The starting point is probably not the performers list, nor appraisal, but the statutory idea of general medical services.<\/p>\n\n\n\n
Under the National Health Service Act 2006, a general medical services contract is a contract under section 84 for the provision of primary medical services. Section 85 then requires a GMS contract to include prescribed primary medical services. Those prescribed services are found principally in the NHS (General Medical Services Contracts) Regulations 2015, especially regulation 17, dealing with \u201cessential services\u201d. Regulation 17 describes essential services in broad patient-facing terms. A contractor must provide services for the management of registered patients and temporary residents who are, or believe themselves to be, ill, terminally ill, or suffering from chronic disease. \u201cManagement\u201d includes consultation, examination where appropriate, identifying the need for treatment or investigation, providing treatment or investigation where necessary and appropriate, referral, and liaison with other healthcare professionals.<\/p>\n\n\n\n
This is the closest statutory foundation for the idea that NHS general practice is broad, first-contact, generalist work. It is not narrow specialist practice. It is concerned with patients who may present with almost anything, including early, unclear, or non-specific illness. That is where NHSE can plausibly find the conceptual root of \u201cundifferentiated\u201d general practice. But the statute does not itself use the term undifferentiated GP, and it does not define a GP by an obligation to maintain active competence in every possible domain of community general practice. The duty in regulation 17 is framed primarily on the contractor or practice, not on each individual doctor personally. A practice must provide the service. The individual doctor must work safely within competence and within the contractual and governance arrangements of the service.<\/p>\n\n\n\n
The performers list legislation then sits on top of this. The NHS (Performers Lists) (England) Regulations 2013 define a \u201cgeneral medical practitioner\u201d as a registered medical practitioner who is either a GP registrar or whose name is included in the GP Register. Regulation 24 says, broadly, that a doctor may not perform primary medical services unless they are a general medical practitioner included in the medical performers list, subject to exceptions. So the performers list does not define a GP by \u201cundifferentiated\u201d scope. It defines eligibility by GP Register status, licence, registration, and inclusion on the list. The work protected by the list is primary medical services.<\/p>\n\n\n\n
That matters because primary medical services are wider than GMS. They may be delivered under GMS, PMS, APMS, section 92 arrangements, and other arrangements under Part 4 of the 2006 Act. The performers list regulations expressly recognise this. They define an APMS contract as an arrangement under section 83(2) of the 2006 Act for the provision of primary medical services. They also require the medical performers list to record whether a doctor provides primary medical services under, or pursuant to, an APMS contract.<\/p>\n\n\n\n
That is fatal to any simplistic argument that APMS work is somehow not GP work or not primary medical services. A doctor working under an APMS contract may not be providing \u201cgeneral medical services\u201d in the strict contractual sense, because GMS means a section 84 GMS contract. But they may very much be providing NHS primary medical services and, in ordinary clinical language, GP-type work.
This is important for prison doctors. A prison GP working under an APMS contract may have a restricted patient population. For example, they may not treat children, pregnant women, or the full demographic range seen in community general practice. NHSE may label that \u201cdifferentiated\u201d because the scope is narrower than full community general practice. That label is not wholly irrational. Prison practice is a specialised setting. It has a defined population, particular clinical risks, and areas of GP work that may be absent.<\/p>\n\n\n\n
But the legal conclusion does not automatically follow. A prison APMS GP is still capable of providing primary medical services. The question is not whether the doctor is identical to a community GMS GP. The question is whether the doctor is safe, current, and fit to practise within their actual scope, and whether they are performing services of the kind relevant to inclusion on the performers list.
The RCGP and GMC material helps explain the professional background. The RCGP curriculum describes the GP as a generalist, dealing with complexity, uncertainty and risk, and addressing early undifferentiated presentations (which in any case prison GPs have to do). That could be seen to support the idea that undifferentiated work is part of the core identity of general practice at qualification. But it remains curriculum and professional language. It does not by itself create a statutory condition that every doctor on the performers list must personally maintain full undifferentiated community GP scope.<\/p>\n\n\n\n
The NHSE low-volume guidance is the most relevant document I found. It concerns doctors on the NHS England Medical Performers List undertaking a low volume of NHS GP clinical work, defined as fewer than 40 sessions per year. It says that fewer than 40 sessions should trigger structured reflection and discussion at appraisal. It asks whether the doctor\u2019s work is general undifferentiated GP work or a more differentiated role. It treats restricted scope as a possible risk factor, especially because loss of a skill set through restricted practice may affect future decisions about scope.<\/p>\n\n\n\n
However, the same guidance is careful. It says the 40-session figure is a benchmark, not a pass\/fail test. It is a trigger for reflection and discussion. It says doctors doing 40 sessions or more do not need extra reflection purely because of volume, but it does not say doctors doing fewer than 40 must be removed or must complete 40 ordinary community sessions.<\/p>\n\n\n\n
The structured reflective template is even more useful. Its stated aim is to allow doctors to demonstrate that they are safe, up to date and fit to practise at what they do, particularly if they have an unusual or restricted scope of practice, or do a low volume of a particular scope of work. That phrase, \u201cat what you do\u201d, is central. It supports reflection on actual scope. It does not support forced reflection on imaginary or unwanted work outside scope.<\/p>\n\n\n\n
