What are the accessibility requirements for private medical practices?

The law

Accessibility is a legal requirement, not only good practice. As a private practice you provide services to the public, so Part 3 of the Equality Act 2010 applies in England, Scotland and Wales. Section 20 sets out three requirements to make reasonable adjustments:

1. Provisions, criteria or practices. Change a policy or way of working that puts disabled people at a substantial disadvantage, such as a strict 10-minute appointment length or a phone-only booking line.
2. Physical features. Remove, alter or provide a reasonable way of avoiding a physical feature that causes a substantial disadvantage, such as steps, heavy doors or poor lighting.
3. Auxiliary aids and services. Provide extra help, such as a hearing loop, a sign language interpreter or information in an accessible format.

Where the adjustment relates to information, reasonable steps include providing it in an accessible format. You cannot require the disabled person to pay any of the cost of complying with the duty.

An anticipatory duty

For service providers, the duty is owed to disabled people generally, not only to a patient who has asked. That means thinking ahead about the barriers patients with different impairments might face and dealing with them before they turn up.

If a physical feature can't reasonably be changed, the Act allows you to adopt a reasonable alternative method of providing the service, such as seeing a patient in an accessible room elsewhere or offering a home visit. You are not required to take steps that would fundamentally alter the nature of your service or profession.

The CQC's GP guidance says that when deciding what is reasonable, you can consider cost, practicality, health and safety, the size of the practice and whether the adjustment will work. Larger organisations are generally expected to invest more.

Premises

An accessibility audit is a good starting point. Walk the patient journey from the car park or bus stop to the consulting room and toilet. Common adjustments include:

• step-free access or a ramp, and a lift or ground-floor room
• doors wide enough for a wheelchair and easy to open
• an accessible toilet
• seating with arms in the waiting area and space for a wheelchair
• good lighting, clear signage and contrasting colours
• a hearing loop at reception
• a height-adjustable examination couch.

It is much easier to choose accessible premises than to adapt them. See choosing a location. New building work must meet the Building Regulations, where Approved Document M sets the baseline for access in England.

Communication and information

• Offer booking by phone, online and email, so patients can use the method that works for them.
• Record each patient's communication needs and act on them.
• Provide information in large print, easy read or other formats on request.
• Book sign language interpreters for Deaf patients. The CQC points out that sign language may be their first language, so do not assume they can read and write English.
• Think about how you call patients from the waiting room if they can't hear or see a name being called.

The NHS Accessible Information Standard applies to organisations providing NHS or publicly funded adult social care. A purely private service is not bound by it, but its steps are a practical way to meet your Equality Act duty.

Your website and online booking are part of your service too. Use clear layouts, alt text, good contrast and forms that work with screen readers. See creating a website.

Appointments and policies

• Offer longer appointments where needed, for example for patients with a learning disability. The CQC expects this in GP practices.
• Allow a carer or supporter to attend.
• Apply cancellation and late-arrival policies flexibly where a disability is the cause.
• Offer video or home visits where attending is difficult.

Staff

A separate duty under Part 5 of the Act requires reasonable adjustments for disabled employees and job applicants. Train your team on the adjustments you offer and how to ask patients about their needs respectfully. See employment law when hiring staff.

What the CQC looks for

In England, regulation 15 requires premises to be suitable and says people should be able to enter, exit and find their way around easily and independently, with reasonable adjustments where they can't. The CQC also expects an equality, diversity and human rights policy with every new registration application. Keep a record of your audit, the adjustments you have made and those you considered but found unreasonable, with your reasons.

Scotland, Wales and Northern Ireland

The Equality Act 2010 applies in England, Scotland and Wales. In Northern Ireland, disability discrimination in services is covered by separate legislation, the Disability Discrimination Act 1995, which also includes a duty to make reasonable adjustments. Building standards differ in each nation.