Registration Policy

Safe Surgeries – New Patient Registration Policy

Introduction

Patient registration is determined by the provisions of the practice GMS or PMS contract and terms of service. This policy is based on the NHS England Standard General Medical Service Contract, the General Medical Services Contract Regulations, Primary Medical Care Policy and Guidance Manual (PGM) and CQC guidance.

Practices are assumed to have open lists unless they have complied with the procedures for list closure as detailed in the General Medical Services Contracts Regulations. Where a practice has an open list it is required to:

  • accept the registration of a new patient unless it has fair and reasonable grounds for not doing so
  • accept allocations by the ICB to its list.

The practice can formally close their list to new patients by requesting permission from its commissioner. Formal list closure lasts between three to twelve months, and cannot last less than three months.

In some cases, it may be possible to request an ‘informal’ or ‘temporary’ list closure, lasting less than three months, for example where staffing difficulties result in suspension of registrations being necessary. GMS and PMS contracts do not allow for these types of list closures, but taking into consideration possible risk to patient care, the practice can discuss these circumstances with their commissioner, who can either provide further support or approve temporary closure, if appropriate.

 

Patient Choice of GP Practice

From 5th January 2015, all GP practices in England are free to register new patients who live outside their practice boundary area, without obligation to provide home visits. This will provide patients with greater choice and aims to improve the quality of access to GP services.

Patients may wish to register as out of area patients to:

  • register with a practice in more convenient locations, such as a practice near their work or closer to their children’s schools, or they reside within the area during the week, but their permanent address is in another area
  • stay registered with their current GP if they have moved home but do not want to change GP
  • register in an area with better access to services

These new arrangements are voluntary for GP practices. If the practice has no capacity at the time, or feels it is not clinically appropriate or practical for patients to be registered so far away from their home address, they can still refuse registration for out of area patients. The practice should explain their reason for refusing registration to patients. When registration is refused, patient choice is not fully realised.

 

Digital registration and PMS1 new form

An online registration service and corresponding paper form, developed by NHS England is now available to all practices in England to use. More information here.

All GP surgeries in England must offer the national NHSE ‘Register for a GP surgery’ service and new paper registration form from 31st October 2024. The GMS1 form is being phased out and will not be available to order, or access online from 31 October 2024.

It is possible for patients to register via paper form or digital/online and practices should make clear to patients the different ways in which they can register with the practice. Updates to the GP contract in 2022/2023 removed the need for a patient to provide a wet signature for registration. The new PRF1 paper form which aligns with the online service is available here.

 

New Patient Acceptance/Refusal

Practices should ensure there is equitable access for all patients who wish to register with them. Registration should be available to all patients every day rather than on particular days and throughout the practice’s advertised opening hours. Where possible, it is good practice for practices to provide pre-registration documentation in advance, e.g. to help patients understand the practice and the services they deliver.

The practice will accept patients onto its list while it remains “open”. If the list is closed, the practice will only accept registrations of immediate family members of patients who are already registered and only if such relatives reside permanently at the registered patient’s address.

Under the terms of their primary medical services contracts, GP practices cannot refuse an application to join its list of NHS patients on the grounds of race, gender, social class, age, religion, sexual orientation, appearance, disability or medical condition.

The practice will, however, refuse registration if the commissioner has agreed that they can close their list to new patients. The practice can also refuse registration (subject to a partners’ discussion and agreement) if:

  • The patient lives outside the practice boundary
  • If they have other reasonable grounds

The reason for refusal will be in writing and recorded in a permanent record for that purpose. This excludes temporary residents, where no record is necessary. The permanent record will consist of the original PMS1 registration form endorsed with the reason for refusal, together with a copy of the refusal letter, filed in surname order. Where a PMS1 has not been completed, a “dummy” PMS1 will be prepared and filed. The record is subject to inspection by the ICB, who may require the practice to justify a refusal to register.

 

ID and Proof of Address

There is no regulatory requirement to prove identity, address, immigration status or the provision of an NHS number in order to register. ID and/or proof of address may be requested to assist with the administrative process, but the practice must apply the same process for requesting documents to all patients requesting registration equally.

