New PMCPA Policies June 2025

Introduction

1. The PMCPA has launched two new policies, effective from 1 June 2025:

a. Managing persistent contact and unreasonable behaviour policy
b. Pilot limitation period policy in relation to historical complaints

Background

2. Over the last few years, the PMCPA has continued to receive a high volume of new complaints, coupled with a large number of cases awaiting Panel consideration.

3. The new Code that was published in 2024 set out our overriding objective. The aim being to ensure we can be flexible in our approach to managing cases and ensure we are focusing our resource on the most serious cases which address patient safety and confidence in the industry.

Summary of the policies

Managing persistent contact and unreasonable behaviour policy

4. The Managing persistent contact and unreasonable behaviour policy has been developed as a way to manage contact with individuals who may be persistent in nature or whose behaviour may be unreasonable. Such behaviour can divert resources away from our core role and can hinder the work we do. We also consider that it is unacceptable for our staff to have to tolerate abusive behaviour. This policy sets out the procedure for the team to be able to manage contact in such circumstances in an effective and safe manner, whilst ensuring procedural fairness and in accordance with our overriding objective to protect patient safety.

Pilot limitation period policy in relation to historical complaints

5. The main aim of the new pilot policy is to ensure that PMCPA resources are deployed in accordance with our overriding objective to protect patient safety, and are not spent on historical matters that may have little ongoing importance compared to contemporaneous complaints.

6. In short, this policy empowers the PMCPA case preparation manager to apply the existing Constitution and Procedure, in particular the overriding objective, to decide not to proceed cases where the activity took place, or the material was last in use, more than two years before the complaint was received. For social media complaints, it is a shorter period of six months (i.e. where the social media activity that is the subject of the complaint was dated more than six months before the date the PMCPA receives the complaint).

7. The pilot has the support of the MHRA who will be updated on progress, and includes several built-in safeguards, such as:

a. The case preparation manager has discretion to proceed historical complaints if there are exceptional circumstances for doing so (e.g. patient safety, public interest, industry reputation).
b. A complainant that disagrees with a decision not to progress their complaint (or believes their complaint gives rise to “exceptional circumstances”) has a right of appeal to an independent referee.
c. We will actively monitor all complaints that do not proceed under this policy, so that we can identify any patterns that require us to take action via our scrutiny powers.
d. In exercise of its supervisory role, the Code of Practice Appeal Board will receive details about all complaints that do not proceed under this policy.

The pilot will be reviewed at the end of 2025 to assess the impact and effectiveness.

The policies are available at www.pmcpa.org.uk.

Ends

 

For more information contact Alex Fell afell@pmcpa.org.uk