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Sunday, April 28, 2013

Peter Holden, responding to a Times article about the "GPs cushy deal" on out of hours work

Dr Holden wrote this letter to the Times in response to an article. He  has given permission for it to be reproduced. 


Comments to Camilla Cavendish regarding article in the Sunday Times 29th of April 2013
"The GPs cushy deal means we are all left to suffer in casualty"

Camilla,

I read your article with interest and huge disappointment. I am a general practitioner of some 30 years standing, qualifying is a GP in 1983. Since 1985 I have been a principal in my practice in Matlock which has training status for both undergraduate and postgraduate doctors and for district nurses and health visitors. We also help run the local community hospital including its minor injuries unit. Until 2000 when the lawyers forced us out we used to do our own obstetrics as well.

From 1985 to 1996 I had to work every fourth night and every fourth weekend in addition to a full weeks work. If a partner went on holiday I had to cover my share of that absence – what used to be called one in four with prospective cover. Such a rota delivered an average working week of 80 hours with a peak of 114 hours and a trough of 56 hours with 32 hours and 80 hours at a stretch . From 1996 to 2004 I was part of our local general practice out of hours cooperative which meant that the population was covered in a local doctor who was not compelled to work all day and all following day, all week and all following week. Even then I had to do 1 in 12 on call for the community hospital in ADDITION to my shifts on the cooperative. Despite the contractual easements of 1996 and 2004 by the time I retire I will have worked 148,000+ hours at 60 years of age and 159,000 hours at 65 – that is twice the working career of the rest of society and typical of my generation of doctors who qualified in the late 70s or early 80’s

In understanding why general practitioners struggled with out of hours as organised before 2004 it is necessary to understand the changes that have occurred in society since the National Health Service began.

1. Nuclear families with no granny round the corner to offer advice to the new mother with a consequence that every child with a runny nose is brought to the GP.
2. Longer life expectancy and large numbers of elderly people with multiple pathology requiring significant input.
3. Modern medicine has moved a long way with much work that used to be done in hospitals and in outpatients now being performed in general practice.
4. Politicians keep on stoking up demand because it’s an easy vote winner
5. A society which is not prepared to tolerate risk of any sort
6. A consumerist society that simply views health services as a commodity when it comes to the organisation yet paradoxically wants highly personalised care when they come to being cared for. Patients want a bespoke service at mass-production prices.

Even in my own practice in a small town nobody can explain to me why with a static population with 100% child immunisation the out of hours call rate went from six or seven per week in 1985 when I joined the practice to over 10 times that number in some weeks in 2004. Such a rising workload coupled with massively increased complexity of daytime GP work is completely unsustainable on the model of out of hours care extant before 1996 and was very difficult between 1996 and 2004.

Compounding matters is the fact that despite the massive leftward shift of care into general practice of much former hospital work (UK general practice now deals with almost all people with hypertension, diabetes, thyroid disease, 90% of mental health problems, and most post-operative follow-ups all of which used to go back to hospital) with a workforce that is estimated to have increased from approximately 27,000 whole time equivalent GPs to about 34,000 whole time equivalent GPs. During this at a time hospital consultant numbers have doubled. To put things into perspective general practice delivers approximately 300,000,000 consultations per annum and does it with roughly 9% of the NHS budget.

I feel particularly aggrieved by your comments because even with my supposedly cushy number both myself and colleagues are finding ourselves with intensive 14 hour days and yet 40% of us still work on the out of hours service. Apart from 2000 to 2004 I have always worked on the out of hours service and have something around 40,000 out of hours calls under my belt. Here in Derbyshire the current out of hours provider Derbyshire Health United is the amalgamation of our two former cooperatives and over 97% of all our out of hour shifts are covered by Derbyshire GPs. It is wholly unrealistic to expect your own doctor or a doctor from your practice to attend you out of hours given the current demands on the service. Remember that when the NHS was set up it was envisaged that each patient would need 2 out of hours consultations per lifetime and one of those would be to certify the fact of death!

This is not just the rant of a country GP. I am one of only two survivors from the 2004 GP contract negotiating team and I was in the room when the out of hours deal was done so I have first-hand experience of exactly what was agreed. The only thing I’m likely to agree with you on is the fact that both Gordon Brown as Chancellor of the Exchequer and Tony Blair as Prime Minister were fully in the picture as to what was being negotiated at the time on a day to day basis. Representatives of number 10 and number 11 were in the room time.

For the avoidance of doubt what was agreed in 2004 was that general practitioners were relieved of the obligation to make the necessary arrangements for patients whose condition so warranted it to be seen out of hours.

Analysis of that obligation is crucial. The NHS was never set up to provide 24/7 routine general practice. Indeed even if we had the money we don’t have the workforce. The NHS was set up to provide 24/7 emergency care. From 1996 the GPs out of hours obligations which were hitherto implied were made explicit; namely that it was for the GP to decide whether when and where the consultation would take place if one was necessary. This was agreed because of rapidly escalating demand. By 2001 recruitment to general practice had collapsed (it is collapsing again) and this was largely because of the unacceptable working hours of general practice.

Although cooperatives were spreading, in 1996 when the cooperative deal was signed over 50% of GPs were condemned to doing their own on-call because they could not find anybody else or any company to cover the work. In 1997 the Doctors and Dentists Pay Review Body formally determined that the quantum of money paid to GPs for making arrangements for out of hours was approximately £6000. At the time I calculated that GPs were being paid much less than minimum wage to be on-call, cover their travelling and motoring costs, and any immediately necessary treatment drugs.

From 1996 cooperatives spread quickly in the urban areas where the was no out of hours deputising service and into the immediately neighbouring countryside, but the problems of getting cover in rural areas and especially remote areas whether urban or rural remained. Those doctors were working with 1947 resource to cope with 21st-century demand and the result was that even in the so-called plum practices - nice genteel rural attractive areas it was impossible to recruit new colleagues indeed, in my own practice it took almost 4 years.

In 2004/5 after we did the deal for out of hours the government expressed surprise that it had found it very complex operationally to organise out of hours care and that it had cost them almost 3 times as much to provide as they had recovered from the profession by withholding £6000 per doctor. That was not surprising to GPs because for many years the government and departmental officials had always denied our claims about the operational difficulties, burdens and, costs of delivering an out of hours service in the modern era.

From 2004 it fell to the primary care trusts to make arrangements to provide out of hours services. In many areas they stuck with the out of hours cooperative but insisted on paying less for purely financial reasons resulting in reduced staffing levels. Indeed this was a recipe for disaster - for example they tried to cover the whole of North Yorks Emergency Doctors area with only five doctors on the service. Call times became prolonged and lives were lost (I can prove that). The model was economically unsustainable and shortly afterwards North Yorkshire Emergency Doctors went under. I understand that re-provision cost far more.