The majority of patients will not find it difficult to produce documents. However, there will be some patients who do live in the practice area, but are legitimately unable to produce any of the listed documentation. Examples include:

  • People fleeing domestic abuse staying with friends, family or in a shelter
  • People living on a boat, in unstable accommodation or street homeless
  • People staying long term with friends but who aren’t receiving bills
  • People working in exploitative situations whose employer has taken their documents
  • People who have submitted their documents to the Home Office as part of an application
  • People trafficked into the country who had their documents taken on arrival
  • Children born in the UK to parents without documentation.

Reasonable exceptions need to be considered and the individual registered with sensitivity to their situation. As there is no requirement under the regulations to produce identity or residence information, the patient MUST be registered on application unless the practice has reasonable grounds to decline, as outlined above. Lack of ID/ proof of residence would not be considered reasonable grounds to refuse to register a patient and access to appointments should not be withheld in these circumstances. If a patient cannot produce any supportive documentation but states that they reside within the practice boundary then practices should accept the registration.

Where necessary, (e.g. homeless patients), the practice may use the practice address to register the patient, putting CO (care of) at the start of the address (as per CQC and PCSE advice). If possible, the practice should try to ensure they have a way of contacting the patient if they need to (for example with test results).

If a practice suspects a patient of fraud (such as using fake ID) then they should register and treat the patient but hand the matter over to the NHS Counter Fraud Authority (NHSCFA).

  • NHS Counter Fraud Authority Reporting Line: 0800 028 4060
  • report to the NHSCFA using the online NHS fraud reporting tool
  • by post to the NHS Counter Fraud Authority, Skipton House, 80 London Road, London, SE1 6LH

Access to online services

Should any patient request online access, then confirmation of identify is required via the following methods:

  • Documentation
  • Personal vouching
  • Vouching with confirmation of information held in the patient record

More detail can be found in the guidance here.

 

Temporary Residents

 If a patient is resident in the practice area for more than 24 hours, but less than three months, they should be offered the option of registering as a temporary patient. In some cases (e.g. someone housed in temporary accommodation) a prospective patient may not know how long they will reside in the area.

Please note: If there is uncertainty around the length of time a patient will reside in the practice area, NHS England advises that the patient should be registered as a permanent patient. For example, asylum seekers residing in Home Office accommodation should be registered as permanent patients.

 

Emergency Treatment

 All GP practices have a contractual duty to provide emergency treatment and immediately necessary treatment free of charge for up to 14 days. This applies to any person within their practice area who:

  • Has been refused application for inclusion in the practice’s list of patients
  • Is not registered with another provider of essential services
  • Has had their application for acceptance as temporary resident rejected

 

Support and Additional Needs

If a prospective patient requires additional support in order to register, the practice will do its best to accommodate this. This includes (but is not limited to):

  • Walking them through the registration process in a more private area of the practice
  • Using a translator/ interpreter
  • Noting any accessibility requirements on the patient’s record so that the practice team is aware and can support them as necessary.

Once the patient is registered, the patient may benefit from other forms of support, including but not limited to:

  • Provision of double appointments
  • Reducing/ increasing prescription duration as necessary
  • Promoting clear boundaries for consultations
  • Providing fast access to a named GP
  • Waiving normal charges for housing letters or medical reports

Ensuring services are accessible to everyone who needs them is mandatory. This includes following the Accessible Information Standard and provision of interpreting and translation services.

Registering Vulnerable Groups

Children

If a child under the age of 16 attempts to register alone, or with an adult who does not have parental responsibility for the child, the safeguarding lead Dr Savithri Wijayatilake  should be informed.

It is recommended that the GP practice gains assurance by:

  • Obtaining proof of identity for each child registering (e.g. a passport, or birth certificate). If a child does not have any form of ID, this should not prevent them from being registered. In this case, register the child, but ensure that the safeguarding lead is made aware of the registration.
  • Ensuring that an adult with parental responsibility is present at registration (and that they can prove parental responsibility).
  • Offering a child a new patient health check
  • Obtaining supporting documentation from other official sources (e.g. previous GP, social workers etc).

