The MYRO Briefing
Independent Healthcare Intelligence
Practising privileges, and the governance nobody was holding
Healthcare Improvement Scotland inspected Ardcroft Medical Clinic in Bothwell on 25 June 2026 and published its report on 7 September. The clinic was graded unsatisfactory in all three key areas — direction, implementation and delivery, and results. Eleven requirements were made. Every one of them carries an immediate timescale.
The findings are worth reading closely, because they are not about clinical practice. They are about who was holding governance over the clinicians working there. The clinic offered practising privileges to doctors and registered nurses, and had no clinical governance policy and no practising privileges policy at all. HIS required it to develop one covering governance arrangements, scope of practice, eligibility and the ending of contracts. It found that a registered nurse who had cancelled her own registration with HIS was nonetheless permitted to deliver the same service from the clinic, with no governance arrangement in place — inspectors required that any registered healthcare professional working there must either hold a practising privileges agreement, be employed, or hold their own registration. It found the service operating outside the terms of its certificate of registration. It found that the service manager did not have access to all patient records, and required that she must, at all times, for inspection, for emergencies and for audit.
Safe recruitment was required to extend to practising privileges staff, with ongoing checks and signed agreements. Performance reviews and appraisals were required. The medicines management policy was required to reflect what the clinic actually did, including both in-person and remote prescribing, and HIS recommended systems to support prescribers to follow the GMC's high-level principles and good practice guidance for remote prescribing. On weight-management prescribing specifically, records were required to document verification of the patient's stated weight and body mass index, the treatment plan and goals, consent to share with the GP, follow-up and monitoring, and the dietary, physical and lifestyle advice given.
The report is not a catalogue of a bad clinic. HIS found the environment clean and well maintained, a defibrillator and oxygen on site with documented equipment checks, safeguarding policy and training in place, face-to-face consultation with a cooling-off period and signed electronic consent, no complaints since registration, a risk register, and patient feedback that had produced real change. All three requirements from the December 2023 inspection had been met. What was missing was the layer above: the documented arrangements that say who is answerable for the clinicians who are not employees.
Who governs the doctor you did not employ?
Practising privileges are how a great deal of independent healthcare is actually staffed. A clinic registers with its regulator, and the clinicians who work there are not on its payroll. They arrive with their own registration, their own indemnity, often a substantive post elsewhere, and they treat the clinic's patients. The arrangement is efficient and entirely legitimate. It also quietly detaches the doctor from the employment relationship that, in most other settings, carries governance.
What the regulator expects the host to hold
Two Healthcare Improvement Scotland reports published within four days of each other set the matter out with unusual clarity, because they show the same model done badly and done properly.
At Ardcroft Medical Clinic, inspected on 25 June and reported on 7 September, HIS found no clinical governance policy and no practising privileges policy, and required both. It required safe recruitment to cover privileged clinicians as well as employees, with ongoing checks and signed agreements. It required appraisal and performance review. It recommended a structured audit programme reaching the records of privileged clinicians, not merely the clinic's own, and structured staff meetings that included them.
At GP Matters in Glasgow, inspected on 14 July and reported on 11 September, the clinical team was made up of GPs and nurses all working under practising privileges agreements — and inspectors recorded that every one of them had a contract in place, with Protecting Vulnerable Groups checks, references, and verification of qualifications and identity. That service received three requirements and was graded satisfactory throughout.
The difference between the two reports is not clinical skill. It is paperwork that establishes who is answerable for whom.
The question that follows for a responsible officer
An appraisal is only as good as the information brought to it. For a doctor working under practising privileges, the information is scattered by design. Complaints made about that doctor's treatment sit with the host clinic. Significant events occurring in the clinic's theatre sit with the clinic. Audit data, prescribing data and patient feedback sit with the clinic. The prescribed connection, and therefore the appraisal, may sit somewhere else entirely — with another organisation, in another part of the country.
If nobody has agreed in advance who collates that material and passes it on, the appraisal proceeds on an incomplete record. The doctor is not concealing anything. The system simply never asked the host clinic for its half of the picture.
This is the gap worth closing, and it closes cheaply. The practising privileges agreement is the natural place to do it: a clause obliging the host to notify the doctor's responsible officer of complaints, significant events and any restriction on privileges, and to supply the doctor with the supporting information the appraisal requires. Most agreements deal carefully with indemnity and termination and say nothing about either.
