Firstly – thank you for coming to the LMC about this issue! There is a very robust document outlining responsibilities in communications between primary care and secondary care. It can be accessed here. We have also created a template letter which can be used to reply to the inappropriate request, please remember to copy us into correspondence (removing any patient identifiable data) so that we can identify trends and take appropriate action! Dear Doctor, I note your recent request for investigations to be done in general practice which is attached to this letter. Upon discussion with Morgannwg LMC, We remind you of your professional responsibilities as agreed by Welsh Government, NHS Wales and BMA Cymru Wales: · If Secondary Care require investigations to be done then it is the responsibility of the requesting Secondary Care department to arrange the investigations to be carried out. · If Secondary Care organise investigations, then it is the responsibility of the requesting Secondary Care department to review the results and action them appropriately. · Handing over of responsibility for patient care from secondary care doctors to General Practitioners should only be done when the General Practitioners agrees to accept responsibility. The All Wales Communication Standards can be found via this link: Communication standards between GPs and secondary care | GOV.WALES This position is not intended to be obstructive, but to simply adhere to our duty to provide safe, consistent, and appropriate care for our patients. We are also supported by our statutory representative body Morgannwg LMC.I have copied this email to Morgannwg LMC at office@morgannwglmc.org.uk. Yours sincerely [name of practice]

GPC England has written guidance to help practices reduce extra workload generated by requests from private providers which is an excellent resource in responding to requests from private healthcare which can be found here.

The LMC is not aware that it is National or SBUHB policy to refuse a referral if a template is not completed. The GMC also specifies that relevant information should be included, and this is considered sufficient for appropriate referral. GPC Wales policy is for a universal referral form via WCCG, and not for individual templates. A template does not need to be used if all the information requested on the template is on a referral via WCCG. The LMC therefore advocate for a WCCG referral in the free text box, with the correct referral information. However, if referrals are missing essential information ( which should be made clear on the health pathway), this can be sent back to the practice to be amended and in the future ensure that this information is included. Please do let the LMC know if you have been asked to complete a template, as we can support you in reminding the department of the local & national policies.

Breach of All Wales Communication Standards · Can use Datix if serious, or use the SBUHB communication standards form (very short) · Access via SBUHB Intranet: Primary Care Contractors - Incident Reporting (sharepoint.com) > Hub sites (at top) > Patient Experience Risk and Legal Services > Datix > Primary Care Contractors – Incident Reporting > Chief Medical Officers Standards · Chief Medical Officers Standards is the direct link (but this could change, so access via the route above) · It is a very short form (Drop down GP Surgery; Date of breach; Which communication standard; Which hospital+dept. Free text further details.) · SBU.PCTSGGovSupport@wales.nhs.uk – SBU Primary Care Governance Team for advice Datix NHS Wales Shared Services Partnership > All Wales Programmes > Primary Care Wales Incident Reporting > General Practitioners > Swansea Bay GP logged out form · Only red asterix questions are essential · OnceForWales.CMS@wales.nhs.uk for queries regarding reporting process or technical issues · Location of incident. start typing: o ‘Morriston hospital’ and ‘Singleton hospital’ will show list of inpatient areas o ‘outpatient’ will show outpatient areas across all SBUHB hospital sites o ‘emergency’ shows emergency department and SDEC · Incident type. Common GP issues can be found by o Access > Access to services or admission delayed > Delay in accessing specialist unit/ward o Assessment > Diagnostic testing > Other o Communication > Communication Issues > Communication failure with another care setting o Medication > Medication prescribing o Transfer, Discharge > Discharge > Discharge inappropriate · Reporters view on level of harm and potential harm/priority o None: eg ‘nearly’ given wrong medication o Low: Required minor treatment or extra observation o Moderate: eg transfer to another area, cancelled surgery, change in treatment o Severe: Permanent harm resulted o Catastrophic/death: Directly resulted from incident

Use of the Welsh Clinical Communications Gateway for all clinical correspondence has been agreed by the Local Health Board and the Local Medical Committee. This process has been agreed as there have been instances where email and other, non-WCCG, forms of communication have not been promptly actioned due to the inherent lack of robustness in the process (staff being on annual leave etc). This is to ensure adherence to the “All Wales Communication Standards between General Medical Practitioners and Secondary care” (available here). A sample letter for you to use when replying to such requests is available here.

