Doctors under GMC investigation 'face 13 times higher suicide risk', LMCs hear
LMCs have warned the GMC is creating a 'climate where doctors practise in fear for their registration' after hearing evidence that doctors under investigation by the regulator face a suicide risk 13 times higher than the general UK population.
by David Millett
https://www.gazettelive.co.uk/news/teesside-news/widow-doctor-who-killed-himself-17828771
A suicide verdict was delivered at the inquest of North Tees anaesthetist Sridharan Suresh
A coroner is writing to agencies to ensure policies have been tightened after the “tragic and untimely” death of a respected doctor.
But his widow maintains those agencies “failed” her husband - and she’s continuing the fight to get better protection for doctors in distress.
Teesside Senior Coroner Clare Bailey was speaking after recording a suicide verdict at the inquest of Dr Sridharan Suresh.
The three day inquest, at Teesside Coroners’ Court, heard how Dr Suresh’s body had been recovered from the river near Jubilee Bridge, Stockton, on May 2, 2018.
The 50-year-old senior consultant anaesthetist at the North Tees and Hartlepool NHS Foundation Trust had just been told by email that allegations against him - which he strongly denied - had been referred by police to the General Medical Council.
Yet at a meeting on April 19 with trust bosses, he’d been mistakenly assured no referral was being made and that he was likely to be allowed to return to work soon.
He was also under the impression a police investigation was being dropped - yet it was the police who referred the matter to the General Medical Council.
But no-one from the trust or police told him about the referral, which he only learned about from the GMC email on the day he died.
The allegation against him centred around a teenage patient claiming Dr Suresh had touched her sexually after administering a sedative.
However, the inquest heard, the drug can cause hallucinations, there were no witnesses to the alleged incident, and the patient’s description of the accused differed vastly from Dr Suresh’s actual appearance.
Dr Suresh, a father-of-two from Ingleby Barwick , totally denied any wrong-doing. His widow has consistently claimed failings in the system meant he didn’t receive enough support in light of the allegations being made.
Recording a verdict of suicide, the coroner said it was clear to her that Dr Suresh was a “dedicated, father and husband” who had an “exemplary work record”.
She said she had been particularly concerned about the trust’s failure to “recognise, communicate and escalate information about a third party GMC referral”.
She was also concerned “by the failure to inform Dr Suresh of the referral...because of assumptions made by the police and the trust”.
But she said things had improved and that she’d been ensured “the gap that existed” as to who should inform an individual about a GMC referral had been closed.
She told the inquest she would be writing to the trust “asking for confirmation within 28 days that the points raised...have been incorporated into the trust’s policies and procedures”.
She said she would write to the GMC to ensure it asks correct questions about whether a doctor is vulnerable, and whether the correct procedures are followed when informing doctors about referrals.
She is also going to ask the GMC to include, in emails they send doctors about referrals, another sentence to ensure they know they can phone the GMC about the situation.
She concluded: "I'm satisfied, and I hope Mrs Suresh is satisfied, that very serious lessons have been learned and that procedures have been adopted and policies changed by all the agencies involved which have been aimed to prevent similarly circumstance arising which preceded her husband’s tragic and untimely death."
Speaking after the hearing, Dr Suresh’s widow said: “These three agencies in this case failed my husband. He was a family man, caring husband, loving father and a dedicated doctor.”
His employers “owed him a duty of care”, she continued.
A spokesperson for the North Tees and Hartlepool NHS Foundation Trust said: “We would like to extend our sympathies to all concerned surrounding the death of our highly valued colleague, Dr Sridharan Suresh.
“Our Trust is dedicated to ensuring that the health and wellbeing of all of our employees is an absolute key priority. We have an extensive process in place to support staff members facing difficult or challenging times during their employment with North Tees and Hartlepool NHS Foundation Trust. This support can include counselling, regular calls/meetings with named management and/or occupational health contacts.
“We always aim to improve and we note that the coroner was assured by the learning and changes to process we have already made.”
A GMC statement about the case said: “Our investigation was at a very early stage and we had no information to indicate that the doctor was vulnerable or at risk.
“‘Our letter was polite and informative, but had we been aware of concerns about the doctor’s vulnerability we would have made arrangements to ensure he was supported.
