Privacy Policy

Clinical Governance / CG005

Patient Access Policy

This policy sets out the principles, responsibilities and processes governing patient access to Direct Medicare’s commissioned diagnostic ultrasound services.

Document No.
CG005
Version
1.0
Status
Draft
Policy Owner
Clinical Governance Lead
Approved By
Clinical Governance Committee
Ratified By
Managing Director
Effective Date
Following Approval
Review Date
3 years from approval

1. Introduction

Direct Medicare Ltd (DMC) is committed to providing high-quality, patient-centred diagnostic ultrasound services that are safe, accessible, equitable and responsive to the needs of the communities it serves.

This Patient Access Policy establishes the principles, responsibilities and operational processes governing access to ultrasound services commissioned by NHS Integrated Care Boards (ICBs), General Practitioners (GPs) and other authorised referrers. The policy ensures that all eligible patients have fair and timely access to care irrespective of age, disability, sex, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion or belief, sexual orientation, socio-economic status or any other protected characteristic.

DMC recognises that equitable access is a fundamental component of high-quality healthcare and is committed to delivering services in accordance with the NHS Constitution for England, the Equality Act 2010, the Health and Social Care Act 2008, the Accessible Information Standard and the Fundamental Standards of the Care Quality Commission (CQC).

The organisation will work collaboratively with commissioners, referring clinicians and patients to ensure that access arrangements remain transparent, clinically appropriate and responsive to local population needs.

2. Purpose

The purpose of this policy is to:

  • Establish a consistent and transparent framework for patient access to commissioned ultrasound services.
  • Ensure that referrals are managed fairly, consistently and in accordance with agreed service specifications.
  • Promote equality of access for all eligible patients.
  • Support timely assessment and diagnostic imaging.
  • Minimise avoidable delays in patient care.
  • Ensure compliance with contractual, regulatory and statutory obligations.
  • Define the responsibilities of staff involved in referral management and appointment scheduling.
  • Assure commissioners that DMC operates an equitable and auditable patient access process.

3. Scope

This policy applies to all NHS commissioned diagnostic ultrasound services delivered by Direct Medicare Ltd under Any Qualified Provider (AQP) arrangements and any other commissioned diagnostic contracts where this policy has been adopted. It applies to:

  • General Practitioners and authorised referrers using commissioned pathways.
  • Administrative staff responsible for referral processing and appointment booking.
  • Sonographers and reporting clinicians.
  • Clinical Governance Lead.
  • Operations and Service Managers.
  • Consultant Radiologists providing clinical oversight.
  • Agency and temporary staff working within DMC services.
  • Students and trainees under appropriate supervision.

The policy applies from the point a referral is received until the diagnostic episode has been completed and the report issued to the referring clinician.

4. Policy Statement

Direct Medicare Ltd is committed to ensuring that access to its commissioned ultrasound services is based on clinical need, fairness and transparency. Patients shall be offered access to services without unlawful discrimination and in accordance with the commissioning arrangements agreed with the relevant NHS Integrated Care Board.

Referral management, appointment allocation and service delivery shall be undertaken using consistent and auditable processes designed to support timely diagnosis while making best use of available clinical capacity.

The organisation will make reasonable adjustments to enable equitable access for patients who require additional support because of disability, communication needs or other individual circumstances. All staff are expected to uphold the principles of dignity, respect, compassion and professionalism throughout the patient pathway.

5. Principles of Patient Access

DMC is committed to the following principles:

Equity

All eligible patients will have fair access to commissioned services irrespective of personal characteristics or circumstances.

Clinical Need

Access to services will be determined by agreed referral criteria and clinical need rather than non-clinical factors.

Timeliness

Patients will be offered appointments within the timescales specified by the relevant commissioning agreement wherever reasonably practicable.

Transparency

Referral acceptance criteria, appointment processes and patient information shall be clear, consistent and openly communicated.

Accessibility

Reasonable adjustments will be made to remove barriers to access and to support patients with disabilities, communication needs or other vulnerabilities.

Patient-Centred Care

Patients will be treated with dignity, courtesy and respect throughout their interaction with the service.

Continuous Improvement

Patient access arrangements shall be monitored, audited and reviewed to identify opportunities for service improvement and to ensure compliance with contractual and regulatory requirements.

6. Referral Acceptance Criteria

6.1 General Principles

Direct Medicare Ltd (DMC) shall accept referrals only for services that fall within the scope of the relevant NHS commissioning agreement or service specification. Referrals shall be managed in a fair, transparent and clinically appropriate manner to ensure equitable access to diagnostic ultrasound services. Decisions regarding acceptance or rejection of referrals shall be based solely on clinical appropriateness, service eligibility and contractual requirements, and shall not be influenced by non-clinical factors.

