Misconceptions frequently arise regarding whether private independent clinics are required to register as a Designated Body. This often arises because these clinics may engage a limited number of doctors who predominantly carry out their clinical responsibilities for a local NHS Trust, where they undergo their appraisals. This could mean that 51-95% of a doctor’s scope of practice is associated with the NHS Trust, while the remaining 5-49% pertains to the independent clinic in question.
But all my contracted doctors are Appraised elsewhere?
You may hold part-time contracts with multiple doctors who have established connections to their Primary Care Trust, a private clinic in your specialty, or even a locum agency or insourcing provider. However, how does this guarantee that their current Responsible Officer is aware of the practices and procedures at your own clinic?
How would their RO feel about being accountable for your Clinic?
Often a Doctor will say ‘We don’t need to register the clinic as a Designated Body as I am appraised within the NHS’, but remember, it’s not just about your doctors and their professional appraisals.
Your doctor’s RO has a connection/responsibility for your doctor within their OWN healthcare organisation – but not for you or yours.
This presents an intriguing question regarding the NHS Responsible Officer’s (RO) role in representing a doctor for activities conducted outside of the NHS or the clinic for which they hold a statutory responsibility.
How well-informed are the RO and their Appraisers about the doctors engaging in additional clinical activities? It is crucial for them to be knowledgeable and comfortable with the policies and procedures of the independent private clinic involved.
The ‘buck stops’ with their RO – who protects you?
In line with the above – consider the questions which then arise;
- What happens if a doctor receives a complaint whilst practising for you?
- Will their NHS RO or other connected RO take responsibility?
- What happens if a doctor receives a complaint whilst practising for them?
- What does an investigation entail and how long would it take?
- What could an investigation involving your clinic find?
- What impact would a GMC investigation and any potential press coverage have on your own business and reputation?
We need to consider this from a regulatory perspective: What are the rules and what happens if they are not followed? Who is accountable?
Becoming a Designated Body can protect you.
Legal questions may arise at the point a concern is raised, and these can be readily addressed with a solicitor as a case is developed and investigated. However, it’s important to consider the potential financial and reputational costs to you and your clinic.
Are your own policies and procedures sufficiently robust to withstand such scrutiny?
Becoming a Designated Body in your own right can safeguard your business, stakeholders, and practitioner workforce. This designation mandates that patient safety, policies and procedures, employment checks, quality assurance, clinical governance, and accountability are all overseen by your Responsible Officer, who bears legal responsibility for ensuring that your clinic complies with governance and regulatory obligations.
Why YOU SHOULD Consider Becoming a Designated Body:
- Becoming a Designated Body is in the clinics’ own interests.
- Becoming a Designated Body assures your business, its stakeholders and your patients that any clinical practices undertaken within your premises, in its name and any entity or individual associated with it – comply with all regulatory and mandated patient care and safety obligations.
- Becoming a Designated Body is taking responsibility for providing the correct support for anyone who practices medicine and cares for patients in your clinic.
- Becoming a Designated Body serves to protect the integrity of your business
- It builds confidence in your policies, processes and practices
- It ensures accountability
- It ensures and can build reputation
Becoming a Designated Body won’t necessarily absolve you of any and all future risks but it serves to assure you that your clinic is; to all intent and purposes, protected.
Still not sure? A conversation around your clinic’s current position can help.
Don’t wait for the “What if….?” scenario to arise – it’s easy to check whether you need to become a Designated Body, to consider and protect your internal and clinical practices against any potential complaint or malpractice.
We can help you understand and establish your responsibilities and whether or not you need to consider notifying as a Designated Body.
A quick conversation to help you understand your position and obligations and how to avert any potential future risks – which costs you nothing, except a little time.
Arrange to speak with our Designated Body Advisor today.
Tel: 0207 183 9544
Email: [email protected]