Prescribing is where the gap shows first
HIS's requirements at Ardcroft on remote and weight-management prescribing are a warning about scope. A clinician granted privileges to do one thing may end up doing another, and the host's registration may not cover it. The requirement that the service operate only within its certificate of registration, and apply to vary it before doing anything else, is a reminder that scope of practice is not only the doctor's question — it is the service's.
Weight-management prescribing is the current pressure point, and the documentation HIS required is a fair statement of the minimum any responsible officer should expect to see evidenced: the weight and BMI verified rather than accepted, a treatment plan with goals, consent to share with the GP, arrangements for follow-up and monitoring, and a record of the lifestyle advice given.
What a host service should be able to produce
On the day a regulator asks, a service using practising privileges should be able to put its hand on six things: a clinical governance policy; a practising privileges policy covering governance, scope, eligibility and termination; a signed agreement for every privileged clinician; recruitment and ongoing-check records for each of them, to the same standard as for employees; evidence of appraisal and performance review; and an audit programme that reaches their records.
None of that is onerous. Its absence is what took a clinic with a clean environment, a working risk register and no complaints since registration to unsatisfactory in every key area.
Appraisal & Revalidation
Practical Tips & Guidance
Before they join your roll: the pre-engagement checks that catch what a CV will not
Two of this month's cases turn on the same weakness, from opposite directions. A tribunal erased a doctor who misrepresented his qualifications, grade, job title and referees across a series of applications and twice denied an ongoing fitness-to-practise investigation. A regulator found a clinic that had carried out no recruitment checks at all on the clinicians working under its practising privileges. In both, the failure was at the point of engagement.
Check the register yourself. Not the doctor's screenshot, not a certificate, not a recruiter's assurance. Go to the GMC register, confirm registration and licence, and confirm the absence of conditions or undertakings. Conditions are published. They are the single most useful thing on the register and the thing least often looked at.
Ask the declaration question in writing, and know what a "no" is worth. Ask directly whether the doctor is subject to, or has been subject to, any investigation by a regulator, employer or police force, in the UK or overseas. A negative answer is not verification; it is a statement you can test against the register and against references.
Take references up yourself, from the organisation. Write to the employer through its own published contact details, not to an address supplied by the candidate. Confirm the referee actually held the role described, and that they agreed to act.
Verify the specifics, not the shape. Qualification, awarding body and year. Grade and job title. Start and end dates. These are the details that are invented, because they are the details nobody checks.
Run PVG or DBS at the right level for the work, and record that you have.
Match scope of practice to what the service actually offers. A doctor competent in one procedure is not thereby competent in the one next door, and the service's own registration may not cover it either.
Check indemnity against that scope, not merely that a certificate exists. Cover for NHS practice does not travel into independent cosmetic work.
Then do it again. Registration status, conditions and indemnity all change. A check performed once, at engagement, tells you about a doctor who no longer exists. Re-check at a defined interval and record the date.
Commercial sunbeds — consultation closed, outcome awaited
The Department of Health and Social Care's consultation on strengthening the regulation of commercial sunbeds in England closed on 14 August 2026, having run since 22 May. The department's page states that it is analysing the feedback; no outcome had been published as at the date of this issue. Services offering UV tanning alongside aesthetic treatment should watch for the response.
Read the consultation page →
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GMC Watch
Regulatory Updates
High Court quashes a finding of no impairment — and sets out what a tribunal's reasons must do
In General Medical Council v Dr Ali Shokouh-Amiri [2026] EWHC 2226 (Admin), handed down on 28 August 2026, Mr Justice Morris allowed the GMC's appeal under section 40A of the Medical Act 1983 against a Medical Practitioners Tribunal determination of 14 February 2025. The tribunal had found misconduct in some respects but concluded that the doctor's fitness to practise was not impaired, and made no direction.
The case concerned twenty-two allegations across six patients, made while the doctor was a consultant obstetrician and gynaecologist in Guernsey. They included the removal of one patient's ovaries without consent, and of another's without consent and without any clinical indication — both admitted — together with allegations of sexually motivated or inappropriate behaviour, failures to have a chaperone present for intimate examinations, and dishonesty. The appeal succeeded on two of four grounds. The judge's provisional view, on which he will hear the parties further, is that the tribunal's decision not to make a direction and its finding of no impairment are to be quashed, and the case remitted to the MPTS for a differently constituted tribunal to re-decide the specified allegations of fact and the question of impairment.
