Recommendation 12b: Information sharing between providers
From Report of the Independent Inquiry into the Issues raised by Paterson, published 4 February 2020.
Recommendation
If the healthcare professional also works at another provider, any concerns about them should be communicated to that provider.
In brief (written by this site)
The Inquiry recommended sharing concerns about healthcare professionals with any other providers they work for. In commentary of September 2024, published in February 2026, the Department of Health and Social Care and NHS England reported that NHS Resolution guidance requires exclusion decisions to be communicated to other providers, while broader reforms to strengthen information sharing remained under consideration (DHSC and NHS England, Feb 2026). The department stated that the timing of legislative changes to the Medical Profession (Responsible Officers) Regulations 2010 was subject to the priorities of the new government (DHSC and NHS England, Feb 2026). The Thirlwall Inquiry legal team noted in February 2026 that further consideration within that regulatory review was awaited (The Thirlwall Inquiry legal team, Feb 2026).
AI-generated summary of the record on this page, checked by a second model and automatic checks, 12 Oct 2026. The record below is the sources' own words.
About this summary
This recommendation applies across many organisations. The record reflects central policy activity; adoption in individual organisations may vary.
Government response
Accept in principle
The government agrees that, where patient safety is at risk, information should be shared with other providers. However, there must be an element of judgement by providers as they will be taking on responsibility to ensure that this information is appropriate and accurate.
Regulators have taken key steps to make it easier for people and organisations to share information regarding patient safety risks. The Medical Profession (Responsible Officers) Regulations 2010 (revised in 2013), which apply to all medical practitioners, have also set out prescribed connections for sharing information regarding performance concerns between health organisations.
The government accepts this recommendation in principle and agrees that, where a provider has evidence that an individual is shown to be acting in an unsafe way, they should share concerns about that individual’s practice with other providers who they work with.
Delivery
DHSC and NHS England say in progress (27 February 2026)
The previous Government agreed that where a provider has evidence that an individual is shown to be acting in an unsafe way, they should share concerns about that individual’s practice with other providers who they work with, in a way that complies with GDPR obligations.
Regulators have taken important actions to make it easier for people and organisations to share information regarding patient safety risks e.g. GMC is clear in its guidance that patient safety is paramount when deciding whether to share information about doctors and that this should occur in a timely manner.
The Department of Health and Social Care has been working on changes to the Medical Profession (Responsible Officers) Regulations 2010 to ensure they are fit for use in the changing healthcare landscape, which includes considering how best to strengthen information-sharing systems. The work had been split into two tranches, with the aim of making legislative changes in the later part of 2024. However, exact timings are subject to views and priorities of the new Government.
The Government has stated that investigations when concerns are raised about medical professionals should be conducted in an appropriate, timely and thorough way. In doing this, Responsible Officers must ensure that local processes are in place for raising and acting on concerns about doctors, with issues escalated to the GMC as appropriate.
NHSR provides expertise to help foster a fair and compassionate approach, and a learning culture when supporting employing and/or contracting organisations and practitioners when concerns are raised about an individual’s practice. NHSR encourages organisations and practitioners to use this service as early as possible. NHSR has also launched new guidance on making decisions relating to exclusions, (exclusions are designed as a short-term, temporary measure to remove a practitioner from their usual place of work until the nature and cause of a performance concern are understood and while an investigation is carried out).The guidance includes the need to communicate these decisions to other providers who work with the professional in question.
NHSR has a Healthcare Professional Alert Notices (HPANs) system. This is a system where notices are issued by NHSR to inform NHS bodies and others about health professionals who may pose a significant risk of harm to patients, staff or the public. HPANs are usually used whilst the regulator is considering the concerns and provides an additional safeguard during the pre-employment checking process.
NHSR has completed and published evaluation of its resources including:
1. Immediate engagement with resources
2. Short term outcomes for employers focusing on improved knowledge and evidence of applying that knowledge
3. Changes in case management as medium term outcomes and extrapolating any changes to the cost of exclusions
4. Positioning of Practitioner Performance Advice as a system leader in the management of exclusions
The Government is considering how best to strengthen information-sharing systems around professionals as part of the reforms to the Responsible Officer regulations.
Site note: DHSC and NHS England's own account of progress, supplied to the Thirlwall Inquiry in September 2024 and printed in the Inquiry legal team's Review of Implementation of Recommendations from Previous Inquiries into Healthcare Issues (version dated April 2025, published 27 February 2026). It is not a finding of the Inquiry. Their reviewed extent of implementation reads “In progress”. Table row: section 29.2 No. P9 / Action 9.1b, PDF page 747-748.
