GCC Learnings – record keeping and referrals

The General Chiropractic Council’s (GCC) Professional Conduct Committee (PCC) recently heard a case where a chiropractor admitted unacceptable professional conduct (UPC) in relation to a failure to keep proper records over a sustained period (six years) and inadequate correspondence with other healthcare professionals and third parties.

Background to the case

The matter was referred to the GCC after a former colleague raised their concerns in line with their responsibilities under standard B1:

B1: Protect patients and colleagues from harm if your health, conduct or performance, or that of a regulated healthcare professional, puts patients at risk.

The clinical records showed a pattern of significant record keeping failings over a period of six years in relation to over 700 patients.

There were over 70 cases where correspondence with healthcare professionals or third parties were inadequate (lacking basics such as a date or signature; or containing clinical details or diagnoses which were not adequately evidenced or recorded in the notes). 

Professional Conduct Committee Finding

The Committee found the chiropractor’s conduct amounted to an extensive and wide ranging failing in record keeping and correspondence that went way beyond what could be categorised as merely professional incompetence. Accurate and full records are an integral and crucial part of any healthcare professional’s practice and the chiropractor failed on a vast scale in this regard. 

The Committee found that the cumulative failures represented a serious pattern of behaviour that fell far below the standard expected of a registered chiropractor and amounts to UPC.

In mitigation, they took into account that, at the time in question, the chiropractor was a new graduate in their first role, working in a practice that was described as “high volume” seeing around 120 patients a week, and seemingly not accessing supervisory support or advice. However, they noted that making a correct diagnosis and ensuring it is reflected in the physical examination and symptoms recorded is both basic and fundamental to the practice of chiropractic and a core and substantial part of training. The Committee considered that newly qualified practitioners are fully accountable for their clinical actions and diagnoses.

They also took account of his current circumstances – he is working outside of the UK in a clinic where the supervisor has both been informed of the case and has provided evidence of substantial improvement in the chiropractor’s clinical practice.

The Committee decided that the most appropriate sanction would be a Conditions of Practice Order for 12 months. In order for the chiropractor to be allowed to practise in the UK in the future, they must be tested by an assessor appointed by the GCC and to provide a reflective piece to address how they have developed personally and as a practitioner in light of the findings made by the Committee. A review hearing will be held prior to the expiry of the conditions.

Learning

Chiropractors are professional healthcare providers, expected to keep detailed accurate clinical notes, maintain high standards in their practice and to communicate properly and effectively with other healthcare professionals.

The Committee noted that this is a fundamental attribute of what it means to be a professional, and to fail in this regard on such a scale has the potential to bring the profession into disrepute and thereby cause reputational harm to the chiropractic profession.

The Royal College of Chiropractors (RCC) has produced a valuable guidance note on clinical note-taking.

Focus on Clinical Governance for newly qualified registrants

This case predates the introduction of the mandatory Focus on Clinical Governance within Continuing Professional Development (CPD) for graduates who have graduated within the last two years. The GCC now expects new registrants to:

• Reflect on their skills and understanding of a range of areas of clinical governance as specified by the GCC, and
• Address any aspects of clinical governance that require development.

These additional CPD activities form part of the expected 30-hour CPD requirement for the year (not in addition to). The most straightforward way for new graduates to address and meet these requirements is through participation in the Royal College of Chiropractors’ ‘PRT’ postgraduate training programme.

Further Reading

RCC guidance note on clinical note taking.

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