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Babylon’s CQC report – the facts

The Care Quality Commission are publishing a report on Babylon, based on an inspection in July 2017.

CQC praise for Babylon
  • The regulator states that their report puts Babylon in “the top quartile of most favourable reports carried out by the CQC” and that “services were safe, effective, caring, responsive and well-led” [1].
  • CQC make clear in their report that “18,323 patients (84% of total responses) who had used the service had rated the service they had received with a score of five out of five.”
  • The report also highlights that “The service consistently sought ways to improve”, a key reason for finding the service to be well-led

 

Babylon’s concerns with the report

Despite the praise that CQC give us, we are disappointed that CQC’s inspection report contains many inaccuracies. In the last 6 months, CQC has found fault with a high proportion of the digital providers it has inspected [2]. This is an issue for digital healthcare and innovation in the UK as a whole. As the Chief Inspector for General Practice, Steve Field, readily admits "I put my hands up and say we’re not as consistent as we should be." We are concerned that the regulator has found it so difficult to assess digital healthcare in its most recent round of inspections. 

Because of this, we have had no choice but to challenge the validity of the report in court – to defend our staff, our reputation, and innovation across healthcare. The court has criticised the CQC report.


CQC inaccuracies, and the facts

CQC claim

“Some patients were prescribed medicines for long term conditions, and there was no evidence that the treatment for those patients was reviewed appropriately”

“There was a reliance on verbal information given by patients instead of obtaining evidence”

The facts

Babylon GPs ask patients for medical history pertinent to their situation prior to prescribing.  CQC inspectors are, however, suggesting that more is required- for example that blood tests and access to full medical records should be available prior to a prescription being issued. Medical guidelines do not require this as a matter of course prior to prescribing. To be clear Babylon does not prescribe on a long-term basis, nor does it offer a repeat prescription service.  The responsibility for thorough annual reviews should sit with the patient’s primary care provider who would provide repeat prescriptions.

NHS out of hours services, and private GPs prescribe on exactly the same basis as Babylon for which Babylon is being criticised. Babylon should not be held to different standards to traditional care providers.

CQC point to an example of where a patient with Asthma does not have access to their inhaler and sought help from Babylon to prevent them from becoming unwell.  The fact that any patient can instead go to any pharmacy and buy an inhaler based on a brief discussion with the pharmacist, without a review by a doctor or their full medical record, further proves that the CQC’s argument on this point is unfounded.

CQC claim

 “…Policies were not clear about when a GP should share information about a patient with their registered GP” 

The facts

The above comments demonstrate: (1) a failure by the CQC to understand Babylon’s service and how it operates; and (2) a lack of understanding around the rules governing the sharing of patient records.  GMC guidance requires that patient consent is obtained prior to the sharing of their records (unless consent is implied, which would not be applicable in this context). This principle is re-enforced by data protection legislation.  Therefore, the criticism that some patients did not have records shared with their registered GP is completely unwarranted, and simply reflects situations where a patient had not consented to record sharing.  To share records in such a situation would in fact have been against GMC and data protection rules. 

Furthermore, Babylon asks patients via its mobile app, prior to every appointment, whether they provide consent for their notes to be shared with their registered GP.  The criticism that policies are not clear about when a GP should share information is wrong, and if patient consent is provided records are shared. The fact that CQC failed to identify this crucial step in our user experience is disappointing. By focusing on ‘traditional’ care inspection methodology they missed a crucial step in the digital user experience, leading to inaccurate findings being noted in the inspection report.

 CQC claim

“we found for two patients, no additional information was supplied to inform them that the medicine was being prescribed for use outside of its license, and there were no records of consent that the patient acknowledged and understood that the medicine was being used outside of its license”

The facts

The statement that Babylon had not followed correct procedures for medicines supplied outside of their license shows a lack of understanding of prescribing and practice. There is no requirement to explain or supply additional information to the patient for drugs which are used outside of license in line with common practice.

GMC guidance states that when prescribing an unlicensed medicine you must:

…c) make a clear, accurate and legible record of all medicines prescribed and, where you are not following common practice, your reasons for prescribing an unlicensed medicine.

The prescriptions referred to in the CQC report were for Metformin (a common medication for polycystic ovaries) and Acetazolamide (a common medication for altitude sickness). These drugs are both commonly used outside their licence for the abovementioned medical complaints, which would be supported by GPs. For context, we would also like to note that these instances represent only two out of over 50,000 consultations that Babylon has carried out in the UK.   

 

What does this report mean for the NHS GP at Hand service?

The narrow concerns raised about Babylon in the inspection report do not apply to the GP at hand service, powered by Babylon. The three areas CQC focused on relate to instances where Babylon is not the primary care provider (e.g. record sharing with NHS GP, and long-term monitoring of prescription), whereas GP at hand is the patient’s NHS GP and primary care provider. The inspection took place before the launch of the GP at hand service.


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[1] CQC court judgement

[2] https://www.gponline.com/cqc-r...