August/September 2022 Newsletter

Included in this edition:

  • DDRB announcement – GPC statement
  • GP workload and workforce
  • The fallacy of failure in general practice in Suffolk
  • GP patient survey
  • GP ‘bureaucracy busting concordat’
  • Reminder: Information for Practices in the East: Datix/Interface Issues
  • Patient Access to prospective GP Records – 1st November
  • Digital firearms marker
  • PCNs – clarification on CQC registration
  • Section 49 report guidance
  • Flu vaccines
  • New Flu Enhanced Service Specifications and Flu Collaboration Agreement
  • Pay Transparency update
  • Changes to COVID-19 Vaccination ES (Phase 5)
  • Patient Lists
  • Phoenix GP development programme
  • Practice Vacancies


Information, Guidance and News

DDRB announcement – GPC statement

The recommendation from the Review Body on Doctors’ and Dentists’ Remuneration (DDRB), and subsequent decision from Government published recently, was a 4.5% increase. This falls far below current levels of inflation, which are expected to reach 11% this year.  In real terms, this amounts to the wages of overworked staff being cut by more than 6%.

Astonishingly, the increase excludes GP partners in England who are locked into a five-year contract deal agreed pre-pandemic in 2019.  Consequently, there will be no funding increase to meet recommended pay awards for other staff.  This decision occurred despite the DDRB clearly urging the Government to consider the impact of omitting those on multi-year deals from this year’s announcement and stressing the “harm that may be caused to recruitment, retention and motivation by not acting”.

At a meeting of the GPCE (GP committee England) last week, members passed a resolution rejecting the pay award and committing BMA representatives to further discussions around next steps, including potential action short of industrial and industrial action itself.

For GPs who have spent the last two years pulling out all the stops to continue caring for their communities – often to the detriment of their own health and wellbeing – only to be left repeatedly unsupported and publicly admonished by Government and policymakers, this announcement only served to demoralise and devalue GPs ever further at a time when they are already feeling down and on the brink.

Read full statement here

GP workload and workforce

GP workload and workforce GP practices across the country continue to experience significant and growing strain with declining GP numbers, rising demand, struggles to recruit and retain staff and has knock-on effects for patients.  GP numbers are falling, with little increase in the overall number of GPs since 2015, and a significant decline in the number of GP partners over that time.  

As shown by the latest GP practice workforce data, as of July 2022 there are now the equivalent of 1,857 fewer fully qualified full-time GPs compared to September 2015. This means that NHS has lost the equivalent of 51 full-time fully qualified GPs compared to the previous month (June 2022).  This is despite the promises by the Government of an additional 6,000 GPs by 2024.

At the same time, the number of GP appointments remains high, with the July total of 26 million, of which 44.3% were same day appointments.

Practices are encouraged to control their workload to mitigate the impact of unsustainable demand and overworking.  The BMA Safe working in general practice ( guidance seeks to enable practices to prioritise safe patient care within the present bounds of their contract with the NHS.  We would encourage practices to consider these suggestions for controlling their workload to ensure safe patient care, and better staff wellbeing could make a significant difference in the coming weeks and months.

The fallacy of failure in general practice in Suffolk

Despite considerable local and national challenge, Suffolk General Practice continues to deliver for patients and deserves system support:

In the last month alone, according to data published by NHS digital, primary care across SNEE consulted 47% of the entire ICS population with 2/3rds of these consultations being face to face and around half of these delivered by a GP. These consultations were delivered despite workforce challenges – in particular a lower than average GP headcount (54 FTE GPs per 100,000 population vs English ICS average of 58/100,000) – and contributes to above average outcomes across a huge range of ICS level metrics – lower than average A&E attendances per head of population, LTC support higher than average and others.

GP patient survey

The GP Patient Survey (GPPS) report has now been published, which found that the proportion of patients having an overall ‘good’ experience of their GP practice has decreased by over 10 percentage points, dropping from 83% in 2021 to 72% in 2022. This further highlights the strain that general practice is under and the need for urgent action by the government to relieve the pressure on general practice.

Read the full BMA statement in response here

GP ‘bureaucracy busting concordat’

Earlier last month the Government published its GP ‘bureaucracy busting concordat’, which outlines seven principles to help reduce unnecessary bureaucracy and administrative burdens in general practice.  Developed with input from the BMA, the concordat includes principles around medical evidence, certification and designing processes around ease of use for both GPs and patients.  See Bureaucracy busting concordat: principles to reduce unnecessary bureaucracy and administrative burdens on general practice – GOV.UK (

Reminder: Information for Practices in the East: Datix/Interface Issues

Practices in the East experiencing issues at the primary:secondary care interface (significant discharge medication errors, clinical governance concerns, etc) should email with details and, where appropriate, copy a member of the LMC office into the correspondence.