The referral management process shall ensure that all patients receive timely access to the most appropriate diagnostic pathway while maintaining patient safety and making effective use of available clinical capacity.

6.2 Accepted Referrers

Referrals will only be accepted from healthcare professionals authorised under the relevant commissioning arrangements, including but not limited to:

  • General Practitioners (GPs).
  • General Practice clinicians working within Primary Care Networks.
  • Advanced Clinical Practitioners.
  • NHS Community Services.
  • Consultant-led NHS services where agreed within the service specification.
  • Other healthcare professionals authorised by the Commissioner.

Private referrals shall be managed under separate operational arrangements and are outside the scope of this policy unless specifically commissioned under the same service model.

6.3 Referral Eligibility

To be accepted, referrals should:

  • Relate to an ultrasound examination commissioned within the agreed service specification.
  • Include sufficient clinical information to justify the requested investigation.
  • Clearly identify the anatomical area or clinical indication.
  • Contain the patient’s demographic details and NHS number where applicable.
  • Identify the referring clinician and practice.
  • Indicate the urgency of the referral where appropriate.
  • Include any relevant clinical history necessary to support safe imaging.

Incomplete or unclear referrals may be returned to the referrer for clarification where essential information is missing.

6.4 Exclusion Criteria

Referrals shall not normally be accepted where:

  • The requested examination falls outside the commissioned scope of service.
  • Another imaging modality is more clinically appropriate.
  • Insufficient clinical information has been provided to support safe assessment.
  • The patient requires emergency assessment through an acute hospital pathway.
  • The examination requested is not supported by agreed referral criteria.
  • Acceptance would be inconsistent with local commissioning arrangements.

Where a referral is declined, the referring clinician shall be informed promptly with a clear explanation and, where appropriate, advice regarding alternative referral pathways.

7. Referral Management

7.1 Receipt of Referrals

All referrals shall be received through approved referral routes agreed with the Commissioner. Upon receipt, each referral shall be recorded within the organisation’s patient administration system and assigned a unique identifier to ensure full traceability throughout the patient pathway. The date and time of receipt shall be recorded to support waiting time monitoring and service performance reporting.

7.2 Administrative Validation

Before clinical processing, referrals shall undergo administrative validation to confirm:

  • Patient identifiers are complete and accurate.
  • Referrer details are present.
  • The requested investigation is clearly specified.
  • Contact details are available.
  • The referral falls within commissioned services.
  • Any required supporting documentation has been received.

Where deficiencies are identified, administrative staff shall seek clarification from the referring organisation before progressing the referral.

7.3 Clinical Review and Triage

Where required by the service specification or clinical complexity, referrals shall undergo review by an appropriately qualified healthcare professional. Clinical triage aims to ensure that:

  • The requested examination is clinically appropriate.
  • The urgency assigned is appropriate.
  • Patient safety considerations are identified.
  • Any contraindications or limitations are recognised.
  • Patients are directed to the most appropriate diagnostic pathway.

Clinical triage shall be undertaken only by individuals who possess the appropriate competence and delegated authority.

7.4 Prioritisation

Patients shall be prioritised according to clinical urgency and the requirements of the relevant commissioning agreement. Categories may include urgent referrals, routine referrals, and surveillance or follow-up examinations where commissioned. Clinical urgency shall always take precedence over the chronological order of referral receipt where patient safety may otherwise be compromised.

8. Appointment Management

8.1 Booking Appointments

Appointments shall be offered as promptly as reasonably practicable in accordance with local commissioning standards and available clinical capacity. Patients shall normally be contacted using their preferred method of communication where this information is available. Appointment information shall include:

  • Date and time.
  • Clinic location.
  • Preparation instructions.
  • Estimated appointment duration.
  • Accessibility information.
  • Contact details for enquiries or rearrangement.

8.2 Patient Communication

Communication with patients shall be clear, respectful and accessible. Where required, DMC will make reasonable arrangements for interpreter services, British Sign Language (BSL) support, accessible written information, large print, alternative communication methods, and support for patients with sensory impairment or learning disabilities, in compliance with the NHS Accessible Information Standard and the Equality Act 2010.