In other areas the primary care trusts recognised the value of what they had and continued funding at economic levels. Quite properly PCTs sought to retender periodically and in some areas the existing contract holders lost out to commercial operations which that believed that they could save money. The only way to save money was to reduce staffing particularly call handling and medical staff. The consequences of this were delays in call handling and processing sometimes of a dangerous nature for the patients concerned. General Practitioners working for the services as employers often found that either their concerns were dismissed or they simply were not offered further work. As the financial pressures increased on the commercial firms they reduced the amounts they were willing to pay doctors and as a consequence the local GPs pulled out of working for the organisation particularly at the pay rates on offer. The result was the importation of general practitioners from Europe and we all know what happened with Dr Ubani.

In some areas the existing out of hours cooperatives made very robust contractual proposals to the PCT’s which were not the cheapest but were the best and the cards were played along the lines of we know this is not the cheapest but it is the best and we have minimal complaint rates and competition amongst local doctors to work for us. That type of approach worked in Derbyshire - the two cooperatives Derby Medical Services and North Derbyshire Doctors merged to form Derbyshire Health United a social enterprise NHS body fully and properly integrated paying appropriate rates of pay to all grades of staff with the result that over 97% of the GP shifts are staffed by Derbyshire GPs. DHU has gone on to secure the 111 contract for Derbyshire which was operating well as a pilot and still managed to stay afloat when the tsunami of transferred calls from other failing 111 services hit it in April 2013

The importation of GPs from Europe carries its own problems. The charge levelled at UK GPs being the best paid general practitioners in the world is true for the simple reason that we have the heaviest job weight of GPs in the world. For example we act as General Physicians in the Community (since there are no longer General Physicians in secondary care) we see all children, undertake considerable amounts of gynaecology and see pregnant or post natal patients and do baby checks, see 90% of mental health problems, undertake huge volumes of chronic disease management, and look after large numbers of elderly people in residential and nursing homes as well as ordinary reactive care.

Indeed the Commonwealth Fund report on primary care show UK general practice in a very good light indeed. I can send you a slide set!

Countries compared: Australia, Canada, France, Germany, Netherlands, New Zealand, Norway, Sweden, Switzerland, U.K., and U.S.

The UK has:
Second lowest health spending per capita (slide 5)
The lowest “cost related access problems” to primary care (slide 6)
The joint best access to same/next day access to primary care physician (slide 8)
The least difficulty I accessing out of hours care without needing to attend A&E (slide 9)
The best access to out of hours care (slide 9)
The highest access to online repeats and appointments (slide 10)
The highest scores for management of chronic diseases (slide 17)
Joint second in use of IT (slide 22)
Highest in reviewing patient data and outcomes (slide 24)
Highest level of practice comparative data (slide 26)
Least physician satisfaction with time spent per patient (slide 37-we need longer consultations!)
Access to GPs and OOH has improved in recent years (slide 40)
Slide 45 summarises the UK well-a lot to be very proud about

European GPs do not see children less than four years of age and in some cases children under 16, many do not handle psychiatric problems at all, they do not provide in a systematic structured form the scope, quantity or depth of chronic disease management and in some countries elderly people in nursing and residential homes are looked after by community geriatricians. Colleagues report that when they are on shift out of hours with GPs who practice in Europe, delays are a nightmare because European colleagues avoid whole swathes of work and refer whole swathes into accident and emergency. The consequence of this is that UK-based GPs when they raise concerns find that they are at best ignored and at worst threatened. Under such circumstances the sensible UK-based GP resigns from the service in order to preserve their registration and that is what happens.

Our colleagues in accident and emergency do a hugely valuable job (I have held a part-time contract to run a minor injuries unit for 25 years) which I have been privileged to witness first hand. The current problems in Accident and Emergency (now properly known as the Emergency Department) are problems of outflow in that the hospital is often full because beds are being blocked by patients who need social support in order to be discharged safely. Social services are struggling because of cuts but also have a very different concept of urgent or emergency from those in the health professions. Those of us who work in the health professions have the perception that social services definition of emergency is this week and urgent is this month. Unless and until that changes government proposals to merge health and social care funds and puts the control of the health service into local authority hands is doomed to failure.

So why won’t GPs take back out of hours care? (OOH)

1. Bitter experience has taught GPs not to trust governments of either colour on this issue. Even if OOH was offered back on favourable terms within a year or so the government would reduce the funding and resources available
2. GPs already work a 52 ½ hour week
3. We have a whole generation of doctors who know nothing other than EWTD compliant working week
4. There are not enough GPs to provide the service AND maintain their own work life balance

Contrary to myth the GP working day is pretty much a sprint from start to finish. Morning surgery will be anything from 20 to 30 quite complex patients followed by three or four almost certainly complex visits usually to the elderly with multiple pathology, lunchtime will be a working affair with a sandwich about service operational matters followed by a surgery restarting in the late afternoon around 4 o’clock of another 20 patients at the end of which there will be repeat prescriptions to sign letters to read and laboratory reports to analyse and act upon. Gordon Brown insisted that we opened extended hours but what he failed to realise is that after 10 hours, 40 patients, 4 visits, a meeting, 30+ repeat prescriptions 55+ hospital letters and a couple of dozen laboratory reports; physically and mentally a GP cannot safely get their head around any more problems that day and will be going home at past 8pm at night.


During the 1990s a well-respected paper demonstrated that after the 17th patient the quality of consultation falls rapidly. If that is the case then the average practice is operating at 17% appointment overload all the time and 55% overload for almost half the year assuming that no member of staff is ill.

Is there any wonder that only 40% of GPs are involved in out of hours?

Most of us are too exhausted mentally at the end of the day to contemplate any further work.

If this is a cushy number then I’d like to know what constitutes a difficult road to hoe?

Peter JP Holden MB ChB FIMCRCSEd FRCGP
GMC reg no 2480804

Friday, April 26, 2013

GMC responds

Note my previous related posts:

The GMC and guidance for anonymous doctors - illiberal and misconceived
Other aspects of the GMC's "Good Medical Practice" 2013 laws
My message to the BMA and medical defence bodies about the GMC guidance    


I have had a response from the GMC. I asked them four specific questions, and pointed them to my blog. The questions were:

  1. As government guidance says, "“When taking decisions that may affect any of the qualified rights, a public authority must interfere with the right as little as possible, only going as far as is necessary to achieve the desired aim” What is your aim? What are the nature and the scale of the problem that the changes are intended to address? 
  2. What is the evidence that these changes will do what they intend? And that they won't have unintended adverse consequences that will do more harm than good?
  3. Are you really convinced that the guidelines are consistent with UK law and the European Convention on Human Rights (ECHR) (particularly given the need for proportionality as stated above)? What legal advice did you receive on this?
  4. Do you plan to revise the guidance in the light of comments received?