The Clinical Online Information Network (COIN) houses local clinical guidelines and protocols from across the entire Health Board ensuring high quality consistent cost-effective practice. Library Services play an integral part in maintaining the quality assurance of COIN, in addition to linking to electronic resources such as Full-text Finder and UpToDate. (Please note that this link is to a Swansea Bay Intranet only site and is therefore accessible to Health Board employees only)

The Welsh Clinical Portal (WCP) (please note that this link is to a Swansea Bay Intranet only site and is therefore accessible to Health Board employees only) is a patient record across hospitals and health boards in Wales which is available to doctors and health professionals through a single application. The Welsh Clinical Portal makes it easier for health professionals to collaborate and access vital information about the patient. It shares, delivers and displays patient information from a number of sources with a single log-on, even if that information is spread across health boards. With information in one place it means clinicians always have access to up to date and accurate patient records. The main features include: Requesting tests Electronic test requesting allows clinicians to create test sets, bulk order tests for multiple patients and request tests for a patient on selected days. Prioritising referrals Helps clinicians sort and display electronic referrals into levels of urgency, place them on hold, or request more information from the GP. Creating patient ‘watch’ lists Allows clinicians to keep track of patients more closely by organising patient care in a way similar to how shoppers sort their lists on consumer websites. Viewing your patient’s GP record Clinicians can access a summary of important information held on a patient’s GP record, such as current medication, recent test and allergies. Accessing results Diagnostic test results and reports for are available to view in the portal, regardless of where they are produced in Wales. Accessing radiology images Patients’ x-rays, ultrasound, CT and MRI scans taken anywhere in Wales are available to view in the portal. There is a new National Imaging Viewing User Guide available. Viewing your patient’s medical history Patients’ referrals, discharges, letters, outpatient assessments, clinical notes, care plans, contact lists, and much more are available for clinicians to view at any point in a patient’s journey. Listing medication and prescriptions A pre-populated list of medicines can be important from a patient’s GP record.

