MRI scans being requested in the GP’s name by Audiology (Update April 2026)

Following updates on February 1st 2026, 15th October 2025 and 17th October 2025, Morgannwg LMC has written to practices on April 14th 2026 to clarify the current situation as many practices have contacted us regarding this matter:

"Dear Practices

We are aware that many practices have received reports from Audiology containing a statement that the Local Medical Committee (LMC) as of 1 February 2026 "made the decision Audiologists should not be requesting MRI scans within the Primary Care Pathway". We wish to clarify that this statement misrepresents the LMC's position.

The LMC's objection was never that Audiologists should not request MRIs. Rather, our position — supported by formal legal advice — is that investigations must not be requested under a GP's name without that GP's knowledge or authorisation. Key points to note include:

• Medico-Legal Risk: The clinician named on a request is legally and professionally responsible for the clinical justification, follow-up, and any missed results. They will also be liable if audiology request a MRI scan when contra-indicated.

  
  

• GMC Standards: Being named as a requester for a scan you have not reviewed or authorised contravenes GMC standards regarding accountability, honesty, and integrity.

  
  

• System Failure: The current situation is a system-level failing where GPs are being forced to absorb professional risk for decisions made by others.

  
  

The LMC proposed an "opt-in" mechanism to allow a safer transition, but the HB declined this in favour of a universal approach. We have engaged legal counsel to protect your interests and are continuing to press the HB for a compliant pathway where clinical responsibility rests with the actual decision-maker. The following points should be  considered when referring:

• Audiology can and should request the MRI under the name of their own assessors. Not under another GP's name to assess unilateral hearing loss. 

  
  

• GPs can request MRIs for certain conditions including MRI auditory canal or MRI brain, with appropriate information as per clinical guidelines.

  
  

• ENT should accept a referral if an ENT issue remains - such as unilateral hearing loss. If not accepted the Practice should datix and inform the LMC.

The newly launched General Practice & HB Clinical Interface Standards 1 and 5 are very clear about the need for transparency. We advise practices to remain vigilant regarding any requests appearing in their name that they have not personally authorised.

Many thanks

Morgannwg LMC"

We have written to SBUHB outlining these points and will provide updates in due course.

If you have any further questions please do not hesitate to get in touch.

If you receive correspondence following a referral regarding this matter via WCCG or other means, we can confirm that The LMC maintains the opinion that SBUHB audiologists should request MRIs in an ENT's consultant name and the LMC has no objection to this. The only safety measure that the LMC has ever asked is that these investigations are not requested or recorded under someone else’s name. 

Please could you kindly share with us a copy / scan of the actual correspondence  (anonymised). The LMC intend to take this up with the Clinical Leads.

In relation to the patient being referred, and to avoid any further delays, the LMC Exec would suggest that you consider requesting an MRI and then re refer the patient to ENT with result and symptoms of unilateral hearing loss.

For future patient referrals the LMC are suggesting that GPs take the following approach:

Dear Consultant ENT Specialist 

This patient has unilateral hearing loss. This is a specialist area outside the expertise of a GP. I am not the most appropriate professional to assess this further. Please investigate and treat as you feel indicated. I enclose a copy of the audiology assessment.

When we have any developments, we will update practices.

All Wales General Practice and Health Board Clinical Interface Standards (replacing WHC (2018) WHC/2018/014 - All Wales Communication Standards between Primary and Secondary care - AWCS)

These standards have been designed to improve the safety and quality of patient care in NHS Wales and ensure that our patients have the best possible experience as they navigate their pathways. It is a consensus document that has been co-produced with Primary and Secondary Care Clinicians and endorsed by the All Wales Medical Directors.

They apply to all NHS Wales clinicians communicating clinical information between General Practice and Health board run services. They also apply to clinicians working in the private sector who interface with General Practice.

They replace WHC (2018) WHC/2018/014 - All Wales Communication Standards between Primary and Secondary care (AWCS)

Individual professional standards:

1 Investigations:

Any clinician managing a patient’s care who deems an investigation is necessary should: 

Request the investigation 

• Take responsibility for actioning of the result 

• Communicate the result directly to the patient and help them understand it. 

• Delegating these responsibilities is appropriate if there is agreement to do so (see Standard 5).

2 Referrals: 

Any clinician referring a patient for a consultation should: 

• Ensure the patient understands the reason for the referral  

• Ensure the patient knows who is responsible for their care 

• Ensure the patient knows what should happen next 

• Ensure the referral contains all information needed to determine the priority of the referral 

• Make the referral themselves when they have the competence to do so 

When not making a referral themselves, a clinician should never direct a patient to another clinician to ask for a specific referral or expected timeframe for action. Clinicians should respect colleagues' autonomy and allow them to determine what is best for the patient. 

3 Med3: 

The clinician who advises the patient to refrain from work must: 

• Issue the Med3 

• Ensure the duration of the note covers the time period to expected return to work or the next planned review 

4 Prescribing: 

A clinician recommending that a patient starts a new medication must: 

• Issue a prescription if that medication needs to be initiated within the next seven days

• Issue a prescription for a minimum of two weeks but longer if clinically appropriate 

• Communicate all necessary counselling of the patient if recommending another clinician starts the medication 

• Ensure prescribing and prescribing recommendations should be within the scope of practice of the clinician to whom the recommendation is being made 

• Name the responsible clinician when recommendations are from non-prescribers. 

