GP practices, along with other types of business, need to ensure they meet the minimum legal requirements and comply with sector specific standards with regard to employees’ terms and conditions of employment and, more widely, HR policies and procedures.
However, this doesn’t mean having a policy for everything, as this only creates unnecessary bureaucracy and can actually get in the way of the day-to-day management and operation of your practice. A policy is not worth the paper it’s printed on if there is no evidence that what it says actually happens.
We asked a leading HR company to review a local GP practices’ policies. They said:
“There is definitely a bit of a culture in GP practices of having very long lists of policies. In this example, you can move a lot of their policies into one. There is considerable duplication. For example, about 20 of them could be combined/reduced to an Equality/Diversity statement and one Equality Policy.”
Practice Managers have told us that the abundance of advice and opinion available on-line has become confusing and creates more uncertainty. It also results in too many poorly drafted and often unnecessary policies and procedures.
Here are some recent comments from Practice Managers:
“It has reached the stage where we have to have a protocol to write a protocol, I have so many protocols now I need an index a mile long to list them all.”
“By the time I have reviewed all the policies it is time to start all over again as another year has passed.”
“In preparation for our CQC visit policies were reviewed and brought up-to-date – yes, I know this should be done all the time, but really who does that?!”
“If you have 200 policies and it takes you 5 minutes to review each one. That’s 1000 minutes. That’s over 16 hours. That’s two solid working days! These are conservative figures too.”
“Do we not need to rein in the proliferation of the three P’s (Policies, Procedures, Protocols) and stick to essential documents that have a clear purpose and someone will read. I recall spending around six months on and off writing policies. The time needed to get it right should not be underestimated. The problem is deciding what is essential.”
You may be surprised to know that very few HR policies are required by UK law, although it is helpful to have some essentials in place to help avoid legal problems and to set out the standards expected of staff.
In addition to a well-drafted Statement of Particulars of Employment (aka the contract), a GP practice would typically benefit from having around 12 to 15 essential HR policies which reflect the needs of the practice and ensure compliance with CQC and other NHS standards.
Remember, although there is a raft of employment legislation that you must comply with, you can choose to refer to the statutory provisions rather than duplicate the information in your own policies. This has the added advantage of always being up-to-date.
Reasons why you should have HR policies:
- To communicate and inform employees
- To provide evidence of good practice
- To guide managers
- To meet statutory requirements
- To comply with CQC and NHS standards
Reasons why not to have HR policies:
- Because you think (wrongly) that you have to have them all
- To avoid real management of an issue by deferring to (or blaming) ‘the policy’
- Fear of getting things wrong
“In my experience, it is useful to have a written policy and procedure, especially when dealing with difficult issues or Employment Tribunal claims, however, a written document that sets out ‘how we do things’ isn’t actual proof that it happens. When dealing with employment and staffing issues it’s the quality of the conversation that counts – the policy and procedure is secondary”. Dianne Lambdin, HR and Employment Law specialist, The Sussex HR Hub.
The CQC expects practices to have policies and procedures in place for almost every eventuality. During an inspection inspectors will be less interested in the piece of paper than in evidence that the policies are understood by all staff and that the policies are updated regularly to reflect current practice.
We spoke to a Practice Manager who is also a CQC inspector. He said:
“Most practices cover themselves with inserting review dates onto their policies, but few do actually review these other than just change the date, and usually just before a CQC inspection.
Almost every practice I have been to for CQC inspections, reviews, preparations etc have standard purchased policy templates that they have updated as being reviewed. However, there are some major telltale signs that these have not, i.e. reviewed in 2015, but still refers to PCT’s!”
So be confident and positive about how you approach HR and by all means have relevant HR policies and procedures in place. But remember, they should be a means to an end, not the end in their own right.
Thank you to our members Robert Campbell and Nicola Hayward for their input in this article, as well as Dianne Lambdin, HR and Employment Law specialist at The Sussex HR Hub.