PUBLISHED: 15:09, 27 February 2020 | UPDATED: 07:49, 28 February 2020
+2View gallery
Dr Sridharan Suresh, 50, a senior consultant anaesthetist at the North Tees and Hartlepool NHS Foundation Trust, was found dead in the River Tees near Jubilee Bridge in Stockton on May 2, 2018. Pictured is his wife, Visalakshmi, at his inquest today
A married anaesthetist took his own life after being accused of sexually assaulting a teenage patient he sedated with a drug known to cause hallucinations, an inquest heard yesterday.
Dr Sridharan Suresh, 50, a senior consultant anaesthetist at the North Tees and Hartlepool NHS Foundation Trust, was found dead in the River Tees near Jubilee Bridge in Stockton on May 2, 2018.
The allegation against him centred around a teenage patient claiming Dr Suresh had touched her sexually after administering a sedative.
However, the inquest heard, the drug can cause hallucinations, there were no witnesses to the alleged incident, and the patient's description of the accused differed vastly from Dr Suresh's actual appearance.
His software architect wife, Visalakshmi, told Teeside Coroners' Court that her husband felt his character had been 'assassinated' by the sex claims, which he vigorously denied.
Dr Suresh was under the impression the police investigation into the allegations was to be discontinued and that he was to be allowed to return to work, the court heard.
However, his hopes of moving on from the allegations were shattered when he received an email from the General Medical Council announcing it was continuing its probe. He was found dead the same day.
His wife said Dr Suresh had been ‘devastated’ by the claims as she told the court: 'In our eyes, my husband was being defamed.'
Dr Suresh had expected to return to work on April 19, 2018, only to be left 'shattered' after being told by the trust the day before that his exclusion was being extended by four weeks 'to dot the i's and cross the t's'.
She said he was also assured at a meeting on April 19 with North Tees and Hartlepool NHS Foundation Trust that police wouldn't refer the matter to the Crown Prosecution Service unless they found substantial evidence to support the allegation.
On April 30, the trust's HR department contacted him to say they were still awaiting news from police.
On May 1, he received an email from the GMC, asking to confirm his email address.
But on May 2 - the day of his death - another GMC email was sent to him 'setting out allegations and what was going to happen.'
The inquest heard that Dr Suresh, who was born in India but lived in Ingleby Barwick, was an experienced and respected consultant doctor at the height of his career.
His wife said he feared his reputation would be shattered if there was a GMC investigation, which could last for years. He wanted to clear his name, resign from the trust and move to London, she added.
The inquest heard that an email Dr Suresh sent to his wife the day he died contained information that he intended to take his own life, saying that he had 'done nothing wrong' but that he couldn't 'go on like this forever'.
In an impact statement, she said her husband had felt isolated but there had been a lack of support, and that even a reassuring phone call 'would have made a huge difference'.
Calling it a 'systematic failure from the organisation', she said: 'He was totally dedicated to serving his patients.'
+2View gallery
Dr Sridharan Suresh, 50, a senior consultant anaesthetist at the North Tees and Hartlepool NHS Foundation Trust, was found dead in the River Tees near Jubilee Bridge in Stockton on May 2, 2018
Teesside senior coroner Clare Bailey asked her: 'At any point were you concerned your husband might take his own life, or would be vulnerable to self-harm or hurting himself?'
She replied: 'No'.
When Leslie Thomas QC, who is representing the family, asked why he didn't request occupational therapy, she said: 'Because he had been told that there would be no referral and he would get back to work soon.'
She also said he was never told by police that a referral to the GMC had been made.
A post mortem gave the medical cause of death as drowning. The inquest is scheduled to conclude tomorrow.
For confidential support in the UK call the Samaritans on 116123, visit a local Samaritans branch or click here for details.
...Although the responsibility of regulators towards those they regulate remains unclear, the case of Watson v. British Boxing Board of Control (BBBC) Ltd55 demonstrates that a regulatory body does owe an affirmative duty to exercise care towards those it licensed as professional boxers. Therefore, the relationship between a regulator and those it licensed falls within an established category of liability for which a duty of care arises. Some may, however, argue that the BBBC is distinguishable from the GMC not least since the former is a sporting body and a non-statutory regulator, whereas the latter is a statutory regulatory body.56 Even if the current situation is, on this consideration, deemed to be outside any existing category of duty of care, it would still meet the 3-stage requirements outlined in Caparo Industries Plc v. Dickman.57 According to the House of Lords in that case, in situations where the courts have not previously recognised a duty of care, its presence can be established if injury is reasonably foreseeable; the parties are in a relationship of proximity; and it is fair, just and reasonable for a duty of care to be imposed. In relation to the first stage, the 28 doctors fall within a class of individuals (namely those under FTP investigation) to whom it is reasonably foreseeable that the GMC's failure to exercise care would cause them harm.58 The GMC as highlighted in Part 2 of this work, knew or ought to have known of a real and immediate risk to the lives of those identifiable individuals.
