THE FAMILY HEALTH
SERVICE APPEAL AUTHORITY
Case No: 11939
Sitting at Napier House, 24 High Holburn, London
21st October 2005
Mr Christopher Limb, Chairman
Dr S Sharma, Professional Member
Mrs J Purkis, Member
BETWEEN:
DR A
O OLAYEMI
(GMC
Reg No: 3115228)
Appellant
and
CITYY
AND HACKNEY TEACHING PCT
Respondent
DECISION
Introduction
- Dr Olayemi is a General Medical Practitioner and
applied to join the Respondent’s Performers List. Such was initially considered at a
meeting on 14th June 2005 and refused on the basis that there
was not sufficient information of her qualifications and training. Fuller particulars are given in the
Decision letter of 23rd June 2005. Dr Olayemi subsequently provided to the Respondent her
Certificate of Acquired Rights which was dated 10th March
2005. In what we understand to be
the standard format the issuing Authority, the Joint Committee on Post
Graduate Training for General Practice, certified that the Appellant held
an acquired right to practice in the Social Security system of the United
Kingdom as a General Medical Practitioner but also bore the note that in
order to practice as a principal in the National Health Service of the
United Kingdom she needed to satisfy the National Health Service
(Vocational Training for General Medical Practice) Regulations 1997. Before such certificate was further
considered by the Respondent the Appellant (acting within the time period
for appeal) indicated her intention to appeal against the refusal of her
application. The Respondent further
considered the matter having received the Certificate of Acquired Rights
and notified the Appellant by letter of 26th August 2005 that
they conditionally accepted the Appellant onto their Performers List. The condition was that she work only in
the capacity of a locum in a practice where there is support from other
general practitioners. The
Appellant thereafter confirmed that she wished to appeal the imposition of
the condition although practising subject to such condition whilst the
appeal was processed. Such appeal
was notified by letter of 19th September 2005.
- Acting pursuant to its inherent powers this Panel
ordered on 23rd September 2005 that the appeals notified by
letters of 17th July 2005 and 19th September 2005
should be heard together and also ordered that the Respondent should
confirm whether it intended to rely upon any matter or evidence other than
the lack of certificate or other evidence of successful completion of
vocational training. It was also
ordered that upon receipt of such notification from the Respondent the
Appellant should either serve an appropriate certificate or other written
evidence in relation to vocational training or give an outline of any
other evidence relied upon in relation to the completion of vocational
training or otherwise indicate her response to any additional matters
which had been identified by the Respondent. By letter of 6th
October 2005 the Respondent confirmed that it intended to rely only upon
matters and evidence relating to the lack of a certificate or other
evidence relating to the completion of the vocational training. The Appellant did not comply with the
Order.
- At the hearing of this matter on 21st
October 2005 we received representations from Caroline Gilmartin, an
employee of the Respondent, but the Appellant did not attend. At a time
when the hearing had already commenced, it is now understood that the
Appellant telephoned the offices of the FHSAA. She indicated that she had sent a letter on Monday (four
days before hearing) indicating that she had the relevant certificate and
was withdrawing her appeal. She
was informed that the FHSAA had not received any such letter and was asked
if she could send a copy immediately and that such would be forwarded to
us. Dr Olayemi in fact faxed a
letter dated 21st October 2005 which referred to having sent
written notification indicating that she did not wish the appeal to
proceed but also indicating that she understood that the Respondent was
willing to admit her to the Performers List. We received such letter after the hearing had been completed
and we had announced our decision.
- Apart from the documents within the paginated
bundle of papers available both to the Panel and to the parties we heard
submissions from Caroline Gilmartin.
The essence of such submissions was that the Respondent had made
numerous efforts to communicate with the Appellant and had informed her
that as and when they saw a certificate confirming completion of
vocational training or other evidence of such training her application
would be reconsidered and was likely to be accepted for inclusion upon the
Performers List without condition. Although Dr Olayemi had orally informed
the Respondent that she now had such certificate, the Respondent had not
been sent such certificate or otherwise seen it or a copy of it.