What is the problem? HMRC has recently taken a keen interest in the employment status of many independent contractors which includes GPs working in a sessional capacity. In essence, if it determines that you are employed, as opposed to being self-employed, then your tax and national insurance contributions will be removed by the organisation which pays you. In addition, if the organisation has, in HMRC’s opinion, wrongly treated you as self-employed then the organisation can face a significant fine and interest which can potentially go back as far as 20 years. Therefore, this is causing much angst amongst employers. In particular, Health Boards have become very concerned about their potential liabilities and have commissioned specific advice from Deloitte. The Health Board interpretation of this advice has concluded that GPs working for the Health Board but not in a salaried position (e.g. in out of hours centres; in prisons; doing shifts in a minor injuries unit; working in directly managed practices) should be classed as employed for taxation purposes but not for employment purposes. Thus, you would be unable to access employment rights, which includes annual leave / sick leave / maternity leave / and other parental rights. Their assertion applies to all sessional GPs whether working through an intermediary (where IR35 applies) or not. Please note, for avoidance of doubt, this guidance applies also to GP principals or salaried GPs offering services and directly contracting with the Health Board on a sessional basis for the types of work as outlined above. Does GPC Wales believe that the Health Board interpretation of the taxation status is correct for GPs working in above settings? Sadly, it appears that the HMRC toolkit to determine whether an individual is employed or self-employed isn’t always that clear-cut, and thus there are risks to any organisation in getting it wrong. However, we support the guidance in other parts of the UK; namely that blanket application of the ruling is wrong as it doesn’t allow for differences in an individual’s circumstances. Does GPC Wales believe that the Health Board interpretation is correct for the employment status / ability to access employment rights of GPs working in above settings? We do not feel this interpretation is correct. The tests to determine whether an individual is employed for taxation purposes and for access to employment rights are very similar, and it seems nonsensical to say they apply to one section and not to the other. We believe this could be open to challenge by GPs who contract directly with the Health Board. However, if you are working through an intermediary/ personal service company (see below) then it is unlikely that you could argue you are employed for employment benefits. Isn’t this just about the HMRC IR35 regulation? This is wider than the application of IR35 regulations. IR35 solely applies to GPs working through an intermediary such as limited liability companies. These are often described as a personal service company which individuals have set up so that they avoid paying tax and are liable to a lower rate of tax via corporation tax (which currently stands at 19% rather than the tax levels for higher earners) and this is why HMRC at trying to close the loophole. The approach from the Welsh Health Boards applies to all sessional GPs working as above. Matt Mayer from the BMA sessional GPs committee has written an excellent blog on this issue which can be accessed here. Should I just accept the HB advice? We would say no. There are a few issues to consider Lack of consultation: is this fair or right given the significant change to your terms and conditions of service? The assertion that employment status does not confer employment rights Do your own HMRC toolkit assessment and take individual accountant advice Talk to your LMC or contact the BMA if you are a member (unfortunately neither are in a position to offer individual legal or financial advice). WHAT ACTIONS ARE POSSIBLE? 1. What can I do? Consider the BMA website advice, complete the HMRC toolkit and discuss the results with your accountant. You could use it to challenge the Health Board to apply non-employed status to you. However, it is unlikely the Health Board will change its stance and the toolkit isn’t quite clear cut. Consider whether you want to continue working for an organisation that has taken this unilateral action. Your accountant may be able to help guide this with respect to impact on tax brackets etc. Consider whether to ask your LMC to act on your behalf and outline what course of action you wish them to take. You should do this whether you continue working or not. Consider whether you are willing to withdraw services or not? The BMAs sessional GP subcommittee states that you can consider the following: If you are willing to withdraw services, then further think about whether you would add your name to signatures to be gathered by LMCs threatening to withdraw services OR write to the Health Board declaring a termination of service in accordance with the contractual obligations to which you are subject. If you are not willing to withdraw services, then (if you are a GP who contracts directly rather than via an intermediary) consider writing to the Health Board telling them that you believe you are entitled to statutory employment protection and reserve the right to take them to an employment tribunal, and advise them, if employment tribunal found in your favour that you would be chasing historic holiday pay / sick pay / pension etc. back to your start date. This latter needs to be done by an individual GP. 2. What can your LMC do? LMCs do have the responsibility of acting on behalf of all GPs in their area in all their working roles. To do so effectively they need a clear mandate from the workforce affected – therefore you have to play your role in making your feelings known. The LMC can: liaise with Health Board to ask further questions as to validity of this change to terms and conditions of service through seeking to see evidence, challenging lack of consultation, highlighting potential adverse impact on sustainability of workforce and service provision (including whether this is on the Health Board’s risk register) work with the Health Board to find possible solutions e.g. deferred implementation date of changes to enable consultation, devising a zero-hours contract for local GPs to work under which could confer some employment rights etc. keep local GPs up to date with likely impact of these decisions and progress on solutions work on your behalf without you having to raise your head above the parapet e.g. gather signatures from affected GPs threatening to withdraw services; OR collate responses from GPs to the Health Boards declaring a termination of services in accordance with the contractual obligations to which they are subject. 3. What is GPC Wales doing? GPC Wales is: working closely with LMCs to support them in progressing local discussions and solutions on behalf of GPs in their area (that’s why it is important to make your views and situation known to LMCs) in our regular meetings with the Welsh Government, highlighting risks to service provision and workforce sustainability in an already creaking service area, requesting that it seeks assurance from Health Boards on how these risks have been considered, including in respect of winter pressure plans considering what other national solutions may need to be implemented after listening to the profession and seeing how the Health Boards respond e.g. a national zero-hours contract for GPs working in settings as above What already happened in Wales and elsewhere? Betsi Cadwaladr UHB did not use Deloitte to determine its stance but instead worked directly with HMRC. This has already been put in place and GPs have made individual decisions whether or not to accept changes, and this has resulted in less GPs working in directly managed practices. In Dorset, a blanket policy was applied early in 2017 which was challenged by GPs, LMC and GPC. A new deal was offered to GPs with better pay and employment rights and a catastrophe was averted. In Swindon, the OOH trust applied a blanket policy but despite pressure did not back down and this resulted in great difficulty in sourcing doctors. What should I do next? It comes down to whether you as an individual want to take action on this. Please review this guidance carefully and consider all the available options before deciding on your response. The Local Medical Committees and GPC Wales are here to help. We need to know your views to inform our next steps in discussions with Health Boards at a local level, and the Welsh Government on a national basis. Please inform your LMC about what you want to see happen.