==

From: <gmcstand@gmc-uk.org>
Date: 24 April 2013 15:12
Subject: RE: Good Medical Practice 2013
To: petermbenglish@gmail.com

Dear Dr English

Thank you for your enquiry about our social media guidance. We have answered some of your points, including the purpose of the guidance and our advice on anonymity, on our Facebook page. 


[As I said in my blogs previously, it is not appropriate IMO to "correct misunderstandings" about what the explanatory guidance was supposed to mean in this way. If the guidance is so open to being misunderstood - and I think the correct interpretation of the words written is not what they intended, and what they think is a misunderstanding - then they should change the guidance.]

When we review Good medical practice (GMP) and our explanatory guidance, we are seeking to make sure that it is up to date, clear and relevant to the environments in which doctors practise. The use of social media has been increasing since we last published GMP in 2006 and we have received a number of queries from doctors and medical students seeking advice about the appropriate use of twitter, facebook and other social media. 

[I have no problem with them publishing guidance on the use of social media. Others, such as the RCGP, have published perfectly sensible guidance. But their guidance is inappropriate.]

The development of social media is fast and constantly changing and we have worked on the basis that it is likely to increase and change in the future. We do not know how many doctors are using social media at present; what we do know is that doctors have asked us for guidance in this area.

We are satisfied that our guidance is consistent with the Human Rights Act although, ultimately, these are questions that can only ever be decided by the courts. [I disagree, and am astonished by their complacency in this respect.] We have no plans to revise the guidance at present. [More fool them.] We want to be responsive to criticisms and concerns - but, we also need to take into account the views of those who support the guidance. [So this is a democratic decision? In which case, let's have a vote. Or, if not, what do they mean? Who are these people who allegedly support the guidance; and how have they responded to my specific criticisms and questions?]

I read your blog - and a couple of things are worth commenting on: [But I note that they have pointedly failed to address the specific questions I addressed to them - see below.]

We deal with the most serious concerns about doctors that have or are likely to put patients at risk or undermine confidence in the medical profession. Any concern raised with us is carefully assessed to consider whether we need to investigate. Over half of the issues raised with us are closed following that initial assessment, usually within a few weeks of receiving the complaint and no information is placed in the public domain. Others are referred to the doctor's employer to deal with locally. About a quarter are fully investigated. We do not release information to the public about cases we are investigating (unless an interim order is made to restrict or suspend a doctor's registration while we investigate) and once the case is concluded we only make public cases where we have taken some action or referred it for a public hearing. 

[It may be true that doctors' identities are no longer published on the GMC website once an investigation is commenced. I believe that it was the case until recently.]

When we develop new guidance or revise existing guidance, we seek views through a public consultation process. When we analyse the consultation responses we don't assume that the (overwhelming) majority of doctors who haven't answered agree with the draft guidance. We have no way of knowing whether silence means a lack of interest, agreement or strong opposition but no time to express it. We appreciate that doctors are busy and we do not require them to complete a lengthy questionnaire to give us their views. A short email on a single issue is taken into account and analysed alongside other responses, whatever form they are in. 

[In other words, it is our fault for not writing in and saying "yes, we like that version, please don't change it".]

Kind Regards
[Name redacted]
Policy Manager 
Standards & Ethics Section 
Telephone: 0020 7189 5414 (+44 020 7189 5414 from outside the UK) 
Website: www.gmc-uk.org

==

So, here are my questions again. Were they answered?


1. As government guidance says, "“When taking decisions that may affect any of the qualified rights, a public authority must interfere with the right as little as possible, only going as far as is necessary to achieve the desired aim” What is your aim? What are the nature and the scale of the problem that the changes are intended to address?  

Their aim, as far as I can tell from their response, was entirely unclear, other than to respond to this frightening thing they don't understand, which is called "social media". They seem unaware of the nature and scale of the changes they intend to address, and even less aware of the gross imposition that their guidelines imposes on doctors.

2. What is the evidence that these changes will do what they intend? And that they won't have unintended adverse consequences that will do more harm than good?

This question seems to have been entirely unaddressed, so I can only assume that they have no evidence that their guidance will do any good, let alone that it will do more good than harm.

3. Are you really convinced that the guidelines are consistent with UK law and the European Convention on Human Rights (ECHR) (particularly given the need for proportionality as stated above)? What legal advice did you receive on this?

They state that they "are satisfied that our guidance is consistent with the Human Rights Act" - but they  don't appear to understand why so many of us think otherwise. They have not addressed any of the arguments as to why we believe the guidance is inconsistent with the ECHR, but have merely provided a bland statement. They don't admit to having sought or received any legal advice on the matter.

4. Do you plan to revise the guidance in the light of comments received? 

Well, at least the answer to that one was clear.

I expect we'll see the GMC being humiliated again in court. 

Friday, April 05, 2013

My message to the BMA and medical defence bodies about the GMC guidance


I contacted the BMA about the new GMC guidance, which I have blogged about recently (see "The GMC and guidance for anonymous doctors - illiberal and misconceived" and "Other aspects of the GMC's "Good Medical Practice" 2013 laws"), and receive the following response:

Thank you for your email. 

The view of the BMAs Ethics Committee is that all guidance from the GMC needs to be read in conjunction with the definitions of "should" and "must" as detailed in Good Medical Practice:

"5. In  Good Medical Practice, we use the terms ‘you must’ and ‘you should’  in the following ways.
‘You must’ is used for an overriding duty or principle.
‘You should’ is used when we are providing an explanation of how you will meet the overriding duty.
‘You should’ is also used where the duty or principle will not apply in all situations or circumstances, or where there are factors outside  your control that affect whether or how you can follow the guidance."

This suggests that the guidance in that you quoted does not represent an overriding duty and may not apply in all circumstances. The BMAs Ethics Committee would suggest however that you contact the GMC for definitive guidance on this issue.  You queried whether the GMC guidance is inconsistent with, for example, the ECHR right to privacy and whether it is legal and enforceable. Unfortunately the BMAs Ethics Committee are unable to provide legal advice and would suggest that you contact your medical defence organisation for further advice.

I have since written to both the BMA and my medical defence organisation (MDO) along the following lines:

I have concerns that the new GMC guidance on doctors’ use of social media disproportionately restricts doctors’ rights to participate in normal social activities.

The guidance requires doctors to provide their names, if they identify themselves as doctors. Any communication in which they make any mention of the fact that they are a doctor using the same pseudonym would be to identify themselves as a doctor. This means, in practice, that doctors can choose to use social media anonymously (or, more usually, pseudonymously), and keep their profession extremely secret; or not to do so anonymously/pseudonymously. 

The explanation of what the GMC means by “should” is not clear; and I fear that it would be reasonable to interpret any tweet, blog, or other contribution to social or other media as falling within the remit of this “guidance”. 

This means that – unlike other members of the public – doctors are forced either to make a choice that others do not have to make, even if everything they put on social media is completely legal in every other way.

