Printed from: https://www.cmf.org.uk/advocacy/submissions/?id=45
Published: 26th July 2007
This is a copy of the online submission made by CMF on 24 July 2007. (The GMC draft guidance can be read by going to gmc.e-consultation.net
Broad approach and overarching principles
1. Is the guidance relevant to the range of situations that doctors and patients will face when making decisions about investigations and treatment? Yes
2. Are the principles set out in Part 1 the right ones? Yes
3. Does the draft accurately reflect the different roles of the doctor and the patient in the process of making medical decisions? Yes
Sharing information/discussing treatment options
4. Does the guidance clearly express doctors' obligations to provide this information? Yes
Comments: We notice no mention in Para 6 of 'ethical' aspects that might occur - eg blood products with Jehovah's Witnesses; porcine insulin with certain religious groups, or ethical issues associated with a discussion of termination of pregnancy.
5. Is this a reasonable obligation to impose on doctors? Yes
6. Is this a reasonable test for doctors to apply when deciding when they should tell patients about such treatments? Not sure
Comments: Given that some treatments may not be approved by NICE, we are concerned there might be adverse effects on patients (and on all relationships) of informing patients about treatments not available locally on the NHS.
7. Are there any other circumstances when doctors should tell patients about treatments not available in the organisation providing care? Not sure
Comments: Not sure we follow the question. What does a doctor do if the patient raises questions about other treatments, whether or not the doctor believes they may be effective?
8. Does paragraph 10 accurately reflect doctors' obligations to answer patients' questions? Yes
9. Is this guidance helpful? Yes
Comments: Para 12 makes no mention of the presence of family, or others close to the patient, during such discussions. We recognise the importance of confidentiality but our experience is that family involvement is often wanted by patients, and helpful to the communication process.
10. Is it clear that paragraph 14 is intended to cover all of these issues? No
Comments: Our comment above might be involved here as 'additional support'. Would family members or others close to the patient qualify as 'additional support'?
11. Is there anything missing from paragraph 14? Yes
Comments: Not immediately apparent that, eg, interpreting services, are what is intended here. Suggest be specific.
12. Do paragraphs 15 and 16 strike the right balance between the need to respect patients' wishes and the need for doctors to provide certain information? Yes
Obstacles to providing information
13. Is the guidance in paragraphs 19 and 20 clear? Yes
14. Is this guidance helpful in practice? Yes
Discussing side effects, complications and other risks
15. Is the guidance on risk clearly expressed? Yes
16. Does this paragraph make clear when doctors should tell patients about potential risks of proposed investigations and treatments? Yes
17. Is the guidance on how doctors should approach discussions with patients about risks helpful? Yes
Comments: However, we know that patients vary considerably in their ability to understand the significance of statistical risk. Could there possibly be everyday examples quoted here that might help to get this concept across?
18. Is there anything missing from this section? No
Comments: But see Comment re 17
Advance care planning
19. Is it helpful for the GMC to provide guidance for doctors on discussing advance care planning with patients? Yes
20. Is there any other guidance we should give on this issue? Yes
Comments: We think there should be some acknowledgement that patient wishes may change as disease progresses. Perhaps there needs to be some mention here of the need for review and updating, as in paragraph 49?
Patients with fluctuating/diminished capacity
21. Is the terminology we use in this section clear? Yes
22. Does the guidance cover the situations doctors may face when making decisions with patients whose capacity is impaired? Yes
23. Is this guidance helpful? Yes
Reaching decisions when adults lack capacity
24. Does this section clearly set out doctors' professional obligations when making decisions about patients who lack capacity? Yes
25. Is there anything missing from this section of the guidance? No
26. Is the guidance on assessing capacity helpful? Yes
27. Is there anything missing from this section of the guidance? No
28. Is this guidance helpful? Yes
Legal issues
29. Does the guidance accurately reflect the legal and organisational environment in which you work or live? Yes
30. Do you think the Legal Annex is helpful? Yes
31. Is there anything that could usefully be added to the Legal Annex? No
General questions
32. Are the standards set in the draft reasonable and achievable? Yes
33. Are there any paragraphs that you feel are not relevant to the majority of registered doctors? No
34. Have any key principles, duties or issues been omitted from the guidance? Not sure.
Comments: Noting the BMA/RCN/Joint Council consultation on principles about resuscitation, again to coincide with the Mental Capacity Act fully becoming law, we wonder whether there should be any specific mention in this guidance of discussing resuscitation issues with patients?
35. Do you have any comments on the structure of the draft, or on the headings or subheadings? Yes
Comments: Clear, logical, lucid
36. Are there any other sources of guidance, or useful links that you think we should include? Yes
Comments: See 34. Should there be mention of discussing resuscitation issues in advance with patients? Could this guidance link to the imminent BMA/RCN/Joint Council guidance?
37. Do you have any comments on the title of the guidance? Yes
Comments: We positively applaud the shift of language towards a greater degree of recognition of partnership with the patient.
38. Do you have any other comments on the draft guidance? No
Steven Fouch (CMF Head of Communications) 020 7234 9668
Alistair Thompson on 07970 162 225
Christian Medical Fellowship (CMF) was founded in 1949 and is an interdenominational organisation with over 5,000 doctors, 900medical and nursing students and 300 nurses and midwives as members in all branches of medicine, nursing and midwifery. A registered charity, it is linked to over 100 similar bodies in other countries throughout the world.
CMF exists to unite Christian healthcare professionals to pursue the highest ethical standards in Christian and professional life and to increase faith in Christ and acceptance of his ethical teaching.