Where any doubt exists, the GP surgery’s safeguarding lead is to be informed and appropriate actions taken.

People with Insecure Immigration Status

Everyone in England, regardless of their immigration status, is entitled to free primary care and to register with a GP. This includes temporary visitors/ tourists, asylum seekers, refugees and other vulnerable migrants. A patient does not need to be ‘ordinarily resident’ in the country to be eligible for NHS primary medical services – this only applies to secondary (hospital) care. In effect, therefore, anybody in England may register and consult with a GP without charge.

When registering a patient, do not ask about their immigration status, or to see proof of it. People seeking asylum should be registered as permanent patients.

The PMS1 registration form includes supplementary questions about immigration status. These questions are optional – patients do not have to complete this section if they do not want to and this should be communicated clearly to patients. If a patient does opt to complete this section, they should not be asked to provide proof for the information they have provided.

People Experiencing Homelessness

Individuals experiencing homelessness, those without a fixed address, or afraid to share their address, should be registered under either:

  • an address of their choosing (e.g. a friend’s address, religious institution, or community centre). Advise the patient that they may receive confidential medical letters to this address, and that they should have the occupier’s consent
  • under the practice address. When registering the patient, enter the full address, including postcode for the GP practice, putting Care of’ at the start of the address. Writing ‘no fixed abode’ in any field will cause the registration request to be rejected.

Ensure that patients are advised to regularly check for post at the address they are registered at, so as not to miss any important medical correspondence (e.g. secondary care appointments).

Duty to refer

The Homelessness Reduction Act (2017) came into force in 2018. It places renewed emphasis on homelessness prevention. Section 10 requires public authorities in England to notify a local housing authority (LHA) of service users they think may be homeless or at risk of becoming homeless.

This statutory duty to refer applies to:

  • NHS organisations that provide inpatient care
  • emergency departments
  • urgent treatment centres.

It is not mandatory for primary care providers. However, it is still beneficial for GP practices to refer patients who are homeless, or are at risk of becoming homeless, to a local housing authority for further support.

Referrals must include:

  • the service user name
  • their contact details and
  • an agreed reason for referring the user.

You can refer without consent to safeguard children and vulnerable adults. Guidance on the duty to refer can be found here.

 

Patients About to be Released from Prison

The process for registering patients prior to their release from the “secure residential estate” which includes prison, immigration removal centres, young offender institutions or secure training centres, is outlined here.

Veterans

Ex-service personnel or reservists will be provided with copies of their medical records by DPHC (Defence Primary Health Care) on leaving the Armed Forces and becoming a veteran. These records should be given to their new GP practice on registering.

Armed Forces veterans are entitled to priority treatment if their injury or condition came about because of their service (subject to clinical need). This is regardless of whether they receive a war pension. Further guidance can be found here and here.

When registering veterans, the following SNOMED code should be entered at the time of registration: Military veteran SCTID: 753651000000107. Having this code will enable access to specialist care or charity support as necessary for the patient.

Mental Capacity Act

If a person is unable to register because they are unable to make decisions about their care, registration can be done by:

  • A relative
  • The main carer
  • A lasting power of attorney
  • A person appointed by a court under the Mental Capacity Act

NHS Health Checks and New Patient Health Checks

All newly registered patients should be offered a New Patient Health Check. Some patients may also be entitled to an NHS Health Check. It is a contractual requirement that once registered all patients must be invited to participate in a new patient check however neither registration nor clinical appointments should be delayed because of the unavailability of a new patient check appointment.

Please also see translated patient health questionnaires for people seeking asylum and refugees which can be shared during registration to improve efficiency and effectiveness of New Patient Health Checks.

Using the New Patient Questionnaire (or a locally-developed version), Health Care Practitioners should record on clinical systems, using the above SNOMED codes, whether the Initial Health Assessment has taken place or been declined.

  • 1874651000000105 | Initial health assessment using New Patient Questionnaire for newly arrived migrants in the United Kingdom (procedure)
  • 1874641000000107 | Initial health assessment using New Patient Questionnaire for newly arrived migrants in the United Kingdom declined (situation)

Further Resources and Guidance

Sign up for updates, events and resources. More information on the Safe Surgeries programme can be found at https://www.doctorsoftheworld.org.uk/safesurgeries/.

