Payment for Safeguarding reports
Did you know practices can claim for any safeguarding reports submitted?
If you don’t already claim for safeguarding reports, this is a reminder to practices should invoice the ICS for any safeguarding reports completed by the GP.
SUBMITTING A SAFEGUARDING INVOICE TO THE ICB
There are two ways to submit invoices to the ICB.
- The first is sending the physical invoices to the below address:
NHS Leicester, Leicestershire & Rutland ICB
QK1 PAYABLES N235
PO Box 312
LEEDS
LS11 1HP
FAO: XXFHUSSEIN
- The second option is to submit invoices electronically via SBS Oracle:
Send final PDF invoice via email to: sbs.apinvoicing@nhs.net to submit (following the criteria below):
- Any email containing the word “Statement” or "Reminder" within the subject line will be automatically deleted by the system.
- PDF invoices may be sent to this email box as an attachment for processing. Please note only PDF Email attachments will be accepted, other file formats will be rejected.
- Emails with multiple PDF’s are acceptable, however there should be only one invoice per PDF and any backing documentation must be included in the same PDF as the relative invoice.
- Multiple invoices within the same PDF document cannot be processed.
- Please include the following info on the invoice:
NHS Leicester, Leicestershire & Rutland ICB
QK1 PAYABLES N235
PO Box 312
LEEDS
LS11 1HP
FAO: XXFHUSSEIN
Safeguarding invoices will need to be clearly marked as for the attention of Fayaaz Hussein (XXFHUSSEIN). This will help speed up the allocation process when invoices come on to the system for processing.
Safeguarding invoices will need to be clearly marked as for the attention of Fayaaz Hussein (XXFHUSSEIN). This will help speed up the allocation process when invoices come on to the system.
Invoices should be sent to cover reimbursement of professional time for the completion of safeguarding reports. Practices should submit safeguarding invoices to ICB. The amount claimed will be dependent on the complexity and time taken to produce the report – we have included some BMA guidance on professional fees: Fees (bma.org.uk)
BACKGROUND
The guidance from GPC regarding obligations and entitlements of General Practitioners who are asked to attend child protection case conferences or to prepare written safeguarding reports for use at them.
This guidance was influenced by extensive feedback and examples of cases from GP's across Leicester, Leicestershire and Rutland.
We are aware this differs across the Country but GP’s within LLR don’t currently receive a fee for the completion of safeguarding reports. LLR LMC have been lobbying to get this changed. Dr Rao (Vice-Chair, Operations, LMC) has written to the CCG Chairs and Safeguarding teams raising these points.
GPC is aware of ongoing problems around the obligations and entitlements of General Practitioners who are asked to attend child protection case conferences or to prepare written safeguarding reports for use at them.
It has been brought to our attention that some CCGs, while noting the GP contracts contain no provisions requiring them to contribute to the safeguarding process, have nonetheless suggested that GPs would need to justify non-compliance, with regard to their statutory safeguarding duties, if a report was not submitted, and that non-compliance could justify a referral to the GMC, with the implication that disciplinary action could be taken against defaulting GPs.
Alternatively, it has been suggested that a CCG could contemplate taking action for alleged non-compliance by means of a breach/remedial notice.
The approach of GPC has been to encourage practices to engage with safeguarding processes, but to agree a fee in advance of attending conferences or providing reports.
The provision by GPs of the relevant safeguarding services falls outside the scope of the range of essential, additional or enhanced services provided for in parts 8 – 12 of the standard GMS contract. Clause 19.1.2 (a) of the GMS contract specifically permits the contractor to demand or accept a fee or other remuneration ‘from any statutory body for services rendered for the purposes of that body’s statutory functions’
GPC has obtained external legal advice on the issue, and has concluded that GPs do have an obligation to comply with their statutory safeguarding duties, but equally that they are entitled to a fee.
GPC advice
There are no agreed fees for completing safeguarding reports or attending case conferences.
GPC’s advice is therefore to provide the relevant services, but on the basis that a fee will be sought for the same, indicating the rate of charge ahead of the provision of the report or attendance at the case conference as the case may be.
The commissioner of the service would be notified that acceptance of such services will be treated as signifying a willingness to engage the GP on the stipulated terms. In the event of non-payment a claim for the fee could then be pursued.
This type of work falls under Section 80 of the NHS Act 2006 and enables local authorities to carry out their responsibilities in the fields of education, social services and public health.
A GP may breach confidentiality if it is in the public interest, but since this work involves either children or vulnerable adults, we would advise doctors to seek advice before doing this.