Being a GP is a challenging job at the best of times and if you are struggling you shouldn't hesitate to reach out to us for pastoral support, or look into some of the organisations listed on our "support for GPs" section of the website. If you have a specific issue, such as an issue with Swansea Bay UHB, a complaint, practice finance queries or a reference panel then please reach out to office@morgannwglmc.org.uk and we will help.

The GPDF exists to ensure representation, influence and support for Local Medical Committees, GPs and general practice. GPDF Limited has its roots in the early 20th century when its predecessor organisation, initially called The Insurance Defence Fund was founded in 1911. The remit, structure, focus and name (variously General Medical Services Defence Trust and General Medical Services Defence Fund Ltd), has changed and evolved several times over the years but always with a common purpose to support the best interest of publicly funded general practitioners. The GPDF funding structure is on a mutual basis across all GPs throughout Great Britain, based on a principle of shared investment for the common good. This payment is made on a ‘per patient’ basis, collected initially by the LMC, and then contributed on a ‘quota’ basis to GPDF, based on the reported patient population for their area, which they confirm to the GPDF every three years. In this way, every GP and LMC contributes on the same basis for mutual benefit and the collective good of general practice. To find out more have a look at the new GPDF Website.

The Rapid Diagnosis Centre (RDC) based at Neath Port Talbot Hospital is for patients with vague but concerning symptoms that do not fit into any of the existing referral pathways. Referral Guidance is available here. At the RDC, patients will have an individualised assessment with the aim of achieving a diagnosis and initiating a treatment plan, or gain the reassurance that nothing concerning has been found. The Centre has radically reduced the average time to diagnosis from potentially 3 months to 6 days. Out of the case load cancer diagnosis is averaging at 10.5 % and a wide range of other conditions are also being rapidly diagnosed (30-40%) allowing treatment and management plans to be enacted. If you would like to refer please consider the following: Referral via WCCG only but informal discussions are always welcomed Please ensure all Set A has been requested/documented – blood tests as per guidelines and a RECENT WEIGHT, URINE DIP AND FULL EXAMINATION FINDINGS IN TEXT OF REFERRAL LETTER. This is as per agreed referral guidelines If referrals are incomplete in detail or are unsuitable we will process and return as soon as possible Most common reasons for return – site specific symptoms so USC referral to that speciality is more appropriate, or – although we are a vague symptom clinic we are for patients where occult malignancy is the most likely cause – we are NOT a general vague symptom clinic. Again as per referral guidelines and advice. More information is available at their website here or by downloading the Patient Information Leaflet (available in Welsh here).

GPs are required under the GMS contract to provide certain information and certification free of charge. This includes sickness certification, death certification and clinical referral. A full list is set out in Schedule 4 of the NHS regulations can be found here. GPs are often asked to provide medical reports or information for patients/outside organisations which are not contractual. These include: Insurance Company/PMA reports, Legal reports, Occupational Health reports, DVLA reports Reports for Case Conferences/Safeguarding meetings Evidence to support benefit claims & Blue Badge applications. Practices are not contractually obliged to provide such information and therefore when such requests are received can reasonably: Decline to undertake the work, Undertake the work and not charge a fee (at a cost of clinical/administrative time and effort to the practice, which may be considerable and impinge on patient care), Charge a reasonable fee to the requester (outside agency/company/patient themselves). Practices should satisfy themselves that before supplying any patient information to a third party that they have the appropriate patient consent in place. Since the Competition Act 1998, the BMA no longer recommends the levels of remuneration/fees payable for such work. Practices should set their own reasonable fees, taking account of the administrative and clinical burden involved in completion and preferably agree the fee prior to completion of the work.