Contact us at safesurgeries@doctorsoftheworld.org.uk.

 

Accessing someone else’s information

Accessing someone else’s information

As a parent, family member or carer, you may be able to access services for someone else. We call this having proxy access. We can set this up for you if you are both registered with us.

To requests proxy access:

  • collect a proxy access form from reception from 10am to 6pm

Linked profiles in your NHS account

Once proxy access is set up, you can access the other person’s profile in your NHS account, using the NHS App or website.

The NHS website has information about using linked profiles to access services for someone else.

Privacy Notice – Accurx

As part of the Digital First National programme of work, GP Practices are required to provide a tool for patients to access primary care services.

The aim of the Accurx platform is to improve communications between healthcare staff and patients resulting in improved outcomes and productivity. The platform facilitates digital communications between the practice and our patients.
Using the Accurx platform will require the processing of special category data by Accurx, their sub-processors and by default the GP Practice as a Controller. This will include; exchanging and storing messages in relation to patients and medical staff, performing video consultations (these will not be recorded or stored) between healthcare staff and their patients This will allow you to respond to the Practice in multiple ways such as; free text, questionnaires and submitting images/documents.

If you have a non-urgent healthcare concern or need to contact the Practice for any medical or admin reason, click on the online via our website or via NHS app or via NHS website. Fill out the online form, which will then be reviewed and processed by our healthcare professionals to decide the right care for you. We will respond to online requests within 2 working days for medical queries and 5 working days for admin queries.

Accurx is approved by NHS England to be used by GP practices and the other systems involved in patient care. NHS England has a lengthy assurance process to make sure they meet the highest standards of safety and security. Your data is safe and is shared only with your GP Practice for the purposes of your direct care. Your data is stored and sent securely using industry best practices, and Accurx only collect the data that is necessary to allow your GP Practice to provide you with care.

The Practice uses the following Accurx features:

·         Online consultations

·         Video consultations

·         AccuMail

·         SMS

·         Friends and Family test

·        Record Views

The Accurx privacy notice can be found on their website here: Accurx | Privacy Policy.

1) Controller

contact details

 

 

Bromley Common Practice

 

2) Data Protection Officer contact details GP Data Protection Officer

gpdpo@selondonics.nhs.uk

3) Purpose of the processing The aim of the Accurx platform is to improve communications between healthcare staff and patients resulting in improved outcomes and productivity. The platform facilitates digital communications between the practice and our patients.
4) Lawful basis for processing Under UK GDPR and DPA 2018 –

6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’.

9(2)(h) ‘…medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems…’

5) Recipient or categories of recipients of the shared data Data may be shared with Accurx, and their sub-processors such as cloud services used for Accurx’ own storage, communications, security, engineering, and similar purposes.
6) Rights to object You have the right under Article 21 of the UK GDPR to object to your personal information being processed. Please contact the Practice if you wish to object to the processing of your data. You should be aware that this is a right to raise an objection which is not the same as having an absolute right to have your wishes granted in every circumstance.
7) Right to access and correct You have the right to access copies of the data that is being shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law.
8) Retention period The data will be retained for active use during the processing and thereafter according to NHS Policies and the law.
9)  Right to Complain. You have the right to complain to us about the way your data is handled or processed. To so, please contact the Practice using the following details:

 

Bromley Common Practice

Crown Medical Centre, 3 Mackintosh Street, Bromley BR2 9GT

 

If you remain unsatisfied with our response, you have a right to complain to the Information Commissioner’s Office. To do so, you can use this link https://ico.org.uk/make-a-complaint/data-protection-complaints/ or call their helpline

Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website).

 

 

Suggestions, Comments and Complaints

We make every effort to give the best service possible to everyone who attends our practice.

In the majority of cases the best way to resolve your concerns as quickly as possible is with the front line staff or the service or organisation that you are complaining about.

However, we are aware that things can go wrong resulting in a patient feeling that they have a genuine cause for complaint. If this is so, we would wish for the matter to be settled as quickly, and as amicably, as possible.

