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The CNSGP (state scheme for GP clinical negligence) has been running for three months and has been well received by the profession. There have inevitably been questions from GPs about the exact scope of the scheme; doctors are keen to know which activities are covered and which aren’t. Mostly this has been a process of clarification and explanation of the new environment created by the scheme’s introduction.
Unfortunately, this month has seen a policy change from the DHSC (Department of Health and Social Care) and NHSR (NHS Resolution) who now administer the scheme in England. The range of negotiations in the run up to the scheme’s launch was broad and detailed, with both the BMA and the RCGP (Royal College of GPs) seeking certainty around many finer aspects of the scheme’s coverage.
One small but important part of this was the question of coverage for travel vaccinations performed in general practice. Some vaccines are delivered as part of GP NHS services and are therefore covered without question. However, the status of chargeable travel vaccination services was an area of keen focus and the decision was made by DHSC that these would also benefit from being within the scope of CNSGP. That was the basis upon which the BMA and other organisations briefed the profession when the scheme was launched.
Just over a month ago we were made aware of a change in advice on the NHSR website that reversed this policy and indicated that chargeable travel vaccinations would no longer be covered under CNSGP. We immediately took this up with DHSC and robustly set out our concerns over this development. Supported by the RCGP we informed DHSC that this policy change could result in some practices ceasing to offer chargeable travel vaccinations and malaria chemoprophylaxis or delivering pass-through costs to patients that could reduce the number of travellers accessing these services. The public health implications are obvious.
We also raised the pressing and serious matter of the retrospective loss of cover for practices who had operated in good faith on the basis of the original advice, that these services were within the scope of CNSGP. Following urgent negotiations, DHSC and NHSR have issued a statement which says that practices will not be disadvantaged retrospectively but they will cease to benefit from this cover from the end of July. This is on the grounds that chargeable vaccines are not an NHS service and are therefore not in scope of CNSGP.
While we welcome the reversal of the retrospective removal of cover we remain concerned that chargeable travel vaccinations and the provision of malaria chemoprophylaxis prescriptions will cease to be covered by CNSGP at the end of this month. We strongly advise practices to review their indemnity arrangements for all of their staff, and especially for practice nurses who traditionally deliver the majority of travel clinic care. We have warned DHSC that some practices may find the potential increase in the cost of private cover for their nurses prohibitive and may therefore cease to provide these services.
It is important to note that simple travel advice remains within the scope of CNSGP but the provision of the chargeable vaccination or prescriptions for malaria chemoprophylaxis require adequate private cover.
The Royal College of Nursing has now announced that their nurse indemnity cover will include chargeable travel vaccinations, and we are in discussions with the Medical Defence Organisations about the potential cost of this cover. While we continue to make it clear to DHSC that there must be no further such revisions to the scheme it is nonetheless vital that every practice is aware of this change and reviews its policies accordingly.
Mark Sanford-Wood is deputy chair of the BMA GPs committee
Thank you for the information and guidance. A few added comments from personal experience as a GP and a Private Travel Clinic Medical Director.
If the nurses work autonomously as a 'nurse led' service then independent nurse insurance is readily available and affordable.
If however there is Dr input (advice and guidance) then you are in the realm of requiring MD cover. The guidance from MDOs (Medical Defence Organisations) is confusing and the quotes vary hugely. Some wish to base their premium on your total income from the vaccinations not acknowledging that the bulk of the clinical work is nurse led and already insured. Another piece of advise is that you will not be able to get cover from an alternative MDO who is not your present MDO as they are averse to sharing risk (it appears that if there is a claim involving shared liability the organisations are more concerned about inter MDO fighting over proportionate liability). I fear patient care and travel services delivered by GP will suffer due to uncertainty and lack of insurance cover.
Dr Rene Skule (personal view)