This is clearly an infringement of their human rights, in particular ECHR rights 8 and 10. 

These are qualified rights; but, as I’m sure you know: “When taking decisions that may affect any of the qualified rights, a public authority must interfere with the right as little as possible, only going as far as is necessary to achieve the desired aim”.

There is no need to argue for a need for anonymity. The right exists. It is a given. It is part and parcel of the right to a private life.[1]

It is not clear what the compelling need is that justifies this restriction. On the other hand, there are many reasons why doctors may reasonably, even professionally, prefer to contribute anonymously or pseudonymously – some of these have been explored in my blog (or the comments to it).[2] 

I am aware of doctors who have been advised not to appeal against unjust disciplinary decisions against them on the basis that if they were to appeal, they would  probably be reported to the GMC on some pretext or other; and although they would be very likely to be exonerated, it would cause another 5 years of stress and inability to progress their careers.

Speaking to other victimised doctors, including whistleblowers, I am keenly aware that employers will use any pretext; and therefore feel that the GMC should not hand them one on a plate. I am, therefore, very keen that the GMC should not provide a reasonable pretext for employers to use to blackmail doctors into bending to their will. Unless the wording is clarified, this will provide such a pretext. All the employer would have to do would be to discover that the doctor had been blogging or tweeting anonymously, with it mentioned somewhere that they are a doctor, and they could use a threat of GMC referral.

Apart from anything else, legal quibbling about what the exact meanings of the words of the guidance are could cost the BMA/MDO (and its members) millions of pounds in legal fees. 

I would like the BMA/MDO to do two things:

To provide clear legal advice on the meaning of the words of the guidance. (The actual words: I think the GMC has said that they didn’t mean their guidance to be interpreted as I have done; but what will matter is what the words say, not their intentions).
To make representations to the GMC and through any other channels they have that might be effective to persuade the GMC to revert to the original consultation draft wording.

With best wishes,

Peter English.

1. Ministry of Justice. The Human Rights Framework as a Tool for Regulators and Inspectorates. London: Ministry of Justice, 2009; 1-47 (http://www.equalityhumanrights.com/human-rights/human-rights-practical-guidance/area-generic/human-rights-framework-for-regulators-and-inspectorates/).
2. English PMB. The GMC and guidance for anonymous doctors - illiberal and misconceived. Peter English's random musings. London, 2013(http://peterenglish.blogspot.co.uk/2013/03/the-gmc-and-guidance-for-anonymous.html). 

Feel free to reuse any part of this text, and to write to your own trade union and or MDO about this.

Thursday, April 04, 2013

Other aspects of the GMC's "Good Medical Practice" 2013 laws

On 25 March 2013 the General Medical Council (GMC) published its revised "Good Medical Practice" (GMP) guidance. I have commented in a previous blog on the guidance on doctors' use of social media, and I'ld like now to comment on some other aspects of the guidance.

Is it "the law"

I have - deliberately rather provocatively - referred to the GMC's "laws" in the title of this piece. Is this reasonable? The GMC guidance clearly isn't legislation.

The guidance says (S6 of the main GMP guidance):
To maintain your licence to practise, you must demonstrate, through the revalidation process, that you work in line with the principles and values set out in this guidance. Serious or persistent failure to follow this guidance will put your registration at risk [my emphasis].

For people practising as doctors (registered medical practitioners, to be precise), however, being registred with the GMC is usually a condition of their practice and employment. If they are struck off, they lose their job, their livelihood, and their social position. Even being investigated by the GMC is stigmatising - your name will be posted on the GMC's web site until they've decided your fate - and it can damage career progression.

So, while the "guidance" isn't strictly speaking the law, it is crucial to a doctor's livelihood.

What does "you should" mean?

The guidance states (S5 of the main GMP guidance):

In Good medical practice, we use the terms ‘you must’ and ‘you should’ in the following ways.
  • ‘You must’ is used for an overriding duty or principle.
  • ‘You should’ is used when we are providing an explanation of how you will meet the overriding duty.
  • ‘You should’ is also used where the duty or principle will not apply in all situations or circumstances, or where there are factors outside your control that affect whether or how you can follow the guidance.

It might be clear to you what this means, but I'm not sure. "...providing an explanation of how you will meet the overriding duty..." seems to me to be pretty directive. The following point, however, about "...where the duty or principle will not apply in all situations or circumstances, or where there are factors outside your control..." looks like a blank cheque for lawyers, who will be able to get fat debating in court whether or not the duty or principle should have applied in particular circumstances, or whether the factors out of the doctor's control permitted him or her to breach the guidance.

Personal beliefs and medical practice

This section of the GMP guidance (and its explanatory guidance) were discussed in statements from the Secular Medical Forum (SMF) on 26 March, and on 2 April 2013; and by the and British Humanist Association (BHA).

Concerrns were raised that the guidance, which permits doctors to opt out (conscientious objection) of providing services which conflict with their personal beliefs. Guidance is given on how to handle this appropriately, including how to pass patients on to other doctors - so that, for example, a doctor whose religion bans abortion does not have to be involved with providing this. (When I was a medical student in the 70s and 80s there was alleged to be a Roman Catholic doctor working in the student health centre who would deliberately delay referral of students for abortions, so that they would be referred too late to have the abortion. I hope that this was an urban myth - though it seems plausible. If that were done now, it would be a clear breach of this section of the guidance.)

The BHA were concerned that this section might cause problems with, for example the provision of emergency contraception

Of greater concern to both bodies was the section which permits doctors to take parents' religious views into account when treating their children. They were particularly concerned about circumcision. The pros, cons, and ethics of circumcision of babies has been much discussed recently  - see e.g. (and there are many more):
For what it's worth, I'm increasingly of the view that you cannot ethically do something which irreparably harms or removes part of a child's body without very strong evidence of benefit. Whether there is any benefit, medically, from circumcision remains moot - and if there is any, it is almost entirely only apparent when the boy reaches an age to become sexually active. Despite two studied lauded by the WHO as providing proof that circumicision reduces the risk of HIV infection I am unconvinced that these studies are the last work on the matter - I suspect that any benefit may be shortlived, and may be overcome by a conviction by circumcised men that they are no longer at risk, and can then indulge in riskier sexual behaviour.

Nevertheless, I can see that guidance which would, effectively, prevent doctors from performing circumcision could not be expected now from a conservative body such as the GMC. Male circumcision is such an integral part of the practice of at least two of the worlds great religions (Judaism and Islam) that it would cause a furore if the GMC were to prevent doctors from performing it; and it would drive children into the hands of practitioners who are less well qualified and less accountable, possiby doing greater damage overall.