Simply contact the Practice Manager preferably in writing via our  Contact Us page or by completing a complaints form available in surgery, and she/he will set all the necessary wheels in motion. Alternatively please visit our feedback form if you have any suggestions.

We are continually striving to improve our service. Any helpful suggestions would be much appreciated and a suggestion box is located in the waiting area.

London Care Record GP Short Privacy Notice

This practice uses a shared record system called the London Care Record. The London Care Record is a secure view of your health and care information and lets health and care professionals involved in your care see important details about your health when and where they need them. Having a single, secure view of your information helps speed up communication between care professionals across London, improves the safety of care and can save lives.

London Care Record can only be lawfully looked at by staff who are directly involved in your care. Your information isn’t available to anyone who doesn’t need it to provide treatment, care and support to you. Your details are kept safe and won’t be made public, passed on to a third party who is not directly involved in your care, used for advertising or sold. For more information please read the London Care Record privacy notice for South East London here:  The London Care Record – South East London ICS (selondonics.org)

Opting out of the London Care Record

You have the right to object to your information being available through London Care Record. Although patients have the right to object and request restrictions on sharing their records, there may be instances where this request will not be upheld due to a clinical need as determined by the direct care giver. Please discuss this with your GP/ health and social care worker and you can find further information in this London Care Record leaflet.

For further information and advice about data protection or your right to object to sharing your data you can contact the team at Lewisham and Greenwich Trust who manage the London Care Record for South East London www.lewishamandgreenwich.nhs.uk/london-care-record  or you can call 020 3192 6011 and leave your name and number for someone to contact you.

If you have already requested to stop sharing on ConnectCare/Local Care Record in South East London, then you will not have to request this again for London Care Record.

Named GP

Each of our GP’s take a section of the alphabet for patients’ surnames and generally see these patients, for consistency purposes and will do any referrals onto specialists for these patients.

If you would like to book with your ‘named’ GP please see the list below.

However this is optional and you are free to book with the GP of your choice.

PATIENT ALPHABET SPLIT FROM 1st June 2023

GP ALPHABET
Dr Savi C D F G I
Dr Vinyas J L P W X Y Z
Dr Sriwardhana H S T
Dr Kulkarni K M N O Q U V
Dr Patel A B R E

Disability Access

If you have any special needs please let our staff know so that we can help and ensure you get the same support in the future.

Wheelchair access

Our premises have easy access, wide corridors, no steps, and a toilet for the disabled.

If you have any difficulty in using our facility do please ask a member of staff who will be pleased to assist you.

Disabled Parking – Blue Badge Scheme

The Blue Badge scheme is for people with severe mobility problems. It allows Blue Badge holders to park close to where they need to go.

Loop System

We have a loop induction system please ask reception for more details. For more information on the loop hearing system visit Hearing Link website.

• British Deaf Association

• The Deaf Health Charity – SignHealth

• Action Hearing Loss

• Royal Association for Deaf People

• National Deaf Children’s Society

Blind/Partially Sighted

If you or family members are blind or partially sighted we will try our best to provide help and assistance for you. If we cannot provide leaflets we will be very happy to explain and research information that you require. Just ask at reception and staff will either help directly or pass your request on to the Practice Manager.

For more advice and support for blind people please see the following websites:

• Royal National Institute of Blind People (RIND)

• Action for Blind People

• Blind.org.uk

• British Blind Sport

Guide Dogs

Guide dogs are welcome at the surgery with a bowl of water available upon request.

Other Disability Websites

• BID Services

• Disability Go

• Disabled People, your Rights, Benefits, Carers and the Equality Act

• Disability Rights UK

• Living with a Disability NHS Choice

• Disability Action

• Mencap

Freedom of Information

The Freedom of Information Act creates a right of access to recorded information and obliges a public authority to:

• Have a publication scheme in place

• Allow public access to information held by public authorities.

The Act covers any recorded organisational information such as reports, policies or strategies, that is held by a public authority in England, Wales and Northern Ireland, and by UK-wide public authorities based in Scotland, however it does not cover personal information such as patient records which are covered by the Data Protection Act.