Two passages carry beyond this case. On reasons, the judge held that "if a tribunal finds that something happened (or did not happen) and its reasons for so finding make no sense or are factually wrong then the Court on appeal is entitled to say that the finding of fact is wrong", and that reasons "must be proper, adequate, and intelligible and must deal with the substantial points that have been raised". On impairment, he accepted that "even if a doctor is fit to practise, both in relation to his competencies and his attitude and remediation conduct, nevertheless that doctor may still be not fit to practice and/or that doctor's fitness to practice may still be impaired on the basis that the public will not have confidence in that doctor because of his past misdeeds."
That last point deserves attention from anyone who has taken comfort from a finding of no impairment. Insight and remediation address the risk of future harm. They do not, on their own, answer the wider public interest — and a tribunal that addresses only the first has not finished the question.
The remitted allegations remain undecided, and nothing in this note should be read as a finding against the doctor on any of them.
Read the judgment →GMC Chief Executive on the limits of fitness to practise data
Writing on 5 August 2026, GMC Chief Executive Charlie Massey argued that raw fitness-to-practise statistics need context to be understood. Complaints from members of the public rose in 2025 for reasons that are not yet clearly understood; the GMC's stated aim is to open formal investigations only where a concern raises serious questions about a doctor's practice. He also restated the government's commitment to legislative reform of the GMC's fitness-to-practise powers.
Read the GMC blog post →Regulatory reform — still no government response
The Department of Health and Social Care's consultation on reforming the GMC's legislative framework, which would bring the draft GMC Order 2026 forward, remains closed with no government response published as at the date of this issue.
DHSC consultation portal →
MPTS Cases
Fitness to Practise Outcomes
Dr Stephen Igwe — erased for what was on the application form
Outcome: ERASURE
Dr Igwe was a junior clinical fellow in neonatology, working in a neonatal intensive care unit on a six-month contract. Following a hearing between 10 and 19 August 2026 he was erased, with an immediate order — not for anything he did to a patient, but for a sustained course of dishonesty in applying for his next job.
Applying to an NHS foundation trust in July 2024, he claimed a medical degree awarded "with distinction in Medicine", a job title he did not hold, a start date a year earlier than the truth, a grade above his own and a specialty he did not work in. He named as a referee a doctor he described as his employer and line manager, who had not agreed to act. He repeated the false qualification claim by telephone a fortnight later. On two further applications, in November 2024 and January 2025, he answered "No" to the question asking whether he was the subject of a fitness-to-practise investigation. He had been under GMC investigation since 3 September 2024 and subject to an interim order of conditions since 10 October 2024, and he gave a misleading account of those conditions on a declaration form in January 2025. When first challenged, he attributed the errors to a "virtual assistant", before abandoning that account.
All of it was admitted, and all of it was found dishonest. A separate GMC performance assessment in February 2025 found his clinical management unacceptable and identified causes for concern in his assessment of patients' condition and in his relationships with patients — so the tribunal was dealing with misconduct and deficient professional performance together.
Every single misrepresentation in this case was capable of being caught by an ordinary pre-engagement check. The qualification, the grade, the dates, the referee — and above all the registration status and the interim conditions, which were on the public register throughout, available to anyone who looked. Two employers did not look. The practical lesson is in this month's Tips & Guidance above.
Read the MPTS decision →Dr Gregory Manson ERASURE
A general practitioner at a Canterbury surgery was convicted at Canterbury Crown Court on 3 July 2025, after trial, of sixteen counts of indecent assault and sexual assault against nine complainants, committed between November 1999 and September 2017, and was sentenced the following day to seven years' imprisonment with indefinite notification requirements. The tribunal directed erasure on 5 August 2026. The sentencing judge, whose remarks the tribunal adopted, found that his method "was to camouflage" the abuse within medical examinations. The doctor did not attend and was not represented. The offending spanned eighteen years within an ordinary general practice; it was the concealment inside a legitimate clinical act that allowed it to continue.
Read the MPTS decision →Dr Mohammed Elmajee SUSPENSION 12 MONTHS
A senior trauma and orthopaedic registrar was suspended for twelve months, with a review hearing directed and an immediate order imposed, over his conduct towards a colleague he worked alongside in theatres, clinics and on wards. The matters arose from incidents in December 2022 and September 2023 and a message sent in September 2023, and were framed as sexual harassment under section 26(2) of the Equality Act 2010, as sexually motivated, and as an abuse of his more senior position. Conduct towards colleagues, not patients, now attracts sanction of the same order as clinical misconduct — a point for any organisation whose bullying and harassment policy sits apart from its clinical governance.