In any case, what the guidance actually says is less prescriptive than I had imagined from the BHA and SMF statements. What they actually say is:

Section 18:
If patients (or those with parental responsibility for them) ask for a procedure, such as circumcision of male children, for mainly religious or cultural reasons, you should discuss with them the benefits, risks and side effects of the procedure. You should usually provide procedures* that patients request and that you assess to be of overall benefit to the patient. If the patient is a child, you should usually provide a procedure or treatment that you assess to be in their best interests. In all circumstances, you will also need the patient’s or parental consent.

Section 20:
If the patient is a child, you must proceed on the basis of the best interests of the child and with consent. Assessing best interests will include the child’s and/or the parents’ cultural, religious or other beliefs and values. You should get the child's consent if they have the maturity and understanding to give it. If not, you should get consent from all those with parental responsibility.

This does not seem to me to require doctors to do things just because parents ask them to do so; they must still do so only if they assess it to be "of overall benefit to the patient... in their best interests". This, sensibly, gives doctors the discretion to act as they see fit, in the best interests of the patient who is not competent to give consent on their own behalf.

Guidance on "lifestyle".

I was a little concerned about two adjacent sections in the main GMP guidance - sections 51 and 52. These state:

51 You must support patients in caring for themselves to empower them to improve and maintain their health. This may, for example, include:
  • a advising patients on the effects of their life choices and lifestyle on their health and well-being
  • b supporting patients to make lifestyle changes where appropriate.
52 You must explain to patients if you have a conscientious objection to a particular procedure. You must tell them about their right to see another doctor and make sure they have enough information to exercise that right. In providing this information you must not imply or express disapproval of the patient’s lifestyle, choices or beliefs. If it is not practical for a patient to arrange to see another doctor, you must make sure that arrangements are made for another suitably qualified colleague to take over your role.

I have read a number of anecdotal reports of patients comlaining that their doctors had been rude to them or failed to respect their lifestyle choices when the doctors concerned insist that they had been as tactful as possible, but the patient was simply very sensitive about comments about their weight. So I wondered whether this version - in particular "...you must not imply or express disapproval of the patient’s lifestyle, choices or beliefs..." of GMP might make it harder for doctors in this situation to defend their actions. Are these two sections compatible? Failure to advise patients on their life style choices (for fear of complaints) is far less likely to generate a complaint than being a good doctor and advising patients that they need to lose weight. Is this what the GMC intended?

Friday, March 29, 2013

The GMC and guidance for anonymous doctors - illiberal and misconceived

UPDATE: Blogger has somehow deleted a previous update I made... I have since written two more blogposts (here and here) on the GMC guidance, and recorded a piece for the Pod Delusion, which I hope they'll accept. I am also interested to see that Max Pemberton has written a piece for the Telegraph on the subject.

ORIGINAL PIECE.

The General Medical Council (GMC) has updated its guidance for doctors, known as "Good Medical Practice" (GMP). Unlike previous versions, this version has explicit "supplementary explanatory guidance" on the use of social media by doctors.

A consultation draft had been published previously, which proposed a section 17 which read:

"If you are writing in a professional capacity, you should usually identify yourself. Any material written by authors who represent themselves as doctors are likely to be taken on trust and/or to represent the views of the profession more widely. You should also be aware that content uploaded anonymously can, in many cases, be traced back to its point of origin."

This struck me as uncontroversial and sensible.

I didn't comment during the consultation process - I didn't see any need to change what they'd proposed, and I was busy with other things, so it seemed a low priority.

Unfortunately, following the consultation process the wording was changed. The final version reads (in part): 

"If you identify yourself as a doctor in publicly accessible social media, you should also identify yourself by name. Any material written by authors who represent themselves as doctors is likely to be taken on trust and may reasonably be taken to represent the views of the profession more widely."

This is completely different. It amounts to a ban on participating in social media11 anonymously, unless you never let on that you are a doctor.2

If, in one tweet or another you mention that you're a doctor, or it's in your biography, then, according to these guidelines you "should" also provide your name,3 and not post anonymously.4So, in effect, you must choose between 
  • posting anonymously and being obliged to keep the fact that you're a doctor a carefully protected secret and 
  • identifying yourself - at least by name.3

The importance of GMC guidance

GMP is taken extremely seriously. Failure to follow the guidance can lead to a referral to the GMC's "Fitness to Practice" panel. The GMC is not known for quickly throwing out vexatious referrals. Every referral is immediately made public: your name is posted on the GMC's web site, so people know you've been referred to the GMC. The process usually takes a long time - often several years. Even if the GMC decides to take no action against you, you are subject to the stigma and suspicion that goes with being under investigation - it's very much like being a suspect in a criminal investigation.

Some people have argued that the GMC guidance is acceptable and appropriate because they cannot conceive why anybody should wish to tweet anonymously. This strikes me as hopelessly naive. True, people may do so in order to bully or post gratuitously offensive material; but most anonymous bloggers and tweeters that I follow do not do this - many are  paragons of politeness on twitter. 

Why was this change made to the guidance; and what is the guidance for?

The GMC clearly felt the need to produce guidance for doctors, as social media has become so much more widely used since the previous (2006) edition of GMP.

Phil Williams (scottishphil83) points out that the GMC's primary role, according to its web site, is “to protect, promote and maintain the health and safety of the public by ensuring proper standards in the practice of medicine”. He worries that they state that doctors should "…follow your organisation’s policy on social media  " - although they cannot possibly know what every organisation's policy on social media will be, and cannot be certain that all of them will be appropriate. What if the policy were to require doctors to do things that conflict with other parts of GMP? (See Scottishphil83's blog on the GMC guidance where he expands further on this point.) 

The GMC have not, as far as I know, explained why they they decided to change the guidance. I put three questions to them:
  • What is the nature and the scale of the problem that the changes are intended to address? 
  • What is the evidence that these changes will do what they intend? And that they won't have unintended adverse consequences that will do more harm than good?
  • Are you really convinced that the guidelines are consistent with UK law and the European Convention on Human Rights (ECHR)
I shall be very interested to see if the GMC will respond to my challenge and answer my questions.

My guesses as to the problems the change is intended to address

I suspect that one of the perceived problems may have been that some doctors have been accused of referring to patients in a disrepectful way, and the belief that this somehow harms the practice of medicine and the status of doctors.  While this seems to suggest that people do (and should) put doctors on a pedestal, and not talk about the people they interact with in a disrespectful way, as others do (see for example the "not always right" blog). It is not clear to me to what extent this is true, and whether it matters to anybody other than doctors who take themselves and the status they think they deserve rather too seriously for their own good - and the good of the rest of us; but it may be part of the perceived problem.

Another perceived problem may be "cyberbullying", and the idea that people who tweet anonymously might be less inclined to regulate their behaviour and intimidate others. I have to say that I find this concept rather troubling - not because I don't think that bullying can happen on line, or that it isn't serious; but because I think that people have become more and more inclined to claim that they've been offended, even when the only reason is that they've said something provocative and been challenged to defend it. An accusation of bullying is very serious; but it loses its value if "fair comment" and the use of occasionally robust language are not permitted. 