Public authorities include government departments, local authorities, the NHS, state schools and police forces.

The Act is enforced by the Information Commissioner who regulates both the Freedom of Information Act and the Data Protection Act.

The Surgery publication scheme

A publication scheme requires an authority to make information available to the public as part of its normal business activities. The scheme lists information under seven broad classes, which are:

• who we are and what we do

• what we spend and how we spend it

• what our priorities are and how we are doing it

• how we make decisions

• our policies and procedures

• lists and registers

• the services we offer

You can request our publication scheme leaflet at the surgery.

Who can request information?

Under the Act, any individual, anywhere in the world, is able to make a request to a practice for information. An applicant is entitled to be informed in writing, by the practice, whether the practice holds information of the description specified in the request and if that is the case, have the information communicated to him. An individual can request information, regardless of whether he/she is the subject of the information or affected by its use.

How should requests be made?

Requests must:

• be made in writing (this can be electronically e.g. email/fax)

• state the name of the applicant and an address for correspondence

• describe the information requested.

What cannot be requested?

Personal data about staff and patients covered under Data Protection Act.

For more information see these websites:

• Legislation GOV.UK

• Information Commissioners Office

How We Use Your Information

To Provide You with Treatment

Doctors need to make notes about any diagnosis, test results, treatments including drugs prescriptions, and other information that you may provide, that seems relevant to the treatment of your condition. We need to keep this information in order to provide proper care for you (for later treatment, or if you should be seen by another doctor) and to allow others to check the treatment that you have received.

Nurses and other health professionals also need access to these records, and will add their own notes, as part of the overall healthcare provision. Secretaries, receptionists, and other clerical staff need access to some of your records in order to do administrative tasks, such as: booking appointments and communicating with you and other parts of the NHS.

Your doctor may also need to provide information under certain Acts of Parliament (e.g. the Communicable Diseases Act 1978, which is necessary to prevent the outbreak of certain highly contagious diseases) to protect you and others.

The Health Service

In order to manage the NHS, some restricted information concerning treatments, drugs prescribed, numbers of patients seen etc. is needed, and hospitals and general practices must provide this information in returns to various central bodies. This information has personal details such as your name and address removed wherever possible. It is necessary from time to time to check these returns to prevent fraud as part of the NHS’s statutory obligations. This may result in your being contacted by an NHS Fraud Office to see if you will consent to your records being checked. Only if you provide your consent will the auditors be allowed to access your records.

Teaching Clinicians

Some medical files are needed to teach student clinicians. Without such materials, new doctors and nurses would be not be properly prepared to treat you.

Planning

We need to be able to plan ahead about treatments, patient numbers, etc., but this uses summary information, not personal information.

Medical Research

Some medical research will require your direct involvement (especially if taking part in clinical trials) in which case the circumstances will be fully explained to you, and your express consent required. If you do not consent, then you will not be included in the trial.

Other researchers only require access to medical statistics, and can greatly improve our understanding of health, and how to treat patients more effectively. Generally, researchers only need information about groups of people, so that no individual information is apparent. In some cases, they need individual records, but wherever we can we will provide these in an anonymous form (so individuals cannot be identified). Sometimes, researchers need access to individual medical files. We will contact you first for your consent (and before this the researchers must present their case before an Ethics Committee to check that their research is appropriate and worthwhile). Rarely, it may not be practicable (or even possible) to contact individuals for their consent, in which case the researchers must make their case before a Confidentiality Committee to show that there is enough benefit to the public at large to justify this.

How do we manage your information?

We need to be able to move electronic information from system to system, extracting the data and modifying it for the next system. Occasionally, tests will need to be made on the data to check that it has been transferred correctly. This will only be done under carefully controlled conditions and all employees and contractors will be under strict contractual obligations to protect your confidentiality.

Incident Reporting

Practice staff should use the new GP e-form to report all patient safety incidents and near misses whether they result in harm or not.

These reports are used to spot any emerging patterns of similar incidents or anything of particular concern.

This will help protect patients by raising awareness of the risks through shared learning with general practices and other health providers across the country.