1. Routine data sharing
2. Emerging and urgent concerns
3. Local regulatory alignment
4. Risk and quality summits
5. Strategic collaboration
Annex 2: Information sharing with the GMC
Annex 3: Information sharing with CQC
Annex 4: Potential illegal practice
A doctor who is registered overseas but not in the UK and who specialises in treating a particular medical condition is visiting the UK to provide consultations to patients affected by the condition. These are at a hotel or in someone’s home rather than in a clinical setting (if consultations are within a clinical setting see scenario 3 or 4).
CQC action
Refer information to GMC Registration Information team to investigate. A breach of the legislation relating to illegal practice may have taken place.
Also, assess information to determine whether there is any action for CQC registration team to take.
GMC action
Investigate to determine whether a breach of the legislation in relation to illegal practice has taken place, and if so, take appropriate action in line with procedure.
Refer information to CQC for intelligence-gathering purposes.
It is discovered that an unregistered doctor employed by a CQC-registered clinic has written a prescription.
CQC action
Refer information to GMC Registration Information team to investigate whether the prescription has been written by an unregistered doctor.
If it has, investigate provider with reference to Regulation 19 and take appropriate action.
If prescription fraud has occurred, review to determine whether further investigation of the clinic is necessary.
GMC action
Investigate to determine whether the actual doctor has written the prescription, or the ‘patient’ did, and report findings to CQC.
If the doctor wrote the prescription take action in line with illegal practice procedure.
If a third party (including the ‘patient’) wrote the prescription take action in line with doctor impersonation procedure.
A member of the public reports that they have been treated by an unregistered doctor at a clinic registered with the CQC, or had a consultation with someone claiming they are registered/licensed when they are not.
CQC action
Investigate provider with reference to Regulation 19 and take appropriate action.
Share information with Registration Information team so they can consider what action should be taken against the unregistered doctor.
If action is indicated by both CQC and GMC, arrange discussion to agree action plan.
GMC action
Share information with CQC so they can consider action against the provider.
Investigate to determine whether a breach of the legislation in relation to illegal practice has taken place, and if so, take appropriate action in line with procedure.
If action is indicated by both CQC and GMC, arrange discussion to agree action plan.
A member of the public reports that they have been treated by an unregistered doctor at a clinic that is not registered with the CQC, or had a consultation with someone claiming they are registered/licensed when they are not.
CQC action
Refer information to GMC Registration Information team to investigate. A breach of the legislation relating to illegal practice may have taken place.
Also, assess information to determine whether there is any action for CQC registration team to take.
GMC action
Investigate to determine whether a breach of the legislation in relation to illegal practice has taken place, and if so, take appropriate action in line with procedure.
If regulated activities appear to be taking place, refer information to CQC for intelligence-gathering purposes.
A doctor who is not registered in the UK and based overseas (registered or not) is undertaking consultations with patients based in the UK via Skype or telephone.
CQC action
Refer information to GMC Registration Information team to investigate. A breach of the legislation relating to illegal practice may have taken place.
If there is evidence of prescribing medication which is to be dispensed in UK, and company is based in UK, CQC to investigate.
GMC action
Investigate to determine whether a breach of the legislation in relation to illegal practice has taken place, and if so, take appropriate action in line with procedure.
If there is evidence of prescribing medication which is to be dispensed in UK, and company is based in UK refer information to CQC.
Overarching principles to be followed
If clinic is not CQC-registered, GMC to lead on what action to take against the individual. If there is evidence of regulated activities taking place, GMC to refer information to CQC for intelligence purposes.
If clinic is CQC-registered, CQC to lead on what action to take against the provider. CQC to refer details to GMC to consider whether action should be taken against the
individual undertaking illegal practice.
If clinic is CQC-registered and there is evidence of illegal practice by an individual, GMC and CQC to agree action plan so as to avoid duplication of effort (eg in
referring to the police), as provider may also want to take action.
CQC to report illegal practice to the GMC’s Registration Information team.
GMC to report illegal practice to the CQC by emailing the CQC escalation contacts in Annex 1.
Snippet for joint working with GMC
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Joint operational protocol between CQC and the General Medical Council