy, it would be very difficult to avoid coming to the conclusion that at best those involved in the planning and promotion of the policy were naive and ignorant and grotesquely incompetent (in short, a ‘blunder’); but, worst still, you might be unable to avoid concluding (as I have) that there has been a wilful misleading of the public and of parliament, that it is not just a blunder but actually a scam, a fraud. This would be embarrassing for your party as this, remarkably, appears to be a flagship policy for the Government (6),  and embarrassing for the Labour Party (one of the prime promoters of this policy was Andy Burnham when he was Secretary of State for Health; he is now the shadow minister for health and his credibility would be severely damaged if a light were shone on his involvement). So I expect you will do all you can to avoid looking at this honestly and fully. And that in itself will raise further questions.

If your committee is unable to scrutinise this policy thoroughly, then who should?

Yours sincerely,

George Farrelly

The Tredegar Practice
35 St Stephens Road
London E3 5JD

*

16/11/13: Yesterday it was announced that GP practice boundaries would be abolished as part of the new GP Contract. I have not heard from Stephen Dorrell or any member of the Health Select Committee. 

*

26/7/14: I never received a reply to this email which was copied to all members of the Health Select Committee

*

1. My Submission to the Health Select Committee

2. My email to Jeremy Hunt, 8/9/13

3. Response from the Department of Health

4. Second email to Jeremy Hunt

5. Pulse article 10/5/13

6. Coalition Government claim that the ‘pilot’ is evidence that they have improved the NHS


My Submission to the Health Select Committee on GP practice boundaries

19/10/2013

[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.

Summary:

  • 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.


Warning to Health Select Committee on a policy damaging to general practice, from a whistleblower

06/05/2013

I wrote to you several months ago to check if you would be the appropriate body to deal with my concerns about a Government health policy. Two of your members kindly responded and said that it did seem appropriate for your committee. So I am now writing to ask you to look into the Government proposal to abolish GP practice boundaries.

Summary:

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. Who am I and why am I campaigning against this policy? I am a GP in Tower Hamlets. I have worked in our practice for 22 years. I was the medical director of the Tower Hamlets out of hours GP co-operative from 1997 to 2004.

I feel very fortunate and privileged to be working as a GP. Good quality UK general practice is a national treasure, something to be nurtured, protected, sustained.

As GPs we serve a local community. Over the years, in our practice, we have had lots of experience of looking after patients who have moved away, even only a few miles away in Tower Hamlets or Hackney. 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. (Examples provided in links, see below).

So we are firm with patients about registering with a local GP.

When in 2009 politicians began to say that they wished to abolish practice boundaries, I was bewildered.

2. There are two main reasons why this proposal makes no sense: one, because looking after patients at a distance does not work (for many reasons) and is at times unsafe; two, because GPs are all currently working at full 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.

So there is a very serious design fault at the heart of this policy. For the past 2 years I have been blogging, and writing to MPs, to Ministers, to journalists to draw attention to the problems inherent in this policy.

Last Autumn I wrote 6 articles for Pulse on this issue.

These articles are also published on a separate blog.

3. At first I thought the politicians and the policy makers were just uninformed, unaware of just how misguided the policy was. But I now think 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 (2) 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 below).

4. 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 this). 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).

5. The (Labour) Government’s ‘consultation’ on the issue of choice of GP practice, 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 (3).

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?

6. The DH agreed with the GPC to hold a pilot around this policy. 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.” 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). What they also failed to say was that 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.

This ‘pilot’ in no true way tests the 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, and deliver a favourable verdict. One way would be to focus on the patient experience, which will no doubt be positive.

7. 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.

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.

8. 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.

9. 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.

10. I am writing as what some might call a ‘whistleblower’. That a busy GP should have to spend all this time in trying to get this message through to the politicians seems to me absurd. I am writing in the hope that you will listen and scrutinise this policy. But I am aware that there are many reasons why you as a committee might wish avoid this.

I am also writing so at least at a future date, when the inevitable problems surface, that you will not be able to say ‘Nobody warned us.’

 

Yours sincerely,

George Farrelly

 

The Tredegar Practice 35 St Stephens Road London E3 5JD

 

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Backing documentation

(Numbering corresponds to the paragraph numbering above)

2.. Looking after patients at a distance from the practice does not work and it at times dangerous:

Blog posts by me.

