What are practising privileges as a private GP?

What practising privileges are

Practising privileges are permission from an independent hospital or clinic for a doctor who is not its employee to treat patients on its premises. The term has a specific meaning in the regulations. In England, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 include “the grant of practising privileges” in their definition of employment.

That matters because the host remains responsible for the care delivered under its roof. You are usually self-employed in the ordinary sense, but for the regulator’s purposes you are treated like a member of staff. The host must be satisfied that you are fit and proper for the role, and your consultations run under its policies.

Practising privileges are sometimes compared to the NHS performers list, but the comparison only goes so far. The performers list lets you work anywhere in NHS primary care in England. Practising privileges are granted by one provider, for one scope of practice, and each provider decides for itself.

Do you need them?

Only if you want to see patients in someone else’s independent hospital or clinic on this basis. They are one of several routes into private work, not a requirement for all of it.

How you work	Practising privileges?
Consulting at a private hospital or clinic that grants them, seeing patients under its governance	Yes
Employed or engaged on sessions by a private GP provider	Usually not. You work under a contract of employment or for services instead.
Running your own registered service	No. You hold the registration yourself.
Renting a room by the session and running your own service in it	No, and the host’s registration does not cover you. You may need your own.

The last row catches people out. Guidance written for independent providers across the UK, published by Healthcare Improvement Scotland, says activity carried out independently of the host’s registration is not covered by practising privileges, and the professional should seek advice on separate registration. If you are unsure which applies, see do I need to be registered with the CQC? and get the host’s answer in writing.

Why GPs use them

• No premises or registration of your own. The host provides rooms, reception, equipment and the regulatory framework.
• Your own patients. Unlike sessional work, you are usually building a personal list under your own name.
• Specialists nearby. Working in a private hospital puts you next to consultants, imaging and pathology. See how to find local private clinicians.

The trade-off is control. You work within the host’s policies, record system, opening hours and fee arrangements, and the host can review, restrict or withdraw your privileges.

What you will be asked for

Each provider sets its own requirements, but most large independent providers in England follow the Independent Healthcare Providers Network’s Medical Practitioners Assurance Framework (MPAF). Its refreshed 2022 version lists a standard dataset for applications. Expect to provide:

• proof of identity with a recent photograph, and right to work if relevant
• a Disclosure and Barring Service (DBS) certificate. See how to get a DBS check
• current GMC registration and licence to practise, and GP or specialist register entry
• your designated body and responsible officer
• evidence of annual whole practice appraisal, including appraisal summaries and personal development plans
• a certificate of indemnity or insurance at an appropriate level for the work
• a CV, references and evidence of conduct in previous posts
• evidence of mandatory training and of your hepatitis B, hepatitis C and HIV status
• ICO registration, where you are a data controller in your own right
• a description of your scope of practice and every location where you work as a doctor
• evidence of taking part in quality improvement activity

The framework also suggests that providers consider requiring at least one UK whole practice appraisal before a doctor can apply. If you are newly qualified or new to the UK, ask about this early.

How to apply

1. Talk to the hospital or clinic first. Ask the hospital director, registered manager or medical director whether it wants a GP service and what scope it will grant. Some hospitals already run a GP clinic. Others will consider a new one.
2. Ask for the practising privileges policy and application form, and read the policy before you apply. It sets out the rules you will work under.
3. Check your indemnity. Confirm with your provider that the specific private work is covered. See indemnity for private work.
4. Submit the application and evidence. In many hospitals a medical advisory committee advises on applications before the registered manager decides.
5. Complete induction. Expect training on the host’s record system, emergency procedures, safeguarding, chaperones and incident reporting.

Have your documents ready before you ask. Missing appraisal evidence and indemnity certificates are the most common reasons for delay.

Once granted

• Stay within your agreed scope. Adding services, such as minor procedures or a new clinic type, usually needs the host’s agreement first.
• Share your whole practice. The MPAF expects your annual appraisal to cover all your work, NHS and private, and providers to share relevant information about you with your responsible officer.
• Expect regular review. The MPAF says practising privileges should be reviewed every two years for all doctors, and more often where extra scrutiny is needed. If the host cannot get the information it needs, privileges may be suspended until it can.
• Follow the host’s policies on consent, records, complaints and declaring conflicts of interest. See conflicts of interest.

Practising privileges and your responsible officer

If you do no NHS work, a hospital where you hold practising privileges can be your designated body for revalidation. The Medical Profession (Responsible Officers) Regulations 2010 list this as one of the ways a doctor is connected to a designated body. Rules decide which connection takes priority if you have more than one. See how to get appraised and revalidated as a private GP.

Fees and money

Arrangements vary. Some hosts charge room rent by the session, some take a share of fees, and some set the patient fee themselves. Get the terms in writing before you start, including who invoices the patient, who chases unpaid bills and what happens to your patients’ records if you leave.

If you also refer patients to the host for tests or treatment, the Competition and Markets Authority’s Private Healthcare Market Investigation Order 2014 prohibits private hospital operators from offering incentives to refer, and prohibits doctors from accepting them. Room discounts linked to the revenue you generate are one example it lists.

Scotland, Wales and Northern Ireland

Practising privileges exist across the UK, under different laws. Wales defines them in the Independent Health Care (Wales) Regulations 2011, regulated by Healthcare Inspectorate Wales. Scotland has Healthcare Improvement Scotland, and Northern Ireland the RQIA under the Independent Health Care Regulations (Northern Ireland) 2005. The MPAF was written for England, but many providers use similar checks everywhere. Ask the host which rules it follows.