These submissions, along with Datix reports generated by secondary care, will be investigated by the appropriate part of the system and the data reviewed at the ESNEFT:GP liaison meetings.

Patient Access to prospective GP Records – 1st November

Practices should have received the following information from their system supplier regarding the ‘switch on’ process.

As previously circulated the Essex LMC document is a very useful resource containing all the links to information on records access and we would strongly recommend practices take time to go through this.  Link to document here

Digital firearms marker

There are issues with the implementation of the new digital firearms marker for practices using the EMIS system.  GPC has raised this with the Home Office and NHS Digital has agreed to a temporary suspension of the EMIS system marker to ensure that the system is addressing the issues raised and enable testing to ensure the accuracy and completeness of the flags that are currently popping up.

GPC continues to work with the Home Office, Police Chiefs and NHS Digital to implement a firearms marker that will improve the current system for GPs and provide a safer and more efficient system to benefit the public. However, we are still looking for clarification/guidance on what doctors should do immediately when the flag comes up.  GPC is conscious that any revised system remains easy to use for GPs and importantly, does not distract or amount to an administrative burden and workload for practices.

PCNs – clarification on CQC registration

Following concerns and some confusion at local level regarding PCNs and CQC registration, the following clarification has been provided by CQC: ‘It is important to remember that only legal entities can register with CQC.  If a provider is a collaborative, such as a PCN, and is not a legal entity then it cannot carry out regulated activities and therefore it cannot be registered with CQC’.

In a situation where a PCN is not a legal entity, and the constituent members are already registered with CQC for the delivery of regulated activities they provide as part of the network (including extended access) they will not need to register separately from the constituent practices, however it is advised that providers amend their statement of purpose to accurately reflect the additional roles they will assume as a participant member of a PCN.  

In a situation where a new or currently unregistered provider organisation is formed as a legal entity AND the organisation will have ongoing direction and control of the delivery of regulated activities it would be required to register with CQC.  If a PCN becomes a legal entity but does not directly control and deliver regulated activities (for example by supplying staff to assist constituent practices to deliver their regulated activities) there is no need to register with CQC.  

Please note that new applications for registration can take up to 10 weeks to process.  The exact timeframe will depend upon the complexity of the application and the availability of key information requested by the registration inspector.’

In addition to this statement, GPC England officers and staff will be working with CQC to develop and publish responses to a range of FAQs addressing PCNs and registration.

Section 49 report guidance

Under section 49 of the Mental Capacity Act 2005 (the “MCA”), the Court of Protection (the “CoP”) may require NHS health bodies and local authorities to arrange for a report to be made for the purpose of considering any question relating to someone who may lack capacity.

Producing a report is a complex process involving assessing the patient, reviewing notes, discussing with relevant professionals and compiling information. The amount of time required to review a long and complex set of medical records presented can be significant.

The definition of ‘NHS body’ does not include GP practices, even if their contractor CCGs/PCOs are. Therefore, practices cannot be directly ordered by the Court of Protection to produce a report under section 49.  Although it is possible for an NHS body (e.g. an NHS Trust) that had been ordered to arrange for a report to be made to request that someone else produce a report (under section 49(3)), e.g a GP – in doing so, the trust cannot compel a GP as an independent practitioner to do the work and if the GP agrees to do the work, he/she is entitled to be paid a rate agreeable to the GP.

Read more here bma-section-49-guidance2022.pdf 

Flu vaccines

The Department of Health has announced an extension of the cohorts for the 2022/23 flu programme to include 50–64-year-olds.  Unlike in previous years, there will not be a central supply to cater for these extra patients, and instead NHSE/I will be looking at ‘local procurement’ routes.

There will be a phased introduction for the additional cohort, with 50–64-year-olds being eligible from October, when there is anticipated to be greater availability of vaccines for this group.  Due to manufacturing processes and commissioning arrangements, some vaccines may only be available in limited quantities.  Therefore, NHS England has recommended that orders are placed with more than one manufacturer to ensure providers receive sufficient stock.

GPC are continuing to discuss the practicalities of this with NHSE/I in order to minimise the disruption and additional workload that it may bring for practices

Read the NHSE/I flu vaccine reimbursement letter

New Flu Enhanced Service Specifications and Flu Collaboration Agreement

NHS England and NHS Improvement (NHSE/I) has now published the service specifications for 2022/23 flu and childhood flu vaccination programmes.