• Adhere to shared care prescribing processes by retaining prescribing responsibility until the GP has accepted the request and received the stable handover letter 

• Take account of guidance provided in the health board’s prescribing formulary and the availability of the medicine in primary care, when initiating or recommending a GP initiates medication(s)  

• Be prepared to retain prescribing responsibility if the medication does not have a UK marketing authorisation (i.e. the medication is unlicensed)

• Be prepared to retain prescribing responsibility if the medication has a UK marketing authorisation but it is being prescribed in a way which is outside the terms of its authorisation (i.e. the medication is licensed but prescribed ‘off-label’), where such prescribing is not generally accepted clinical practice

Organisational Standards

5 Investigations: 

• Organisations should have standard operating procedures (SOPs) to mitigate against clinical governance risks and transfer of clinical responsibility when requesting investigations and actioning the results 

• There should also be SOPs with regards communication of results to patients 

• These SOPs should support clinicians in adhering to the individual professional standards 

  
  

6 Referral and Outpatient Communications:

• Must be compliant with data protection regulations. 

• Must be made via the nationally or locally agreed electronic method where it exists.  

• Must be actioned promptly, including requests for further information 

• Changes to priority must be communicated to the referrer and the patient 

• Should be addressed to the referrer with copies to the patient and their GP if not the original referrer.  

• Referrals that are declined, must be clinically justified and require timely communication to the referrer within the timeframe stated in Planned Care guidance (currently 48 hours).

7 Expedite Requests:

Patients who make contact to expedite appointments should be dealt with accordingly: 

• Should be based on clinical need; a long waiting time does not alter priority 

• For patient experience, clinically valid expedite requests should be dealt with by the team who they contact, rather than directed elsewhere

• Follow-up appointments for review or treatment should be brought to the attention of the specialist overseeing their care for action.  

8 Did Not Attend:

• Care needs to be taken to ensure reasonable adjustments are made for patients with protected characteristics under the Equality Act. 

• Where patients do not attend for out-patient appointments without giving notice, in line with WG guidelines for pathway management, they will be discharged. 

• The original referrer, the GP (if not the original referrer) and patient should all be advised of the discharge. 

• Where the patient has reasonable grounds to challenge the decision, they should be reappointed without a new referral. 

• In the case of vulnerable adults and children who do not attend refer to the local “was not brought” policy 

9 Patient Discharges:  

• Electronic discharge advice letters (eDAL) should be completed at the time of discharge, and a copy sent with the patient 

• Patients should be discharged with at least two weeks of medication (which may be supplied from the hospital or from medication already in the patient’s possession. Where there may be a longer than usual time needed to source a medication in primary care (e.g. where a special formulation or unlicensed preparation is prescribed), consideration should be given to providing at least four weeks of medication at discharge  

• Discharges out of hours should ensure appropriate handover to Out of Hours providers e.g. End of Life Care. 

• Similar information should be provided for completion of an ambulatory care assessment. 

10 Pre-operative Assessment Clinics 

• Must have named medical support  

• Should first use the named medical support when unexpected findings are identified. Refer internally for optimisation for surgery, or an appropriately commissioned optimisation service  

If you are aware of a breach of these standards, please datix the incident and contact us so that we can ensure these standards are upheld throughout Swansea Bay.

09-04-2026_General Practice & HB Clinical Interface Standards.pdf

Download PDF • 1.66MB

BMA advice on declining non-GMS / unfunded work or work inappropriately transferred from secondary care

The clinical and professional responsibility you have for your patients does not mean that you must provide services over and above those for which you are contracted, or that you cannot give reasonable notice to cease doing such additional services.

The BMA has useful advice regarding how to answer responses you encounter when declining non-GMS or unfunded work:

'It's not professional'

What I do outside my contract is a personal choice and plenty of other professionals decline extra work if the remuneration is not appropriate.

'This is a GMC matter'

It is not a matter for the GMC and indeed, threatening referral and using this as a threat for me to work extra in my own time is harassment. I continue to deliver everything expected of me as required under my contract [latest information on the 2025-26 contract available here and GPDF have funded a useful consolidated document “NHS General Medical Services Contracts Regulations Wales Consolidated 2025”] and Good Medical Practice [download here]. Whether or not I undertake additional extra-contractual work is my choice.

'You have a responsibility to the patients'

And I take that responsibility very seriously and will continue to fulfil all aspects of my contract and continue to deliver excellent care. However, I cannot be forced or made to feel guilty about not undertaking extra work in my own time for inadequate rates of pay.

'Your colleagues are doing this work'

Being extra contractual it's a matter for personal choice.

'You are taking money from other staff'

The funding of the health service is a matter of political choice for the government. I am only asking to be paid fairly for work I undertake that is outside of my contract.

'You are taking money from patients'

The government have a responsibility to provide a health service, it is not the responsibility of individuals. Part of that responsibility is to pay staff enough to motivate them. It's a political choice.

'There is a financial crisis'

It's not fair that the public sector is expected to pay for every financial crisis when others in the economy do not. We cannot expect NHS staff to subsidise the service with their own pay.

'It is not in our budget'

It is not my responsibility to ensure that sufficient budget is allocated to adequately pay doctors to provide the service.