We have had several practices report an increase in consultations from school pupils and nursery age children regarding fitness to attend school/nursery. The GMS contract makes no provision for such work and therefore other than treating the patient who ‘is ill, or believes themselves to be ill’, there are no circumstances where a GP is required to issue a Med 3 or any letter/report to a school/nursery confirming fitness to attend. GPs are not contracted to advise schools on attendance or medication requirements whilst at school and head teachers have been reminded of this by the Education Minister and Local Education Authorities. Any such request may be considered as extra-contractual and could reasonably expect to be chargeable work. Helpful advice about the management of common childhood illnesses can be found at the following; Is My Child Too Ill For School Health Protection in Schools and Other Childcare Facilites – Chapter 9 Managing Specific Infectious Diseases

The BMA provides guidance for medical practitioners about common fees, including what and when to charge here.

Work out the cost of the service Look at current level of remuneration and cost to deliver service. Have a chat amongst clinical team and with practice manager to decide next steps. If you wish to continue then read no further Payment not covering costs and / or impacting on GMS care? You can withdraw from the service How to withdraw: Give 3/12 notice in writing to the Health Board of your intention and reasons. Ask for them to inform you of where to redirect patients once notice period has ended. Put a time date on response to this and put a diary marker in your diary to check this has been responded too. Copy in the other services affected by the decision Top tip – make sure you get confirmation of receipt – email route perfect for this Continue to provide the service for 3/12 Start updating your staff that service is no longer going to be provided and ensure all know where to refer patients once service has ended. Consider giving them a “script” to use when faced with such requests Start to inform your patients via posters / screen messages / during consultations of when this service will no longer be available and why (if appropriate) The LMC will be developing patient information materials for you to use in some cases Consider how you can best utilise the freed up resource/ time to provide additional capacity within your clinical team Keep track Make a note on your systems when service is due to end Remind all staff after that date that you no longer provide these services and where they should send patients. What if the HB don’t tell you what to do with patients after notice period? Contact the LMC Office Morgannwg LMC is here to support you! It is not unusual to feel concerned at stopping work OR to think that you are the only practice considering taking this action. YOU ARE NOT. Practices can no longer continue providing services at financial or clinical capacity costs to themselves. Follow the checklist above, discuss as a practice and reach your own conclusion.

A Home Office License is NOT required by a GP who keeps opiates in their bag which they have requisitioned themselves directly from the Pharmacist A License is required in those surgeries that order a “central “ supply from which the GPs draw what they need. It is recommended that surgeries which currently or intend to hold drugs in surgery should apply for a Home Office License if they do not have one already.

The BMA have published “Sustainable and environmentally friendly General Practice” which outlines ways in which general practice can develop, and can be helped to develop, environmentally responsible practises. Specific advice regarding reducing the carbon footprint of inhaler prescribing can be found here. Information regarding NHS Wales’ Carbon Footprint can be found here.

At a Morgannwg LMC Committee Meeting, held 13th July 2021, we discussed Global Warming, the contribution from healthcare provision and declared a Climate Emergency. Global warming might be viewed by some as an existential threat to humanity which has to be addressed by politicians not doctors. The 2019 report of The Lancet Countdown on health and climate change outlines the many harms to health which will result from unchecked global warming. These are unfortunately becoming increasingly evident and we believe this makes addressing it the responsibility of all healthcare workers. The Welsh Government have set a Wales wide initiative to achieve a net-zero carbon public sector by 2030. This includes NHS Wales. The LMC believe that Practices that wish to reduce their carbon footprint could do so through the following actions. These are the simplest steps, bringing the biggest reductions, yet do not require large amounts of work in this time of high workload due to the ongoing Covid crisis: * Shift away from using inhalers such as Ventolin Evohaler towards those such as Salamol which have a smaller carbon footprint but can be used in the same way. Global warming from one Salamol inhaler is equivalent to a 60 mile car journey compared to 175 miles for one Ventolin Evohaler. This change can be implemented immediately allowing time for slower changes such as implementing the new All Wales Asthma Guidelines (which emphasise the use of prophylaxis over reliever therapy) or switches to dry powder inhalers. * Find ways to procure sustainably (such as energy from renewable sources). * Reduce car travel to and from surgeries and continue using different ways to consult. The LMC will continue to petition for the implementation of Electronic Transfer of Scripts which will reduce travel associated with obtaining prescriptions from surgery buildings. Further useful resources can be found at: The Greener Practice website links together those in Primary Care who want to deal with the environmental impact of healthcare. The Green Impact for Health Toolkit outlines actions that Practices can take. Green Inhaler website has more information on the environmental costs of different inhalers; a shorter and less detailed comparison is produced by North East Devon Inhalers4u has videos of how to use different dry powder inhalers which can be shared with patients Wales’ small size on a global scale actually makes it easier to achieve change on a nationwide basis. Recognising these factors, Morgannwg LMC accepts that we have a responsibility to act to address the Climate Crisis and seeks to collaborate with other organisations to achieve the aim of net-zero carbon for healthcare in Wales.