As practices will be aware from the previous NHSE/I flu letters, practice staff are still not included within the cohorts for the programme.  GPC have expressed serious concerns about this as including practice staff within the eligible cohort would improve uptake, protect patients, and help maintain workforce.   These concerns have been raised repeatedly with NHSE/I, especially as practice staff were included in last year’s programme.  GPC continues to discuss with NHSE/I as a matter of urgency.

As staff are not included in the specification, this means that currently the indemnity cover is no longer available from the Clinical Negligence Scheme GPs (CNSGP).  If this changes, we will advise practices accordingly.  In the meantime Practices may wish to refer to the flowchart here for guidance on staff flu vaccinations. 

Pay Transparency update

In April 2022, amendments to the GP contract regulations were made that removed the requirement for individuals within scope of the general practice pay transparency provisions to make a self-declaration of their 2020/21 NHS earnings by 30 April 2022.  Individuals within scope of the pay transparency provisions are not required to take any action in relation to their 2020/21 NHS earnings at this stage.

Pay transparency remains part of the current regulations, however DHSC has confirmed that commissioners should not enforce the requirement at this time.

Currently the individuals in scope of the regulations introduced in October 2021 will need to make a declaration of their 2021/2022 earnings in April 2023 as the provision remains in the GP contract. The latest position on Pay Transparency is available on the NHSE website:  NHS England » General practice pay transparency

GPC continue to request further suspension of the requirement to declare earnings as it is believed this is harmful to morale of the profession and could lead colleagues to reduce their working commitments or to retire.  It is alsoinequitable to single out general practice for this requirement.

Changes to COVID-19 Vaccination ES (Phase 5)

Significant concerns have been raised about recent amendments to the Enhanced Service for the COVID-19 vaccination programme, particularly in relation to the reduction of the item of service charge from £12.56 to £10.06, the removal of the care home administrative payment, and the decision to pass the cost of consumables (needles and needle disposal, cotton swabs etc) on to practices.

GPC wrote to Nikki Kanani (Medical Director of Primary Care, NHSE/I) and Amanda Doyle (Director of Primary and Community Care, NHSE/I) on 18 July to raise these concerns. We underlined the key role of, and enormous efforts made by, general practice in the rollout of the COVID-19 vaccination programme and highlighted that this amendment will effectively disincentivise practices from taking part – with severe risks to vaccine uptake and public health.  NHSE was strongly urged to reverse its decision, and to extend the opt-in window to reflect these late changes.  Finally, GPC emplored NHSE/I to adopt a collaborative approach on these crucial issues, noting that GPCE was not afforded a meaningful opportunity to negotiate these amendments.

On 3 August a response was received that whilst recognising the concerns and the previous efforts by primary care in the covid pandemic it was made clear that NHSE was not willing to make any of the concessions requested to ensure that the Enhanced Service remains sustainable.  Whilst this is a frustrating outcome, GPC will continue to make representations on this issue to NHSE/I.

Patient Lists

NHSE/I has asked PCSE to recommence data quality checks on GP practice patients lists, this includes a reconciliation of practice patients lists. This work was paused during the COVID-19 pandemic but started again on Monday 1 August 2022. Copies of the communication circulated to practices can be found here: Patient list reconciliation and Patient list maintenance.

Phoenix GP development programme

We have been asked to circulate this programme by the GP Lead at SNEE Training Hub:

Phoenix GP is a career and skills development program specifically targeting mid-career GPs. It provides a series of 6 evening sessions over 6 months for a cohort of 30 participants. It balances a series of talks from inspirational GPs with dedicated skills workshops developed by the Time for Care team to focus on the challenges faced by mid-career GPs. These include topics such as change management, fundamentals of quality improvement, engagement and influencing people, facilitating online meetings and increasing personal impact and influence.

The program is fully funded and is delivered virtually through MS Teams. It is supported by NHSE and RCGP. Previous programs have been extremely successful and universally well-received by attendees.

“I’d had a rubbish day & was feeling really disheartened when I arrived. By the end of the evening I felt inspired, enthused & energised – thank you so much”

“Really worthwhile. This can’t change the problems behind the current situation but really good to meet, get support, share ideas & feel better about what I am doing. Thank you.”

“Hugely enjoyable evenings. It is having a big impact on how I feel about being a GP and how I approach things in practice. It might just keep me as a GP”

Applications are now open and you can apply by clicking below;

Practice Vacancies

Can be found on the LMC Website

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