The suicide of doctors under regulatory investigation in the United Kingdom has recently been under scrutiny. Despite a commissioned report into the issues surrounding these deaths, we discuss a variety of procedural and legal lacunae not yet openly considered for reform. We identified that the UK coronial system has in place several legal instruments requiring coroners to report the physician suicides as preventable to the regulatory body, the General Medical Council (GMC). We were unable to identify that these suicides were reported in line with established legislation. We also explored the relationship between the GMC and its registered doctors, concluding that the GMC does indeed have a duty of care towards its members on this important matter and that there should be procedural reform to tackle the inherent risk of suicide whilst under investigation.
28 doctors committed suicide between 2005 and 2013 whilst under fitness-to-practise (FTP) investigations. These were the alarming and distressing figures revealed following a Freedom of Information (FOI) request made independently to the General Medical Council (GMC) in 2012 by a psychiatrist, Dr Helen Bright.1 The reasons for the suicide are multitudinous. However, a common theme is the stress and threat of investigation by the GMC and the painfully named ‘death by 1000 arrows’ 2 associated with an almost simultaneous investigation by various other authorities. This may include the police, an employer, the Clinical Commissioning Group, NHS England, and the Local Medical Committee. These deaths were not contemporaneously highlighted as preventable and only recently made public. In this article, we seek to explore whether these deaths could indeed have been averted, and if so, by whom and how. Part 2 below will discuss how far FTP investigations should be recognised as a distinct suicide risk factor. By analysing firstly the high rate of suicide among doctors in general, the discussion will then assess the extent to which ongoing FTP investigation either exacerbates existing suicide tendencies or poses as an abnormally insurmountable challenge, so much so that it warrants consideration as an independent risk factor for physician suicide. In Part 3, we will argue that the failure thus far to isolate and recognise FTP investigation as a risk factor has meant that insufficient effort has been made to prevent the death of the affected doctors. The 2 main parties on whose shoulders lie the bulk of the responsibility are the coroners and the GMC itself. We aim to highlight specifically, that none of the deaths were reported by the coroner under Rule 43 of the Coroners Rules 1984 or as Prevention of Future Deaths (PFD) Reports under the Coroners and Justice Act 2009.3 The reporting of these deaths to the GMC may have promoted brisk, efficacious changes in the manner in which doctors are investigated and may have prevented the loss of lives. Further, even in the absence of a PFD report, it will be argued that the GMC has actual or constructive notice of the cause of death. This, coupled with the gravity of the issue, gives rise to a duty to take appropriate actions to ensure that further suicides are averted. Part 4 reflects on the lessons that need to be urgently learnt from the array of failings to date.
Suicide whilst under GMC's fitness to practise investigation: Were those deaths preventable? David Casey a, * , Kartina A. Choong b a School of Medicine and Dentistry, University of Central Lancashire, Preston PR1 2HE, United Kingdom b Lancashire Law School, University of Central Lancashire, Preston PR1 2HE, United Kingdom
JFLMsubmission (pdf)
DownloadDoctors who commit suicide while under GMC fitness to practise investigation Internal review Sarndrah Horsfall, Independent Consultant 14 December 2014 Executive summary Introduction This report was commissioned by the GMC to review those cases where doctors have committed suicide while under the fitness to practise procedures between 2005 (when the GMC introduced electronic data systems) and 2013. The aim was to establish whether the GMC’s processes could be improved to reduce the impact on vulnerable doctors and whether there is more the GMC can do to prevent these tragedies from occurring. The report addresses lessons that can be learnt from these deaths, as well as any changes the GMC could make in the way it handles vulnerable doctors. During the period under review there were 28 reported cases in the GMC’s records where a doctor committed suicide or suspected suicide while under their investigation procedures. The case reviews showed that many of the doctors who committed suicide suffered from a recognised mental disorder, most commonly depressive illness, bipolar disorder and personality disorder. A number also had drug and/or alcohol addictions. Other factors that may have contributed to their deaths included marriage breakdown, financial hardship, the involvement of the police and the impact of the GMC investigation. Case reviews The review identified 114 doctors that had died during 2005 and 2013 inclusive and had an open and disclosed GMC case at the time of death.