This NHS report provides a detailed account of the NHS’ modelling and analytics underpinning the latest NHS carbon footprint, trajectories to net zero and the interventions required to achieve that ambition. It lays out the direction, scale and pace of change. It describes an iterative and adaptive approach, which will periodically review progress and aims to increase the level of ambition over time. Information regarding NHS Wales’ Carbon Footprint can be found here.

Inhalers account for 3-4% of the whole NHS carbon footprint. To reduce the carbon footprint of inhaler prescribing we recommend that health professionals: 1. Optimize asthma and COPD care 2. Use dry powder inhalers or soft mist inhalers as first choice when clinically appropriate 3. If metered dose inhalers are needed then chose brand and regime with care to minimize carbon footprint 4. Ask patients to return all used inhalers to pharmacies for disposal Further information regarding these measures and FAQs are available to download here.

Morgannwg LMC is committed to providing and sustaining a working environment free from any form of inappropriate or unacceptable behaviour; and wish to ensure that all those operating within the organisation are treated, and treat others, with dignity and respect. Discrimination and harassment are unacceptable and that all employees and Members have a role to play in creating a thriving environment for everyone. If you feel you are being harassed, bullied or otherwise discriminated against by someone associated with Morgannwg LMC, or you are aware of others being subjected to such treatment, we strongly encourage you to raise this with us and there are three suggested routes available: Informal direct approach – You may wish to consider first whether you feel able to address the problem informally with the person responsible. If so, you should explain clearly to them that their behaviour is not welcome, or makes you uncomfortable. Informal approach with support – If is difficult for you to engage directly we would encourage you to speak to our Executive Officer / Chair or another member of the Executive Team. They can provide confidential advice and support and also offer to speak to the individual on your behalf. Formal complaint – If informal steps are not appropriate, or have not been successful, the matter can be escalated and formally presented as a complaint in writing to the Chair or any member of the Executive Team. You can be assured that such complaints will be investigated in a timely and confidential manner as per the LMC’s Complaints Policy. Once an investigation is complete you will be informed of its outcome. If it is found that you have been harassed, bullied or otherwise discriminated against by an employee or Elected Member of Morgannwg LMC the matter will be dealt with under the Disciplinary Procedure or via the Constitution. If the harasser, bully or discriminator is a third party, we will consider what action would be appropriate to deal with the problem. Whether or not your complaint is upheld, we will consider how best to manage any ongoing relationship between you and the person concerned. We want people to come forward and anyone, who in good faith makes complaints or participates in any investigation, must not suffer any form or retaliation or victimisation as a result. Morgannwg LMC recognises that certain treatment of or by particular individuals is unlawful and you may wish to seek legal advice. It is however imperative that we know about these matters, regardless of whether or not legal protections and liabilities are triggered, so these bahaviours can be properly addressed.

Morgannwg Local Medical Committee is committed to protecting and respecting your privacy. As part of our representative function we collect certain personal data. This privacy policy will outline the basis on which we hold and use any personal data provided to us in connection with our support and representation of General Practitioners. This policy applies to: The General Practitioners that we support and represent (‘Represented Practitioners’ and ‘Constituents’) Individuals whose personal data we receive in connection with our support and representation of Represented Practitioners (‘Non-Constituents). Our privacy policy can be found using the link at the bottom of this page.

