Primary Care advertising guidance
The CCG/ICS has produced some guidance on primary care advertising (April 2021)
LLR CCGs are supportive of any practice promoting new patient registrations and encouraging patients to access NHS services. However GP practices must be mindful of the duties and obligations they are under as providers of NHS primary medical services to the public. Therefore the CCGs cannot allow advertising and marketing campaigns to continue where they have the potential:
- To undermine the public’s trust in the NHS services that we commission,
- To exploit the vulnerability of patients
- To influence patient choice in order to realise a benefit to the person runningthe campaigns.
With the above in mind, the key policy and contractual considerations as registered medical practitioners are the rules and regulations imposed by the General Medical Council (the “GMC”). The GMC regulates by reference to a specific set of guiding principles set out in the document called “Good Medical Practice”. These principles set out, as the GMC describe it, “what is expected of all doctors who are registered with the GMC.”
It is the last domain (maintaining trust) that registered medical practitioners are subject to the following core duties and any advertising will need to comply with these principles:
Principles For Advertising (based on the GMC Guidance)
- When advertising primary care services, practices must make sure the information published is factual and can be checked, and does not exploit patients’’ vulnerability or lack of medical knowledge.
- Practices must not allow any interests they have to affect the way they prescribe for, treat, refer or commission services for patients.
- Practices must not ask for or accept – from patients, colleagues or others – any inducements, gifts or hospitality that may affect or be seen to affect the way you prescribe for, treat or refer patients or commission services for patients.
- Practices must not offer these as inducements.
- Practices must not try to influence patients’ choice of healthcare services to benefit them. Therefore any advertising campaigns must not influence patients in this way.If your practice is planning any advertising and promotional campaigns the above needs to be adhered to and considered in your planning and delivery of such campaigns. Practices are advised to have discussions within the PCN around establishing a consistent approach to advertising services across PCN practices, contact the LMC or the CCG to discuss an accepted approach.
Any queries relating to this communication please contact ICS contracts/LMC office