Doctors who commit suicide while under GMC fitness to practise investigation Internal review Sarndrah Horsfall, Independent Consultant 14 December 2014
Internal-review-into-suicide-in-FTP-processes_pdf-59088696 (pdf)
Download
Published 3 March 2022
The General Medical Council has published a report on doctors who have died while under investigation or during a period of monitoring.
The data shows that sadly 29 doctors died while under GMC investigation or monitoring over the three-year period 1 January 2018 – 31 December 2020. The cause of death of 20 were from natural causes; six were of external causes, of which five were confirmed as suicide; and three were from unspecified reasons.
The data, which will now be published on an annual basis, has been introduced following a new process for obtaining and recording the cause of death of doctors who die while they are in the regulator’s fitness to practise procedures.
The work is part of the GMC’s wider drive to reduce the impact and stress of its processes. In recent years the regulator has commissioned an independent review looking at cases where doctors had died from suicide while under investigation. The GMC also appointed leading independent mental health expert, Professor Louis Appleby, to advise on how it could make its approach more sensitive, supportive and compassionate to the needs of doctors which led to wide range reforms of the fitness to practise process.
"If any improvements can be made, we move with pace to implement them."
Anthony Omo
Director of Fitness to Practise and General Counsel, GMC
Anthony Omo, Director of Fitness to Practise and General Counsel at the GMC, said:
‘Complaints can be extremely distressing for doctors, patients and their families. Although we’ve come a long way in improving how we handle them, we will continue to listen to feedback to identify further improvements that we can make to our processes or how we communicate with doctors.
‘Any death is tragic and when it happens, we undertake a review to ensure we understand and learn any lessons. If any improvements can be made, we move with pace to implement them.’
Doctors-who-have-died-while-under-investigation-or-during-a-period-of-monitoring-2018-2020--89398370 (pdf)
Download‘I never even dreamt or thought that this could happen in my home – and especially to my husband. Definitely, this decision that has come out of him is not his own. He must have been shattered by seeing that letter.’
On 2 May 2018, Sridharan Suresh, a consultant anaesthetist at North Tees and Hartlepool Hospitals NHS Foundation Trust – a doctor with an ‘exceptional, unblemished’ professional record – received a letter from the GMC informing him he would be subject to an interim orders tribunal.
Dr Suresh had been under police investigation at the time following allegations of sexual touching made by a teenage patient undergoing sedation for dental extraction – although an inquest into his death last year heard that the drugs used to sedate the patient are ‘well-known’ to produce hallucinations and heightened sexual feelings, the description the victim gave did not match Dr Suresh’s appearance and the police later closed the case with ‘insufficient evidence’.
Dr Suresh had been told by his trust he would not be referred to the GMC, but the police made a third-party referral and the trust did not inform Dr Suresh, despite knowing the action had been taken.
The letter came as a ‘bolt from the blue’. Just hours later Dr Suresh sent an email to his wife saying he had done nothing wrong, but could go on no longer, and took his own life.
Speaking to The Doctor, Dr Suresh’s widow, Viji Suresh (pictured, top), says: ‘He was on his own, he was alone, there was nobody there with him. The amount of impact it had – it was a kind of shockwave. His mind was not in the right place.
‘For me it is an irreplaceable loss and causes me extreme anger and disappointment.’
Mrs Suresh’s medico-legal adviser Rajendra Chaudhary says: ‘I didn’t know Dr Suresh but when I see that letter myself it hits me how this would have panned out in his mind.
'Doctors see the GMC as a very cold, unsympathetic organisation, and that they have no concern whatsoever about doctors’ wellbeing. You feel you become guilty before you have been tried.’
GMC figures show that in 2019 there were 8,654 fitness-to-practise enquiries – the majority from members of the public. Of those 1,389 extended to a full investigation, 602 to a provisional inquiry and 365 ended in a referral to a responsible officer.
The significant majority, 6,298, were closed prior to those stages at ‘initial triage’.