Morgannwg Local Medical Committee is the statutory voice for all NHS GPs and practice teams across the areas of SBUHB. The LMC provides assistance for general practitioners on all matters relevant to general practice such as NHS Regulations, GMS contracts, GPs Terms of Service and Conditions, complaints and partnership issues. The LMC represents GPs in discussion with local and regional health authorities. In addition, Morgannwg LMC is a gateway to pastoral care and provides personal and totally confidential support for GPs and practices in difficulty or experiencing major change. We want to be able to make improvements to ensure that the LMC operates efficiently, effectively, equitably, respectfully and lawfully. Morgannwg LMC therefore encourages constituents, Members and employees to feedback on ways that the LMC needs to improve or to report on any wrongdoing. How to make a complaint or a personal grievance Morgannwg LMC aims to provide the best service possible and operate in a professional and ethical way, but we may sometimes fall short of the mark. If this is the case we would encourage you to speak to whoever you feel most comfortable with within the organisation at the earliest opportunity. We welcome feedback to help us improve our standards and will do our very best to put right anything that has gone wrong. All feedback we receive gives us a chance to know how we are doing and where improvements can be made. All formal complaints, concerns or grievances will be confidentially recorded. If you would like to make a formal complaint or to raise a grievance, you can do this by emailing office@morgannwglmc.org.uk or alternatively by contacting the Medical Director personally. How your complaint, concern or grievance will be managed The Chief Executive Officer of Morgannwg LMC will be designated to lead investigations however concerns can be raised to any member of the Executive team. Oral complaints and concerns satisfactorily resolved informally, will not be subject to the formal procedure as outlined below: All complaints, concerns or grievances will be handled anonymously, if this is deemed appropriate. Details of the investigation, your name and the name of any person accused will only be disclosed on a “need to know” basis (which may include enabling an individual to properly answer any allegations). We will of course consider with care whether any steps are necessary to manage the ongoing relationship between you and the person/s accused during the period of any investigation. Where possible, any investigation will be conducted by someone with appropriate experience and no prior involvement in the situation. You should normally make a complaint or raise a concern within 6 months of the incident causing the problem or within 6 months of the date you discovered the problem. This time limit can be extended, depending on circumstances, as each complaint is treated individually. If you are complaining on behalf of someone else, we will need to make sure they have given their consent for you to do this. Morgannwg LMC will acknowledge your complaint within 5 working days of receipt in writing. The acknowledgement will include the offer of a discussion (which might be by telephone or a meeting) to agree a plan of how the concern will be handled and agree reasonable timescales (response period) for investigating and concluding the complaint. You are very welcome to be accompanied by a family member or colleague for meetings. If you choose to decline the offer to discuss the issue, or do not agree with the response period proposed, the Executive will decide how the complaint will be handled. A letter will be sent setting out how the complaint will be investigated and confirming the expected response date. You should expect to receive a full written response from the LMC Executive team within 25 working days. Some complaints are more complicated and may take longer to investigate. If a full reply cannot be provided within the 25 working day timescale you will be kept updated on progress and the reason for the delay. On concluding investigations the delegated Executive Member will write, confirming how the complaint has been investigated, the evidence considered and giving the conclusion. This will include details of actions the LMC has and will be taking as a result of its findings as appropriate. If you are unhappy about the response you can appeal and we can arrange a conciliation meeting between yourself, the relevant staff and an independent conciliator. The conciliator will talk to both parties and try to help resolve matters for you. You may also be accompanied for this meeting. An appeal should be made within 28 days of the outcome of the investigation. Whistleblowing Some concerns might be of public interest and therefore categorised as whistleblowing. These include: a criminal offence, for example fraud or breaking the law when someone’s health and safety is in danger you believe someone is covering up a wrongdoing You can raise your concern at any time about an incident that has happened, is happening now, or you believe will happen in the near future and can do this either with a prescribed body (more details available via gov.uk) or via the LMC. As a whistleblower you’re protected by law. You must say straight away if you do not want anyone else to know it was you who raised the concern and we will of course consider with care steps that can be taken to manage the ongoing relationships. Due to the potential severity of the wrongdoing, the LMC will take advice from a legal or a prescribed body and you will unfortunately not have a direct say in how your concern is subsequently managed.