- We were satisfied that Dr Olayemi was aware of the
written evidence before the Tribunal and fully aware of her entitlement to
attend and address the Panel and if she so wished to give any further
evidence to the Panel.
The law
- The Family Health Services Appeal Authority
(Procedure) Rules 2001 make provision for the conduct of appeals such as
the present. In particular it may
be noted that pursuant to Regulations 32 and 36 an appeal may be dismissed
in whole or in part if directions are not complied with but only if the
person who does not comply with such direction has been given an
opportunity to show cause why the appeal should not be dismissed. We have not acted pursuant to such
powers. It may also be noted that
pursuant to Regulation 40 if a party fails to attend or be represented at
a hearing of which he/she has been duly notified, the Panel may, unless
satisfied there is a reasonable excuse for such absence, hear and
determine the appeal in that party’s absence. Being satisfied by reason of the correspondence within the
bundle that the Appellant was aware of the hearing and had given no reason
for her non-attendance, we proceeded to hear the appeal in her absence.
- Regulation 4 of the NHS (Performers List) Regulations
2004 makes provision as to the information and evidence required upon an
application for inclusion in the Performers List. Such includes details of professional
experience. Paragraph 6 indicates
that an application may be refused (inter alia) on the grounds of the
applicant being unsuitable to be included. Further provisions are contained in Regulations 23 and
24. Regulation 23 requires (inter
alia) provision by the Applicant of details of medical qualification and
professional experience. Regulation
24 provides that an application may be refused if having checked
information provided pursuant to Regulation 23 the applicant is considered
unsuitable.
- We considered as a matter of law that it was not
only within the legal rights of the Respondent to consider evidence in
relation to vocational training but entirely reasonable and responsible
that they should consider evidence in relation to such matters and that it
was a fully reasonable approach in principle to consider that in the
absence of any evidence of vocational training by an applicant who is not
otherwise able to demonstrate appropriate experience and training, the
Trust acted reasonably in refusing the application.
The evidence
- The written evidence available to us demonstrated
that the applicant initially failed to produce a Certificate of Acquired
Rights and subsequently did not produce any written evidence of vocational
training. There is nothing within
any material available to us to cause doubt as to such matters. The factual basis before the Panel was
therefore that there was proper evidence of a Certificate of Acquired
Rights but no evidence of vocational training having been undertaken.
- The Appellant has not provided any evidence to the
Panel of her vocational training.
We are satisfied from the written evidence and from the submissions
of the Trust’s representative at the hearing that representatives of the
Trust have not seen any formal certificate or evidence of vocational
training even though being given oral indication that there has been
such.
- Upon the evidence available to us we are satisfied
on the balance of probabilities that the Appellant has provided neither to
the Respondent nor to this Panel any satisfactory evidence of vocational
training. We are satisfied that
the Respondent is properly concerned to have evidence of vocational
training prior to inclusion of an applicant upon the Performer’s List.
- In the foregoing circumstances we dismiss the
appeal.
- We wish to add (as briefly indicated orally at the
end of the hearing) that we would not wish our present finding to unduly
influence or harm any subsequent application by Dr Olayemi as and when
proper evidence of vocational training is provided. We also wish to add
that we are very concerned that the Appellant, Dr Olayemi, appears not to
have expended any great effort in clarifying her vocational training. We find it unlikely that with
reasonable effort she would not be able to secure formal evidence or
certification of training if she has undertaken such. Her conduct of her appeal and her
failure to respond to the previous direction of this Panel tend to
indicate a rather over-relaxed attitude to what we consider to be
important matters. A substantial
amount of time and expenditure both on the part of the Respondent and of
this Panel have resulted.
- The parties are reminded that they have rights of
appeal pursuant to Section 11 of the Tribunals and Enquiries Act 1992.
CHRISTOPHER LIMB
Chairman – November 2005