Will the guidance be effective in mitigating these perceived problems?

Even if the above "problems" exist and are serious, I think it extremely unlikely that the revised guidelines will improve matters to any significant extent; and given that they will cause considerable harm (as I shall discuss below), I cannot believe that they are proportionate. 

Is the guidance legal?

A lawyer has stated , on another blog (which I commend to you):

"I find this guidance extremely chilling in terms of both free speech (Article 10), and the right to a private life (Art 8). I have read through the entire guidance, and I can not find anything anywhere which states that when one becomes a doctor, one becomes a doctor above all else and subjects him or herself to regulation of their entire, not merely professional, life."

I am told that as a professional regulator, GMC guidance must be compatible with the European Convention on Human Rights (ECHR). If this is true, and my lawyer friend is correct - that the guidance is incompatible with the ECHR - then the guidance is unenforceable by the GMC. But it will still have a chilling effect until it is withdrawn.

Why might a doctor want to tweet anonymously?

I do not tweet anonymously - as somebody else said, it's not my style. In any case, I'm too concerned that a regulator would be able to work out who I am; and my practice means that I have little direct and ongoing contact with patients, so my patients aren't likely to follow me on Twitter. Nevertheless, I can see why others would prefer to tweet anonymously, and I shall discuss some of these reasons below.

Personal disclosure and the effect of tweeting on doctor/patient relationship 

A doctor may well not wish their patients to know who they are. They may wish to discuss family issues. They may want to discuss other issues anonymously on the internet, without their patients knowing that it is their doctor who is tweeting. Doctors do, after all, have a right to privacy - becoming a doctor does not mean giving up your human rights (unless it can be shown that this is necessary e.g. to protect patients).7

And doctors might feel that if their patients knew what they were were tweeting, it might affect the professional relationship they have with their patients. Perhaps they have religious beliefs that they don't consider to be their patients' business or which they feel might make it harder to relate to some of their patients. Maybe they have view on abortion - perhaps they even work or have worked in an abortion clinic - that might put them at risk if people knew who was expressing them. Perhaps they like to share the occasional smutty joke, or other ideas that are perfectly legal, but which some would object to. If they can tweet anonymously they can do all of this without too much concern that it will interfere with their doctor/patient relationships and without revealing information about themself or their family that they would rather kept unidentifiable. But if they have to reveal their full identity, they might have to curtail their use of social media. Some doctors will choose not to participate in social media, rather than lose their anonymity, or risk sanctions by inadvertently revealing that they are a doctor.

Engagement with hostile groups

Doctors may wish to engage with groups or individuals who offer dangerous treatments, or who try to convince people that safe and effective vaccines that will protect them or their children are actually dangerous. Such people and groups can be very vindictive towards people who disagree with them, and doctors (like Orac) may, reasonably, wish to engage with them as a doctor, but without revealing their identity.

Professional learning

Doctors may also want to discuss patients anonymously with other doctors, in order to reflect on their practice and to become better doctors. They are obliged, of course, to maintain patient confidentiality. This can be done by changing some of the details - describing them as male rather than female, saying the consultation had happened in a different month, or whatever. Doctors should, of course, be very aware of the possibility of deductive disclosure of the patient's identity, and shouldn't discuss cases in a public forum if there is any risk of this; but if patient anonymity can be assured, such discussions can be very valuable. 

Cases are often worth discussing because they are in some way unusual. This means that, while there may be many other such cases; there may not be many in that particular doctor's practice. If the doctor's identity is not known they can describe aspects of the case without any risk that the patient's identity could be deduced. But if people know exactly who the doctor is, they might be able to identify the patient - this seems to me to be an argument for tweeting anonymously, which can reduce the risk of inadvertent deductive disclosure.

Whistleblowing or appropriate criticism

Here is a blog written by a doctor who has cause to wish she had made her criticisms anonymously.

Whistleblowers may wish to reveal information anonymously - at least in the first instance. Many of them have been silenced, sidelined, suspended and/or dismissed on a pretext, nothing to do with the issue they were whistleblowing about.  I tweeted earlier about the potential "chilling" effect of section 17 in a sequence of numbered tweets. Imagine a hypothetical situation. You are aware of facts that should be in the public domain. You have reason to believe that the management of the trust where you work wants to cover the situation up and hope it never comes to light - as was probably the case in Staffordshire. You may wish to seek advice as to what to do about it, using social media; or you may choose to raise this anonymously, knowing that the trust will silence you if they can. 

Unfortunately, you have, at some point, mentioned in your anonymous blog or twitter account that you are a doctor. If the Trust can deduce from the information that you are likely to be the source of the information, and they find some way to confirm this (possibly bullying you into admitting it), they've got you! They can now accuse you of a breach of section 17 of GMP 2013, and use this as a pretext for disciplining and silencing you, or to threaten you with a long drawn out referral to the GMC. You've been stitched up by the GMC.

I'm hope this isn't what the GMC intended; but, even if they never take action against any doctor for tweeting anonymously, you can be sure that an HR manager will be well aware that they can use the chilling effect of the threat of a GMC referral (as described above) or of disciplinary action for breaching GMP.

Will the guidance stop people who are not doctors from false claims that they are?

GMC guidance only applies to doctors - or rather, to "registered medical practitioners", which is the protected term. Anybody can claim to be a doctor - or purchase a PhD online from some dodgy university. "Registered medical practitioner" is the legally protected term.

GMC guidance applies only to registered medical practitioners - you can't strike somebody off the register if they're not on it in the first place. So this guidance will have no effect at all on anybody who claims to be a doctor when they are not.

What do proponents of the guidance say about it?

Defenders of the guidance seem concerned that claiming (anonymously) to be a doctor could reduce public confidence in the profession. I'm not sure what they're thinking about here -  they haven't clarified what they mean. I can see that if I were to, for example, promote a commercial product on the basis that I'm an a doctor, albeit an anonymous one, the fact that I'm a doctor might add credence to the product; and if the product were not a good one, my endorsement might reflect badly on me, and on doctors in general. But the fact that I'm anonymous would diminish the credence.

Some proponents of the guidance seem to think that it would prevent doctors from bullying people. I am not aware that doctors are particularly prone to bully people (unless you count asking people to argue their case if they make statements they disagree with - such as that vaccines cause autism). In any case, no evidence has been presented that this is a problem, let alone that forcing doctors to identify themselves if they claim to be a doctor will solve the problem.

If you're going to be anonymous, why is it so important to say you are a doctor?

Defenders of the guidance go on to ask why doctors need to say they are doctors if they want to tweet about their personal lives or beliefs in a way that might be inappropriate if people could identify them need to identify themselves as doctors. As Martin Brunet put it, "If you're going to be anonymous, why is it so important to say you are a doctor?"