And it is clear that the effect of each and every one of these processes can be huge.
A West Midlands GP, who asked to remain anonymous, told The Doctor the stress of even the initial, six-week in his case, inquiry ahead of a potential investigation had a huge impact – and led to him taking medication to block obsessional thoughts and emotions.
He says: ‘It affected every grain of me in terms of what I did in the workplace. I had repetitive, intrusive thoughts and anxiety and it just wouldn’t go away. I constantly worried about everything else that happened, other patients I had seen and I was constantly looking back and analysing things I had done. On top of that I worried about losing my job and becoming destitute and all those sorts of things.’
He adds: ‘I ask myself – “would I have had the resilience to persevere knowing how long this process would take?”
It is an irreplaceable loss and causes me extreme anger and disappointmentViji Suresh
I don’t think I would have had the armoury to cope with that at that point.’
The effects of these processes should not be a surprise to the regulator, either. It has even investigated the link between doctor suicide and fitness-to-practise investigations itself, before.
In 2014 the GMC commissioned an independent review from Sarndrah Horsfall, which identified 28 suicide – or suspected suicide – cases among doctors under investigation between 2005 and 2013.
Manchester University professor of psychiatry Louis Appleby was subsequently tasked with analysing the impact of GMC investigations on doctors and coming up with proposals to lessen those impacts.
He said at the time that ‘suicide is not confined to those who are known to be mentally ill – it can be those who are thought to be coping that are most at risk – so reducing risk is a task for the system as a whole’.
Speaking to The Doctor, Professor Appleby says doctors under investigation can feel trapped, humiliated and unjustly treated – three ingredients for a recipe of great concern.
He adds: ‘Sometimes the response in the system can seem disproportionate when doctors start to see not just a threat to their livelihoods and professional standing but something much more profound about who they are.’
The GMC says it made a number of changes following the review, including only carrying out formal investigations ‘where necessary’, ‘coordinating’ approaches so doctors under investigation has a single point of contact, ‘improving’ communications with doctors, and establishing a specialist team to handle cases where doctors are unwell.
Doctors see the GMC as a very cold, unsympathetic organisationRajendra Chaudhary
All of these changes were made prior to the death of Dr Suresh and he was not identified as vulnerable. It seems the GMC would likely need something as clear cut as an obvious diagnosis of mental ill health in order to trigger any particular concern or extra layer of compassion.
Professor Appleby says: ‘The gap that leaves – an important gap – is that sometimes people who feel that sense of humiliation or being unjustly treated might not have a mental disorder.
'That is, to some extent, a natural reaction of the high-standard, perfectionist, professional challenged about the work they do and in which their identity is wrapped up. It’s very important we don’t just see suicide risk as just in those people who have got a specific mental disorder. It also applies to other people who may not be depressed in a clinical sense but are becoming a risk because of these factors and these reactions to the process.’
As Dr Chaudhary says: ‘I personally feel it was quite foreseeable that there was a high risk of self-harm at this point – particularly for someone facing those allegations already.’
The BMA is supporting Dr Suresh’s family in a claim for damages and other relief brought under the Human Rights Act 1998, the law of negligence under the provisions of the Fatal Accidents Act 1976 and under the Law Reform (Miscellaneous Provisions) Act 1934.
A letter before action will be sent to the GMC outlining the details of the case. It says the GMC should have known there was a real and immediate risk of suicide, and that there were system failures after the GMC failed to take any steps to liaise with Dr Suresh’s employer or the police to assess his vulnerabilities, despite Dr Suresh telling his trust how the investigations were affecting him and his family.
The letter outlines that the GMC’s communication with Dr Suresh on 2 May 2018 was impersonal despite the GMC suggesting it has improved these processes. It also says the GMC failed to conduct a risk assessment.
BMA council chair Chaand Nagpaul says: ‘Those three letters – GMC – send a shiver down any doctor’s spine. For as long as I have known every doctor lives in fear of a letter through their letterbox from the GMC. When doctors see such a letter, what flashes through their minds is they see their careers ending, they fear adverse publicity, they fear suspension from their employers, they fear for their livelihoods, they fear the shame and they fear their side not being heard.’
I feel it was quite foreseeable that there was a high risk of self-harm at this pointRajendra Chaudhary
In his report, Professor Appleby also recommends ‘systematic recording’ of the cause of death of doctors under investigation but the GMC told The Doctor it did not introduce this new method until January 2018.