Read the MPTS decision →Industry Intelligence
Independent Healthcare Sector
Thirteen requirements at a Glasgow clinic offering sedation
Healthcare Improvement Scotland's inspection of The Ever Clinic in Glasgow, published on 28 August, produced 13 requirements and 9 recommendations — the heaviest count in this Briefing's coverage of Scottish independent clinics. The clinic provides non-surgical and minor surgical treatment including botulinum toxin, laser and procedures under moderate sedation. Inspectors found that a notifiable incident of vascular occlusion had not been reported to the regulator; that sedation was carried out with a second staff member who had no evidence of sedation training; and that the clinic held a pulse oximeter, a first aid kit and eye wash but no oxygen, suction, airway equipment or defibrillator, despite its own sedation procedure requiring them. Reusable instruments were autoclaved outside any dedicated decontamination area. Laser local rules were out of date, held digitally only and unavailable in the laser room. The requirement on staff appraisal repeats one made at the February 2022 inspection.
The clinic's governance lead was a GMC-registered doctor who reviewed the sedation and controlled drug protocols annually, and the clinic's audits recorded compliance that inspectors could not find. The protocols existed. The assurance that they were being followed did not.
Read the inspection report →
Half the public thinks aesthetic practitioners are regulated
Research published by the Professional Standards Authority on 11 August found that 46% of UK adults believe practitioners offering non-surgical cosmetic treatments such as botulinum toxin and dermal fillers are legally regulated, and that only 16.5% had consulted a verified source such as a government-backed register before booking. Among 18 to 24-year-olds the misconception rises to 53%. More than a third of those seeking cosmetic treatment said they were influenced by five-star reviews, and 29% by before-and-after photographs or testimonials on social media. The survey of 1,000 adults was conducted by Censuswide between 30 June and 7 July 2026. PSA Chair Caroline Corby described "a clear health risk blind spot".
For a clinic, the practical consequence is that patients arrive with an assumption about regulatory status that nobody has given them. Making the position plain on the website and in advertising is now a governance matter, not a marketing one.
Read the PSA research →
Self-pay reaches a record as insured admissions fall
Data published by the Private Healthcare Information Network on 8 September show private hospital admissions in the UK at 247,495 in the first quarter of 2026, barely changed on the year — but with the funding mix moving decisively. Self-pay admissions rose 7.7% to their highest recorded level, while insurance-funded admissions fell 2.6%, the first first-quarter decline in insured admissions in five years. The split now stands at 69% insurance to 31% self-pay. Active private consultants reached 11,600, more than in any quarter in five years. Cataract admissions reached 22,805, up 12.8%. Wales was the only UK nation to record a rise in insured admissions.
Read the market update →
Two more Scottish inspections, and the difference a contract makes
Two further Healthcare Improvement Scotland reports published this month set the standard against which the month's enforcement should be read. GP Matters in Glasgow, reported on 11 September, received three requirements and was graded satisfactory throughout; inspectors recorded that every clinician working under practising privileges had a contract in place, with Protecting Vulnerable Groups checks, references and verification of qualifications and identity. Its requirements concerned the re-prescribing of long-standing controlled drugs without obtaining a full history from, or notifying, the patient's NHS GP — which HIS states is not in line with GMC prescribing guidance. Forth Aesthetics, a mobile home-visiting service in Dalgety Bay reported on 7 September, received no requirements at all at its first inspection, with four recommendations on aims, performance measurement, feedback and quality improvement.
Read the GP Matters report →
Healthcare at events: registration opens
The Care Quality Commission published guidance on 27 August for providers delivering health care or treatment at events, following changes to the law. Where a service meets the criteria for the regulated activity of treatment of disease, disorder or injury, the provider must register. Applications opened on 7 September 2026, with the first stage running to 1 March 2027 for providers to register or to update an existing statement of purpose. CQC's monitoring, assessment and enforcement powers under the new requirements begin on 6 December 2027. The guidance is framed around healthcare delivered at events generally; operators who deliver treatment at events should check the scope guidance against what they actually do.
Read the CQC guidance →Subscribe to The MYRO Briefing
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