The GMC invited contributions to a process of consultation on the HRG Report (see previous link). This is the text of SDT's submission.

The Sick Doctors Trust is pleased to be consulted on this matter. The following are our main comments.

Recommendation 1.

The precise scope and limits of the investigations that the GMC should undertake on doctors where there are allegations of alcohol and drug abuse need to be very carefully defined and justified.

Recommendation 2.

It is extremely welcome that the Review recognises the severe deficiencies in the treatment and support of doctors who become dependent on alcohol and/or other drugs. Equally welcome is the Review's response to the evidence given to it of the highly effective procedures for treatment and monitoring of such doctors in North America.

However, the frequent references in the Report to the Shipman Enquiry are of concern. The tone of Dame Janet's comments on doctors with problems relating to substance abuse is worryingly harsh and appears to run counter to the fact that such doctors are not ‘bad', but ill. Her negative comments about the importance of rehabilitation are disappointing. Such doctors respond to appropriate treatment and can become valuable members of the profession if correctly monitored and supported.

The GMC will need to define the conditions under which the treated doctor can be allowed to return to work. In most cases there will be a requirement for total abstinence from all mood altering substances, a position supported by the Sick Doctors Trust.

The Sick Doctors Trust together with the BMA have been part of a coalition ‘Clinicians Health Intervention Treatment and Support – CHITS' which has, for a considerable time, lobbied intensively for appropriate treatment and support services for addicted health professionals.

Recommendations 3 – 6.

The need for clarification of roles and detailed guidance as outlined in these recommendations is welcome. It is essential that the guidelines as well as the clarification of roles and responsibilities be widely available for consultation.

The GMC case examiners (senior GMC staff) have considerable powers to determine how a doctor is fit to practise. It is unclear how their performance is audited or monitored.

Recommendation 7.

The specific tests and methods used for testing need to be up to forensic standard and to have proven reliability and validity as well as sensitivity, as it is almost inevitable that there will be legal challenges to the results of testing.

The Sick Doctors Trust is of the opinion that properly used chemical testing of recovering doctors can be helpful and supportive to that doctor and may be a useful tool in enabling them to demonstrate their continuing adherence with GMC requirements in the face of accusations from others.

Recommendation 8.

This recommendation on confidentiality correctly identifies the sick doctor as a patient, with rights of confidentiality and consent set out by the GMC itself. How these rights are balanced by the need to inform appropriate bodies should be further reviewed. It would be entirely wrong to publicise the names of doctors being treated under the reformed health procedures. Such a policy would drive addicted and sick doctors underground and greatly impair the chances of effective treatment being sought.

Recommendation 9.

It is essential that the guidance:

* Be developed from and based on wide consultation.
* Be widely published and available.
* Be subject to continuing scrutiny and revision.
* Be sufficiently acceptable to all concerned, that any deviation should require explanation and justification.

Recommendation 10.

This recommendation is welcome. The review rightly identifies indefinite suspension as an excessively harsh penalty for a doctor who is sick. That said, the natural history of addiction is characterised by relapse. For a small number of doctors (in USA programmes this is between 5 and 10% of doctors who enter treatment), clearly long term suspension is the only realistic option.