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Following a "discussion" on MRIs being requested by audiology in the GP's name at PLTS on 16/10/25, Morgannwg LMC has written a formal complaint on behalf of the constituents regarding the conduct of a recent presentation concerning MRI scans being requested in the name of General Practitioners.


Several constituents attempted to submit legitimate questions and concerns via the moderated discussion platform. We are profoundly disappointed to report that these attempts at open discussion were actively censored. Numerous submissions from our members, including key questions highlighting that this requesting pathway appears to contravene established General Medical Council (GMC) guidance that clinicians should not request investigations using another clinicians name, were neither published for general viewing nor put to the presenters for a response. If a similar request was made of secondary care consultants to authorise other persons to request investigations in their name, we would expect them to have similar concerns. Several constituents also felt that it was incorrect to suggest that mastoid abnormalities and vascular abnormalities impinging on the 8th nerve are "incidental" findings in a scan requested for a patient with ear symptoms to regard them as such raises concerns regarding the capabilities of those reporting the scans, concerns which, again, they were unable to raise for discussion. 

 

Morgannwg LMC had previously encouraged its constituent GPs to ensure that all outstanding professional concerns regarding this pathway were robustly discussed at this forum and discussions with the Health Board led us to believe that there would be the opportunity to do so on 16/10/25. The failure of the moderator to allow any opportunity for these critical points to be addressed is unacceptable and undermines the spirit of collaboration and transparency required between primary and secondary care services.

 

Our concerns which remain outstanding and are summised on our website at: https://www.morgannwglmc.org.uk/post/mri-scans-being-requested-in-gp-s-name .We strongly urge practices to consider these ethical and professional matters when engaging with the pathway as it has been described. It is the view of Morgannwg LMC that the pathway is unlikely to be withdrawn completely as it is regarded as a success by the Health Board, despite the gap in commissioning ths service which has resulted in this demand for MRI scans to be requested by audiology in the name of the GP,  and reduces the workload for the ENT department.

 

We have requested a formal explanation from the Health Board as to why legitimate questions relating to professional guidance were censored, and what steps will be taken to ensure open and honest dialogue on contentious clinical pathways moving forward.

 

We would very much welcome feedback regarding this issue so please do not hesitate to contact us with any questions or queries.



 

 
 
 

The LMC understand that within a PLTS session on 16/10/25, audiology requesting MRI results in a GPs name will be discussed.

 

Whilst there are many merits to the work being undertaken by audiology, there are several points that the LMC believe practices should be mindful of:

  1. GMC: "Delegating tasks or responsibilities appropriately" states that "You must give clear instructions when delegating, including about what needs to be done, by whom and by when." The LMC believe that this is breeched by allowing a test/MRI to be organised on your behalf.

  2. This could result in the GP taking on the risk by proxy for issues which arise (eg patients with metal in their head and are inappropriately given an MRI)

  3. It is a breach of the All Wales Communication Standards section 2 " Results of investigations remain the responsibility of the requesting clinician, and under section 3 " It is the responsibility of the requesting doctor to arrange for investigations to be carried out."  

  4. Could this set a precedent for more requests and how might this affect GMPI?

 

The LMC are concerned that although these are very well intended programmes, they are relying upon GPs to act when secondary care colleagues are either not confident to do so, or  alternatively, when secondary care are under resourced.  

 

Fundamentally this is a practice decision and one that we feel is important to collectively discuss.

 
 
 

Contractual Requirements and Data Entry

 

  • A new flu vaccination delivery model has resulted in some operational challenges.

  • All provider practices must adhere to the National Primary Care Contractual Instruments (PCCIs) Schedule 2025 ( attached), which is the same for both general practices and community pharmacy to ensure equity of service.

  • The specification requires that vaccine administration and stock checks must be data entered onto the WIS system by the end of the working day.

  • Due to significant and sporadic outages of the WIS system, practices were previously authorized to input data on the following working day, a situation which may have caused confusion.

  • Practices must log any data upload concerns with the primary care team and immunisations team via the general primary care email (even on weekends) to maintain an audit trail. A DHCW service point call is also recommended for evidence.

  • The Health Board (HB) agreed to send out a communication to clarify contractual data entry requirements and address any confusion.

 

Functionality and Use of WIS

 

  • Practices reported that WIS flu invites were being sent too late, causing patients to miss appointments.

  • WIS is sending generic blanket text messages that invite patients to a session rather than a specific time.

  • It was agreed that the specification allows practices to use their in-house appointment systems or "established booking system including GP Clinical systems" to invite patients for flu vaccination; the specification does not mandate using WIS for flu invites.

  • Opportunistic administration of the flu vaccine is encouraged.

  • There is confusion because the requirement is to ONLY use WIS to invite patients for the COVID-19 vaccine, which is difficult to manage alongside the separate rules for flu, especially given changes to the eligible age ranges.

  • The HB confirmed the technical ability to use WIS for both flu and COVID-19 invites, but noted "teething problems."

  • The HB agreed to issue a clarification immediately to address misinformation regarding invitation methods.

 

WIS Write-Back Delays

 

  • Significant WIS write-back delays were reported (up to four days), which creates a clinical governance risk as patients could receive the vaccine from another provider (e.g., a pharmacy) during the delay period.

  • A national update was shared indicating the WIS platform had been down from 6-9 October to address duplicate entries. Duplications were found from both clinical systems (EMIS/Vision) and WIS, as well as some unexplained duplicates.

  • The impact of these delays on the practice's ability to call and recall patients will need to be monitored.

 

HB Vaccination Assurance

 

  • The HB has not started any general 'mop-up' programme and plans to begin administering to the general population only on December 1st, 2025, as per the national specification.

  • Requests to vaccinate housebound patients have been declined, with a request made for those practices signed up to the supplementary service to administer.

  • The HB has agreed to a request to vaccinate care home residents for flu. This area needs greater clarity and coordination for future years, as the HB administers COVID-19 in care homes while practices are asked to do the flu vaccine.

  • A national Task and Finish Group has been set up to specifically resolve care home vaccination challenges.

  • Other groups who may have been vaccinated by the HB include pregnant women at HB clinics and NHS staff, which may have caused confusion.

  • Due to responding to specific practice-based requests, the HB is currently unable to issue an assurance that no flu vaccines have been administered.

 

Uptake Targets

 

  • Practices still have a 75% target rate for vaccination.

  • The HB is confident there is enough stock for all eligible over 65s.

  • Uptake for 2-3 year olds and at-risk groups remains low, consistent with previous years.

  • A representative noted that recent negative discussions in the media have affected this year's uptake, and asked the HB to update the website with more guidance to help patients research vaccine safety.

  • The HB agreed to look into ways to disseminate patient information.

 

Patient Booking Phone Line

 

  • Patient delays were reported when using the immunisation service booking line.

  • The HB confirmed a phone outage on one specific day in October. Outside of this, the average call waiting time was 3 minutes, with the longest reported wait being 10 minutes.

 
 
 
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