DHSC states no delivery position (15 May 2024)
Action 9b
The government agrees that where a provider has evidence that an individual is shown to be acting in an unsafe way, they should share concerns about that individual’s practice with other providers who they work with, in a way that complies with GDPR obligations.
Regulators have taken important actions to make it easier for people and organisations to share information regarding patient safety risks e.g. GMC is clear in its guidance that patient safety is paramount when deciding whether to share information about doctors and that this should occur in a timely manner.
DHSC is working on changes to the Medical Profession (Responsible Officers) Regulations 2010 to ensure they are fit for use in the changing healthcare landscape which includes considering how best to strengthen information-sharing systems around professionals as part of these reforms. Reformed regulations are expected to be laid in 2024.
The government has stated that investigations when concerns are raised about medical professionals should be conducted in an appropriate, timely and thorough way. In doing this, Responsible Officers must ensure that local processes are in place for raising and acting on concerns about doctors, with issues escalated to the GMC as appropriate.
NHS Resolution provides expertise to help foster a fair and compassionate approach, and a learning culture when supporting employing and/or contracting organisations and practitioners when concerns are raised about an individual’s practice. NHSR encourages organisations and practitioners to use this service as early as possible. NHSR has also launched new guidance on making decisions relating to exclusions, which includes the need to communicate these decisions to other providers who work with the professional in question.
From: The Thirlwall Inquiry: Review of Implementation of Recommendations from Previous Inquiries into Healthcare Issues (version of 15 May 2024), The Department of Health and Social Care
Site note: DHSC's own comments on progress, supplied to the Thirlwall Inquiry in February 2024 and printed in the Inquiry legal team's Review of Implementation of Recommendations from Previous Inquiries into Healthcare Issues (version of 15 May 2024). They are not a finding of the Inquiry. Table row: section 26.2 No. P9 / Action 9.1a, 9.1b, PDF page 746-749.
Department of Health and Social Care says in progress (15 December 2022)
NHS Resolution has launched new guidance on making decisions relating to exclusions, which specifically includes the need to communicate these decisions to other providers who work with the professional in question.
The government has continued to consider how best to strengthen information-sharing systems around professionals as part of the reforms to the Responsible Officer regulations.
What other bodies have found
In their own words. These do not change the delivery statement above.
Thirlwall Inquiry legal team (27 February 2026)
Action 9.1b:
Accepted in principle by the government: “The government agrees that, where patient safety is at risk, information should be shared with other providers. However, there must be an element of judgement by providers as they will be taking on responsibility to ensure that this information is appropriate and accurate.”
To be considered further by the Department of Health and Social Care in its review of the Medical Profession (Responsible Officers) Regulations 2010 (revised in 2013), awaited.
Site note: The Thirlwall Inquiry legal team's own notes on implementation, from its Review of Implementation of Recommendations from Previous Inquiries into Healthcare Issues (version dated April 2025, published 27 February 2026). The review does not colour its Extent of Implementation cell for this recommendation green; it leaves the cell uncoloured where a recommendation was rejected, where evidence of implementation was insufficient, or where steps had been taken but implementation was not yet complete. Table row: section 29.2 No. P9 / Action 9.1b, PDF page 747-748.
Earlier findings (1)
Thirlwall Inquiry legal team (15 May 2024)
Action 9.1b: Accepted in principle by the government: “The government agrees that, where patient safety is at risk, information should be shared with other providers. However, there must be an element of judgement by providers as they will be taking on responsibility to ensure that this information is appropriate and accurate.”
To be considered further by the Department of Health and Social Care in its review of the Medical Profession (Responsible Officers) Regulations 2010 (revised in 2013), awaited.
Site note: The Thirlwall Inquiry legal team's own notes on implementation, from its Review of Implementation of Recommendations from Previous Inquiries into Healthcare Issues (version of 15 May 2024). The review does not colour its Extent of Implementation cell for this recommendation green; it leaves the cell uncoloured where a recommendation was rejected, where evidence of implementation was insufficient, or where steps had been taken but implementation was not yet complete. Table row: section 26.2 No. P9 / Action 9.1a, 9.1b, PDF page 746-749.
Source
Responsible bodies
Themes and tags
Who has spoken
- Department of Health and Social Care
Response, delivery statement - DHSC and NHS England
Delivery statement - DHSC
Delivery statement - Thirlwall Inquiry legal team
Finding