As such there was no systematic monitoring, and are no figures available, for the period from the report concluding to January 2018.
The GMC has been collecting the figures since but has not yet published them.
In April, in a response to a Freedom of Information request from The Doctor requesting the figures the GMC said: ‘We are now working towards publication of data concerning suicide of doctors under investigation or monitoring for 2018 to 2020 later this year.’
That would represent a wait of at least 30 months for the figures from calendar year 2018.
I am going to keep campaigning until this changesViji Suresh
A GMC spokesperson said new safeguards were being put in place including a phone call with the first email contact and that the regulator was seeking legislative reform which it hoped would ‘reduce the impact of investigations on doctors’.
They said: ‘We are deeply saddened by the tragic case of Dr Suresh and the devastation this has brought his family. It’s so important we keep listening, learning and improving our processes, and we have made a number of changes since the inquest.’
The GMC may believe it has taken the necessary action to create a compassionate process but the majority of its changes were made prior to the death of Dr Suresh.
Doctors leaders believe it is time for another look at the systems which cause such fear and distress for frontline staff. At the heart of any reform should be the tragic case of Dr Suresh – and the principle that doctors be treated with the same respect, dignity and compassion they are expected to provide to patients.
Dr Nagpaul says: ‘Knowing this is what the impact of notification of a GMC investigation can have it really is vital that every effort is made to make sure this information is communicated in as humane a manner as possible and also recognising the natural justice that no one is guilty at the onset of an investigation. Investigation is not a notification of guilt.’
For Mrs Suresh, it has already been a three-year battle for action – and has included a gruelling inquest and now another legal process.
Mrs Suresh says she will not stop until she believes the institutions which hold sway over the lives of doctors are more accountable to frontline staff and operate with compassion at their core.
She says: ‘The GMC is an organisation that terrifies doctors. I am going to keep campaigning until this changes.’
Speaking about her husband, Mrs Suresh says: ‘He was a very polite, kind and soft-hearted person. He is a person who everybody would trust to the core and he had a lot of friends and respect from the community, families around us and colleagues.’
If one thing is clear, it is that one more tragedy like this would be one too many.
The BMA is also supporting legal action against North Tees and Hartlepool NHS Foundation Trust.
A letter before action which will be sent to the trust suggests Dr Suresh’s employers owed him a duty of care and breached that by wrongly informing Dr Suresh that he would not be referred to the GMC, failing to update Dr Suresh or their medical director when the police made a referral to the GMC and failing to take steps to protect Dr Suresh’s mental health in light of those developments.
The letter says the trust could have put appropriate measures in place to provide further support to Dr Suresh, including a more interventionist approach where counselling and occupational health could have been arranged.
The letter will say the trust’s failings contributed to Dr Suresh’s decision to take his own life.
BMA council chair Chaand Nagpaul says all employers should be ‘acutely aware of the impact of an investigation by the GMC – and the communication of that investigation – can have on a doctor.’
He says: ‘There should be systems to ensure that the mental wellbeing of a doctor is safeguarded, the right support given, any work adjustment allowed for and that they have colleagues they can speak to and trust and have the ability to share their fears and feelings in a confidential space rather.
'Without this employers risk adding to the isolation that being notified of an investigation can create due to the worry and the shame of that being more widely known. Employers must put in place systems to support the mental health of doctors, any adjustments they need and a safe space to speak confidentially about anything they need.’
A North Tees and Hartlepool NHS Foundation Trust spokesperson commented: ‘We remain saddened by the loss of a highly valued colleague in such distressing circumstances for his family, friends and colleagues within the trust.’
Earlier this year the Department of Health and Social Care announced a public consultation around the regulation of healthcare professionals.
The BMA will support proposals for a three-stage process for the fitness-to-practise reforms, which will provide for an ‘accepted outcomes’ process which may avoid registrants being considered by panels where they accept the facts and action necessary.
However, doctors leaders will call for timelines for each stage of the process to give doctors some certainty and avoid drawn out cases, as well as that health must stay as a grounds for action rather than being subsumed under ‘lack of competence’.
The BMA will also call for significant doctor representation in GMC decision making, which is not currently an assurance in the proposals.
Copyright © 2023 GMC-Watch - All Rights Reserved.