GMC
If you’re on the GMC Register and a doctor you will be held to the standard appropriate to that status- but what does that mean?
Within the GMC guidance “Good Practice in Prescribing and Managing Medicines and Devices” it is made clear that the responsibilities are wide and are described as “recommending or prescribing other medicines, devices, dressings and activities, such as exercise.”
In the context of functional medicine, the broad range of activity that might be labelled “wellness” or “longevity enhancement” fall within the guidance and you will be judged according to the requirements set out there.
It may not have been your first thought that diet and exercise advice will be viewed through the lens of “… prescribing and managing medicines…” if the GMC have need to investigate your practice from this perspective. To say nothing of off licence prescribing…
CQC
The Care Quality Commission (CQC) is a broad church, with an exemption for those engaged in functional medicine, right?
Well, here is what the exemption says:
“the practice of alternative and complementary medicine, with the exception of the practice of osteopathy or chiropractic,” (from Schedule (1), exception 3(e) The Health & Social Care Act 2008 (Regulated Activities) Regulations 2014).
Equally, regulated activity includes treatment.
There is one further twist in that the CQC exempts diagnostic and screening procedures. Schedule 1, paragraph 3 c of the 2014 Regulations.
So, where does the boundary lie between exempt activities and treatment (which is subject to the Regulations)?
We think regulated activity starts where you make use of investigations and you prescribe/ advise a patient about their approach to health generally and/or a specific complaint in particular.
Insurance
This is typically the last aspect that practitioners consider. Equally often it is last minute thing via an internet search or call to a colleague for a recommendation of where to go.
Whilst it seems obvious, not all policies are the same and there must be explicit cover for prescribing in view of the GMC guidelines.
As a doctor you may feel that you are under undue scrutiny, and perhaps you are. Nevertheless, the GMC guidance is clear.