3. a. The narrative: the mainstream press has so far largely just reproduced what the Department of Health Mediacentre have told them in the form of press releases. There have been three main press releases, and corresponding articles in various media. Analysis of these articles shows that mainstream journalists for the most part do not understand how general practice works, and that they have uncritically taken the DH formulations and promises as fact, when in fact they often do not make sense.

 See my post.

In time, the mainstream press may well wake up and look into this issue.

b. The problem of capacity:

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 is to shrink our practice area further a few months ago. So there is no way we could cope with an influx of patients from Tower Hamlets (let alone anywhere in England as Andy Burnham promised), we are drowning as it is.

I came across an example which illustrates this problem recently. 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 currently registered patients, all of whom reside within their practice boundary.

Another example which illustrates this in a farcical way. The DH chose City and Hackney as one of their pilot sites. The City 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. 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. 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.

See my article.

4. On Burnham visit to King’s Fund, see my post.

5. On Government ‘consultation’, see my post.

6. On the Choice of GP pilot, see my post.

 

 

 


NHS Choices Website: my attempt to leave a comment regarding ‘Patient Choice Scheme’

14/04/2013

A few weeks ago, I found the NHS Choices page promoting the ‘Patient Choice Scheme’. I registered and left this comment:

I am a GP in Tower Hamlets, one of the sites chosen for this pilot. What the Department of Health is not telling you is that two of the 6 sites above (Tower Hamlets and City and Hackney) have refused to take part in this pilot in order to protect the local health economy and services to our local population.

The proposed policy to abolish GP practice boundaries is deeply flawed, but the Department will not tell you that.

For more information, see www.gpboundaries.org

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I checked this afternoon, and noticed that my comment (which I thought had been accepted on 31/3/13) was missing. There are in fact no comments to this page. So I have tried again. My Comment on Choices website but somehow feel that it won’t be visible, ever, to anyone else.


‘This is why practice boundaries exist’

16/06/2012

An article [link below] appeared in the BMA News in January 2012 illustrating why, from a purely practical point of view, GP practice boundaries exist. I have blogged previously with examples from our own practice [link below].

The article makes a number of important points: looking after people at some distance from the practice is time consuming. Not only is it difficult to look after these individuals well and safely, but to do so will impact on the service as a whole (so the service and care to the local population is affected).

This is why practice boundaries exist    Click here

Examples of patient care at a distance    Click here

 

 


13. How can they be so stupid? Corporate lobbying?

05/06/2012

I put a question mark after corporate lobbying simply because I have no direct proof myself of this activity. I am close to certain that this activity has taken place over time with respect to the issue of GP practice boundaries, and I think it is likely that this plays a central role in driving this policy. The politicians talk about patient choice, but underneath it all is really an aim to de-regulate English general practice and open it up in quite a new way to for profit companies.

How and why?

At present practices cover a limited geographical area. This limits the number of patients. Remove this factor, make registration free of geography, then it opens up an entirely different model which can be exploited by companies like Virgin Care.

These companies can set up medical centres in major cities, wherever is most profitable. They will attract a clientele of mobile, essentially healthy professional people. They will not have to deal with these patients when they are actually sick because they will be too unwell to travel to their centres; someone else will have to visit them. The elderly, people with chronic diseases, will remain registered with local GPs.

It will be convenient for the mobile and well, and profitable for the firms. But it will not deliver primary care in any real sense, and will in essence be a virtual asset stripping.


12. How can they be so stupid? Brain damage

05/06/2012

While on holiday recently I read a book on the neuroscience of pleasure (David Linden, The Compass of Pleasure). The idea came to me that in some sense the policy to abolish practice boundaries and extend patient choice is actually ‘brain damaged’.

In this sense: the book discusses the way in which various pleasures (sex, certain foods, drugs, behaviours like gambling) activate discrete parts of our brains, which we then experience as pleasurable. The author highlights situations where, under the influence of certain pleasurable experiences (such as falling in love) there is a distortion of our critical faculties, a ‘deactivation of the prefontal cortex’, the judgement, planning, and evaluation centre. Money, cocaine, heroin activate these pleasure centres.

It occurred to me that possibly the thought of choice, the promise of choice, somehow activated the pleasure centres, and led to a deactivation of the prefrontal cortex, a distortion of our critical faculties.

This is perhaps just a metaphor. But it certainly seems to me that certain policies from the DOH appear to be ‘brain damaged’, that is to say that important thinking steps are simply left out.