This, again, seems naive. The guidance says that if you tweet at all, anonymously, you must not identify yourself as a doctor. If your biography refers to your being a doctor, or you ever mention the fact that you are a doctor, all the tweets from that profile must be identifiable as coming from you. To avoid this you'd have to obsessionally ensure that you never let on that you are a doctor in your biography or any of your tweets.

This is unreasonable. Being a doctor is so much part of most doctors' identity that it would be very hard to tweet without ever revealing what they do - and what is the compelling reason for them to have to keep this a secret?

Have two accounts

Defenders of the guidance sometimes suggest that doctors who wish to tweet anonymously should have non-anonymous "professional" account (or accounts), which they keep scrupulously  professional, not saying anything they wouldn't print in a professional journal; and one or more other anonymous accounts which in which they scrupulously avoid any mention of the fact that they're a doctor. Again, this is naive. Many of the things you might want to say in the non-professional account will be informed by the fact that you are a doctor, making it hard to avoid mentioning the fact in the anonymous account; and in any case, anybody who's tried to tweet from two separate accounts will know that, sooner or later, you will inevitably, accidentally, use the wrong account. 

Missing the point.

In any case, these defences of the guidance are missing the point. Readers of my blog may be aware that I am a small-l liberal. I believe (and in general the law supports this belief) that you should be able to do whatever you like, unless there is a compelling reason why you shouldn't.5 The law - and regulatory bodies like the GMC - should not prohibit or compel any actions without a compelling reason. Supporters of the guidance have singularly failed to provide a compelling reason why this requirement is necessary. Any questions about why anybody should object are therefore irrelevant - you should not restrict people's choices without a compelling reason; and they have failed to provide a compelling reason.

Are doctors so compelled?

It has been suggested that since this is in "explanatory guidance" rather than in the main GMP, and because it only says "should", rather than "must", then doctors have discretion about this, and need not follow the guidance. But GMP says that "'you should' is used when we are providing an explanation of how you will meet the overriding duty" - not much discretion there, then.

The preface to GMP states: “serious or persistent failure to follow this guidance will put your registration at risk”. So even those clauses which only appear in the supplementary guide and not Good Medical Practice itself are to be taken as law.

Illiberal, misconceived, and disproportionate

This guidance is - as David Allen Green would say - illiberal and misconceived. It is disproportionate, requiring a restriction to what doctors may do that is out of proportion. It will prevent some doctors from participating in social media (out of fear of breaching the guidance if they remain anonymous) for no good reason; and it may prevent whistleblowing. It is almost certainly incompatible with the ECHR, and any judgements made on its basis by the GMC will be struck down in court. This would by no means be the first time that the GMC will have been humiliated in this way. Arguably, such a humiliation to the regulatory body will do more harm to the profession than this guidance is likely to prevent.

No less a person than the chair of the the Royal College of General Practitioners, Clare Gerada, has commented (on AM Cunningham's blog - I hope she won't mind if I quote her in full):

"I worry about the constant inference of doctors lives outside their consulting rooms. The GMC has no right (sorry) to control what i do if it is not directly going to influence patients. My life on Social media is mine - with the caveats that we laid down on RCGP SoMe highway code. Doctors are professionals and hence act in that manner - if we transgress there are already enough avenues to seek redress from us. If a doctor wants to be anonymous on social media - so be-it (again see our highway code). Social media needs to develop and must not be nipped in the bud - its finding its way and we need to learn how to use it too its fullest- its like a pen- some can do harm with it , some bring joy."  

I am at a loss as to why the GMC felt the need to change the wording of the guidance - but would it not be better to revert to the wording in the draft guidance, before it does any harm?

===========

A petition to get the guidance withdrawn or amended

Click on the text below to follow the link to sign the petition:

"Medical and Healthcare workers have the right to express themselves in any way they wish provided patient confidentiality is not compromised.

"The new GMC guidance on social media places draconian restrictions on the use of social media by doctors. Similar rules are laid out by the NMC. We feel that doctors, nurses and other health professionals should have the right to express themselves as they see fit in any medium provided patient confidentiality is never breached or in any way compromised. We feel that this kind of freedom of speech is what the health service needs at a time of unprecedented financial and logistical challenges, particularly in light of recent failures and the gagging of staff."

Tweets from a proponent of the guidance

Bernadette John seems to be a supporter of the guidance. I am not sure if she was involved in the consultation process that led to the guidance being changed from its (to me) perfectly acceptable original form, to its current inappropriate form. On 29 Feb 2013 she tweeted extensively in discussions of the guidance, and I have quoted some of her tweets below.

Other blogs on this topic

Footnotes

  1. Footnote01For the purposes of simplicity and brevity in this blog when I refer to twitter, tweets, and tweeting I mean to encompass all uses of social media, including Facebook, blogging, commenting on other blogs, posting on forums...
  2. Footnote02For the purposes of simplicity and brevity, "doctor" is short for "registered medical practitioner".
  3. Footnote03It's an oddity of the guidance that it only says you should give your name. So, if your name is John Smith or similar, you're still fairly unidentifiable, unlike if you have a very unusual name - which seems unfair on those doctors with unusual names.
  4. Footnote04I know that mostly in social medial people are usually pseudonymous rather than anonymous. It's curious that GMC used "anonymous" - but this is probably only because this distinction will seem rather arcane to most people.
  5. Footnote05Or not do things unless there's a compelling reason why you should.
  6. Footnote06Thank you to Anne Marie Cunningham (see comments below) for reminding me where this tweet was.
  7. Footnote07Dr Rita Pal, commenting on AM Cunningham's blog, would disagree with me - she claims that doctors give up all their human rights in exchange for their GMC registration. Do they really, I wonder?

Thursday, November 22, 2012

Dont rubbish flu vaccine just because it's not perfect



I am concerned to see the rubbishing of flu vaccine that is prevalent in the media (both lay and professional) at present,[e.g. 1-4] much of it based on the CIDRAP report.[3]

It is true that the evidence for the flu vaccination programme has always been contested, not least by the Cochrane foundation.[10 et seq] HOWEVER...

My understanding is that:
  • Flu vaccine is effective, albeit much less effective than many other vaccines. It is less effective in older people, partly as a result of immunosenescence (although there are suggestions that adjuvanted or intradermal vaccines may be more effective in this group).
  • It is very difficult to do the studies that would robustly and clearly demonstrate whether vaccination of care and healthcare workers (HCWs) is effective in protecting the people they care for; but it seems not just plausible but likely that it does.[6]
  • Even if vaccinating HCWs has minimal or no effect in protecting the people they care for, it will be as effective in the HCWs as in other adults (i.e. providing useful protection that is still well short of 100% protection); and it is safe.
  • Given this, it seems reasonable to encourage HCWs to be vaccinated (although I have previously expressed my reservations about vaccine promotion materials and messages that go beyond the evidence, as I think some of the DH/NHS Employers' messages do).
I have discussed the issues of compulsory vaccination (or mandation or whatever expression you prefer) of healthcare staff previously in Vaccines in Practice.[7]. I am not entirely convinced by the arguments – in either direction. Crislip, for example, makes a good case for it here[8] and here (incorporating his wonderful "budget of dumb asses"[9]). Going along with reasonable precautions is a duty of HCWs. It is also true that people don’t need to choose to be HCWs, so in that sense they do have a choice not to be vaccinated; but whether expecting them to change their job to avoid it is reasonable is another matter.

