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LMC warns against GPs using practice address to register homeless patients

by Elisabeth Mahase
8 August 2018

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Local GP leaders have advised their practices not to register homeless patients using their surgery’s address, contrary to NHS England advice.
Worcestershire LMC told practices that there are ‘significant reasons’ not to register a homeless patient under the practice address, including taking on the liability of passing on important secondary care letters.
This comes after NHS England previously said practices must register patients who have no evidence of a permanent address within the practice’s boundaries and can use their surgery’s address to do so, but have since added that GPs should sign over responsibility for maintaining contact to the patient if they are concerned.
Worcestershire LMC wrote in its newsletter that ‘LMC advice is that a practice is not to use their surgery address’, instead advising GPs to consider registering them at ‘the address of the local Salvation Army’, the CCG headquarters or ‘a post office box’.
The newsletter said: ‘It is possible to register them [homeless patients] at your practice address but there are significant reasons why you should not do this…
‘If a communication comes to your address on behalf of that patient it is your responsibility to locate the patient and pass on that information. Is your staff willing to take on such a role?’
Helen Garfield, practice manager at Northumberland House Surgery, in Kidderminster, Worcestershire said that her practice is already following the LMC’s advice.
She added: ‘We don’t use the practice address as it leads to potential issues down the line if this is used as a correspondence address for homeless patients. We may [for example] find we need to get information to them and are unable to.
‘We instead [ask that] they provide us with some contact address – the onus is on them to [do that]’. 
However, NHS England told our sister publication Pulse, where this story was first published, that if GPs have concerns regarding liability, they could have a signed agreement with the patient that sets out that it is the patient’s responsibility to maintain regular contact with the surgery in order to recieve any secondary care correspondence.
It added that under NHS England guidance, the practice can use its address where necessary to register homeless patients and, if possible, they should try to ensure that they have a way of contacting the patient if they need to.
When asked about whether practices who already have patients registered with the surgery address, without a signed agreement, could be held accountable if they cannot reach person, NHS England said it could not speculate as each case would be considered individually.
The BMA and CQC also offer advice on homeless patients, but neither have an official stance on what practices should do.
A BMA spokesperson told Pulse: ‘Practices aren’t obliged to use their practice address to register homeless patients; they are expected to register all people who live in their area but don’t have to ask for evidence of an address…
‘Our guidance on patient registration says homeless patients are entitled to register with a GP using a temporary address which could be a friend’s address or a day centre for example.’
Similarly, a CQC spokesperson added: ‘Our role is to see that the relevant guidance is being followed rather than define it, but surgeries themselves may choose to use the practice address.’
In 2016, people without a fixed address – such as those who are homeless, those who live in hostels and those who ‘surf’ sofas – in London were issued ‘my right to access healthcare’ cards, with the aim of making it easier for them to register at local GP practices.
This story was first published on our sister publication Pulse. 
Worcestershire LMC and NHS England were approached by Management in Practice for additional comments. 
Additional reporting by Valeria Fiore.