NHSE can say that full-scope community general practice is broad, generalist and often undifferentiated. It can say that a doctor whose work is restricted, such as a prison APMS GP who does not see children, should reflect on the risks of deskilling and the implications for any future return to unrestricted community GP work. It can require annual appraisal, supporting information, and reflection across the doctor\u2019s whole actual scope of practice<\/em><\/strong>. <\/p>\n\n\n\n NHSE does ask for reflection where a doctor\u2019s work is low-volume or restricted in scope, but any such request must be grounded in the doctor\u2019s actual scope of practice and cannot convert full-time specialised\/APMS primary medical work into \u2018low-volume\u2019 work merely by excluding it from NHSE\u2019s preferred concept of undifferentiated community GP.\u201d<\/p>\n\n\n\n I have not found authority for the proposition that such a doctor must perform 40 sessions of ordinary non-specialised NHSE community general practice. Nor have I found authority for a requirement that the doctor must keep up skills in areas outside their declared and actual scope, such as paediatrics, if they do not treat children. Nor have we found authority for requiring a doctor to create a personal development plan to become \u201cundifferentiated\u201d where their actual work is safely and lawfully differentiated.<\/p>\n\n\n\n The proper distinction is between current scope and future scope. For future unrestricted community GP work, it is reasonable to acknowledge that a return would require appropriate updating, supervision, induction, refresher work, or staged re-entry. That is a safety position, not a concession of current inadequacy. This is the same for any doctor wishing to change his scope of practice and we would reflect that in our CPD<\/p>\n\n\n\n A GP must:<\/p>\n\n\n\n \u2022 engage with annual appraisal But they do not<\/strong> to have to:<\/p>\n\n\n\n \u2022 accept NHSE\u2019s \u201cundifferentiated\u201d label as a legal category The relection can be this<\/p>\n\n\n\n \u201cI have reflected on my actual scope. My current scope is full-time prison\/APMS primary medical care. I do not practise unrestricted community general practice and do not currently intend to do so. I therefore maintain competence, CPD, governance and appraisal evidence for my actual scope. If I later wished to move into unrestricted community GP work, I accept that I would need appropriate updating and reflect this in my CPD. I do not accept that I am required to maintain competence in areas outside my current and intended scope.\u201d<\/p>\n\n\n\n <\/p>\n\n\n\n Primary medical services are broad enough to explain how NHSE values undifferentiated generalist capability. But neither GMS law, APMS law, performers list law, nor the low-volume appraisal guidance can impose a freestanding duty on every GP to maintain full undifferentiated community GP practice regardless of actual scope. A prison APMS GP may be differentiated in the descriptive sense, but the lawful appraisal question is whether they are safe, up to date and fit to practise at what they do, and what safeguards would be needed before moving into a broader or unrestricted role. See more at https:\/\/bulger.co.uk\/blogs\/?p=266<\/a><\/p>\n\n\n\n <\/p>\n","protected":false},"excerpt":{"rendered":" The starting point is probably not the performers list, nor appraisal, but the statutory idea of general medical services. Under the National Health Service Act 2006, a general medical services contract is a contract under section 84 for the provision of primary medical services. Section 85 then requires a GMS contract to include prescribed primary … Continue reading General Medical Services, Primary Medical Services, APMS and the \u201cUndifferentiated GP\u201d Problem<\/span><\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[98,97,92,99],"class_list":["post-262","post","type-post","status-publish","format-standard","hentry","category-uncategorized","tag-apms","tag-gms","tag-nhse-appriasal","tag-prsion-gp-undifferentiated-gp"],"_links":{"self":[{"href":"https:\/\/bulger.co.uk\/blogs\/index.php?rest_route=\/wp\/v2\/posts\/262","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/bulger.co.uk\/blogs\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/bulger.co.uk\/blogs\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/bulger.co.uk\/blogs\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/bulger.co.uk\/blogs\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=262"}],"version-history":[{"count":5,"href":"https:\/\/bulger.co.uk\/blogs\/index.php?rest_route=\/wp\/v2\/posts\/262\/revisions"}],"predecessor-version":[{"id":337,"href":"https:\/\/bulger.co.uk\/blogs\/index.php?rest_route=\/wp\/v2\/posts\/262\/revisions\/337"}],"wp:attachment":[{"href":"https:\/\/bulger.co.uk\/blogs\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=262"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/bulger.co.uk\/blogs\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=262"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/bulger.co.uk\/blogs\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=262"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}
For current prison APMS work, the doctor should demonstrate fitness, CPD, governance, feedback, significant events, complaints, peer benchmarking, and safe practice within prison primary care. If they do not treat children, they should not pretend to maintain paediatric competence as though they do. They can instead state that paediatrics is outside their current scope.<\/p>\n\n\n\n
\u2022 provide supporting information across their actual scope
\u2022 demonstrate they are safe, up to date and fit to practise in what they do
\u2022 reflect honestly on significant changes or limits in scope
\u2022 not misrepresent competence in areas they do not practise<\/p>\n\n\n\n
\u2022 treat full-time prison GP work as low-volume GP work
\u2022 complete a \u201clow volume\u201d template if the factual premise is wrong
\u2022 make a PDP to maintain or regain skills outside their intended scope
\u2022 perform 40 sessions of ordinary community general practice if they do not intend to practise ordinary community general practice<\/p>\n\n\n\n
Summary<\/p>\n\n\n\n
<\/p>\n\n\n\n