Colleagues wrote an excellent response to a previous flurry of concern.[6] Would it be better if something similar were to be published in a more august publication than Pulse magazine? Is some other sort of credible response appropriate. Maybe a series of articles in widely read magazines like Pulse would be more effective – perhaps we should give to up the journalists bandoliers with “bullets” of evidence rather than trying to write all the articles ourselves.

It’s all rather difficult, because in many ways the CIDRAP report is very sound.[5] Some may view it as special pleading from researchers who want even more resources to fund better vaccines; but it is true that flu vaccine:
  • is not as effective as we’d like
  • is not “universal”, so we have to give a new vaccine every year (or at least most) years, to counter the changes to the virus that mount up through “drift” and “shift”
  • is not as effective in old people
  • has to be given by injection (except for the newer LAIV vaccines) – and this seems to deter a lot of people from having it
With all of these disadvantages, there is clearly a real need for a new vaccine; which is the key message of the report. If, say, we could find a vaccine that only needed to be given once every 15 years (perhaps after an initial prime/boost course), and had half the failure rate of current vaccines, that would save huge numbers of lives, not to mention healthcare costs from disease prevented and savings from not having to give the vaccine every year.
We must not allow people to promote the Nirvana fallacy or perfect solution fallacy – the idea that because the available flu vaccines are imperfect, they must be useless.

But how should we respond?

(I have had my annual flu vaccine; and I cannot understand why anybody should refuse it if offered - unless they are one of the tiny minority with a genuine contraindication.)

UPDATE 23 November 2012
Since writing this post I have seen  an excellent piece at the NHS Choices web site. It is a good response (better than mine, above), and deservers wider readership.

It is accompanied by an audio track which is also very good.

Irritatingly when I opened that site on my smart phone an audio feed started up - from Dr Rob Hicks. It was annoying enough that my phone had started starts talking to me while there were other people around and it was inappropriate - I dislike web sites that open audio or video feeds without asking ou first. It took me some time to work out what was going on, and to silence the phone (the talking continued when I pressed the off button, as if it were a music track).

Worse, the piece starts by explaining that people who have genuine flu know about it because they are really ill. So ill that if they were to see a £10 note on the floor, they probably wouldn't bother to pick it up... As I understand it, serological surveys following flu epidemics or outbreaks show that lots of people became immune to the virus without having had serious symptoms, suggesting that a lot of people with the infection have mild or no symptoms. This made me question the content of the audio stream. Having listened again more carefully I think he did say "the vast majority of  people with..."; and apart from the repeated statements that people with flu have much more serious symptoms (which is true for a signficant number of cases, perhaps even a majority who have symptoms at all), the rest of the audio content seems very good. 

  1. Lenzer J. Beliefnot science is behind flu jab promotion, new report says. BMJ 2012;345.(http://www.bmj.com/content/345/bmj.e7856). 
  2. Silverman R. Flu vaccine effectiveness exaggerated, scientists claim. 2012; London: The Telegraph, Updated 21 November; Accessed: 2012 (22 November): (http://www.telegraph.co.uk/health/flu/9692193/Flu-vaccine-effectiveness-exaggerated-scientists-claim.html). 
  3. Borland S. Flu jabs are a 'waste of taxpayer's money', claim scientists who say the benefits have been over-hyped. 2012; London: Daily Mail, Updated 22 November; Accessed: 2012 (22 November): (http://www.dailymail.co.uk/health/article-2236253/Flu-jabs-waste-taxpayers-money-claim-scientists-benefits-hyped.html).
  4.  McCartney M. Show us the evidence for the flu jab. Pulse 2011;71(34):18-19. (http://www.pulsetoday.co.uk/main-content/-/article_display_list/12911759/show-us-the-evidence-for-the-flu-jab).
  5. Osterholm MT, Kelley NS, Manske JM, Ballering KS, Leighton TR, Moore KA, et al. The Compelling Need for Game-Changing Influenza Vaccines. An Analysis of the Influenza Vaccine Enterprise and Recommendations for the Future. Minneapolis, MN: The Center for Infectious Disease Research and Policy (CIDRAP), University of Minnesota, 2012 (October); 1-160 (http://www.cidrap.umn.edu/cidrap/files/80/ccivi%20report.pdf).
  6. Ghebrehewet S, Stewart A. Flu vaccination of HCWs reduces illness in vulnerable patients. Pulse Online 2011, Updated 24 November; Accessed: 2011 (28 November): (http://www.pulsetoday.co.uk/main-content/-/article_display_list/13118389/the-flu-vaccine-is-evidence-based-and-here-s-the-evidence)
  7. English PM. Should we introduce compulsory vaccination? Vaccines in Practice 2008;1(2):1-3. (http://www.vaccinesinpractice.co.uk/ - one-off free registration required). 
  8. Crislip M. Influenza Vaccine Mandates. Science Based Medicine 2010, Updated 22 October 2010; Accessed: 2011 (4 January): (http://www.sciencebasedmedicine.org/?p=7714).
  9. Crislip M. Protect Yourself. 2012: Science Based Medicine (blog), Updated Sep 21, 2012; Accessed: 2012 (3 October): (http://www.sciencebasedmedicine.org/index.php/protect-yourself/).
  10. Thomas RE, Jefferson T, Lasserson TJ. Influenza vaccination for healthcare workers who work with the elderly. Cochrane database of systematic reviews (Online) 2010;2(17):CD005187  PMID: 20166073. (http://www.mrw.interscience.wiley.com/cochrane/clsysrev/articles/CD005187/frame.html).
  11. Jefferson T, Di Pietrantonj C, Rivetti A, Bawazeer GA, Al-Ansary LA, Ferroni E. Vaccines for preventing influenza in healthy adults. Cochrane Database Syst Rev 2010;7(7):CD001269  PMID: 20614424. (http://onlinelibrary.wiley.com/doi/10.1002/14651858.CD001269.pub4/abstract)
  12. Jefferson T, Di Pietrantonj C, Al-Ansary LA, Ferroni E, Thorning S, Thomas RE. Vaccines for preventing influenza in the elderly. Cochrane database of systematic reviews (Online) 2010;2(17):CD004876  PMID: 20166072. (http://www.mrw.interscience.wiley.com/cochrane/clsysrev/articles/CD004876/frame.html).