8.3 Reasonable Adjustments

The organisation is committed to removing barriers that may prevent patients from accessing healthcare. Reasonable adjustments may include:

  • Wheelchair-accessible appointments.
  • Extended appointment times where clinically appropriate.
  • Assistance for patients with mobility difficulties.
  • Communication support.
  • Support for patients living with dementia.
  • Provision of chaperones where appropriate.
  • Consideration of cultural or religious needs where reasonably practicable.

9. Waiting Time Management

DMC shall actively monitor referral-to-appointment times to ensure compliance with contractual requirements and to support timely patient care. Waiting times shall be reviewed regularly to identify emerging delays, optimise clinic capacity, support service planning, ensure equitable access, and minimise unnecessary variation in patient waiting times.

Where demand exceeds available capacity, the organisation shall work proactively with commissioners to identify appropriate solutions while maintaining patient safety and clinical quality.

10. Patient-Initiated Cancellations

Patients who are unable to attend their appointment are encouraged to notify the organisation as early as possible. Where appropriate, an alternative appointment shall be offered within available capacity. All cancellations shall be recorded to support service monitoring and audit. Patients shall not be disadvantaged for cancelling appointments where reasonable notice has been provided or where exceptional circumstances exist.

11. Provider-Initiated Cancellations

Where DMC is required to cancel an appointment, the organisation shall notify the patient at the earliest opportunity, provide a clear explanation where appropriate, offer the earliest suitable alternative appointment, and minimise inconvenience to the patient wherever reasonably practicable. Provider cancellations shall be monitored through the Clinical Governance Framework as a quality indicator.

12. Did Not Attend (DNA)

Patients who do not attend their appointment without prior notification shall be managed in accordance with the commissioning agreement and local operational procedures. The organisation shall recognise that non-attendance may be influenced by a range of factors including communication difficulties, health conditions, caring responsibilities or other personal circumstances.

Before discharging a patient following repeated non-attendance, consideration shall be given to safeguarding concerns, vulnerability, communication needs, learning disabilities, mental health needs, and any known barriers to attendance. Where appropriate, the referring clinician shall be informed of the patient’s non-attendance and any subsequent action taken.

13. Safeguarding and Patients Requiring Additional Support

13.1 Commitment

Direct Medicare Ltd (DMC) is committed to protecting the welfare and wellbeing of all patients accessing its services. The organisation recognises that some individuals may be vulnerable due to age, disability, physical or mental ill health, learning disability, cognitive impairment, domestic abuse, exploitation or other safeguarding concerns.

All staff have a duty to recognise, respond to and appropriately escalate safeguarding concerns in accordance with the organisation’s Safeguarding Adults and Safeguarding Children Policies. The presence of safeguarding concerns shall never result in a patient being denied equitable access to commissioned healthcare services.

13.2 Vulnerable Patients

During referral processing, appointment booking and attendance, staff should remain alert to indicators that a patient may require additional support, including older adults with frailty or cognitive impairment, patients with dementia, adults at risk of abuse or neglect, children and young people (where services are commissioned), individuals with learning disabilities, patients with severe mental illness, sensory impairment, or those experiencing domestic abuse or requiring communication assistance.

13.3 Chaperones

Patients shall be offered the opportunity to request a chaperone in accordance with the DMC Chaperone Policy. The availability of a chaperone shall be explained sensitively and documented within the patient’s clinical record where appropriate.

14. Equality, Diversity and Accessible Services

Direct Medicare Ltd is committed to ensuring that all patients have fair and equitable access to healthcare services. No patient shall be treated less favourably on the grounds of age, disability, sex, gender reassignment, pregnancy and maternity, race, religion or belief, sexual orientation, marriage or civil partnership, or socio-economic status. The organisation shall make reasonable adjustments to remove barriers to accessing care in accordance with the Equality Act 2010.

14.1 Accessible Information Standard

DMC will identify and record patients’ communication needs at the earliest opportunity. Where appropriate, the organisation shall provide interpreter services, British Sign Language (BSL) interpreters, large print information, Easy Read documentation, alternative communication formats, and communication support for patients with sensory impairment.

14.2 Cultural and Religious Considerations

Where reasonably practicable, DMC will seek to respect patients’ cultural, religious and personal preferences while maintaining safe clinical practice — for example, preference for a male or female sonographer where operationally possible, privacy requirements, religious observances affecting appointment scheduling, and cultural sensitivity during intimate examinations. Such requests shall be accommodated wherever reasonably practicable without compromising patient safety or delaying urgent clinical care.

15. Confidentiality and Information Governance

Patient information shall be managed in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Common Law Duty of Confidentiality, Caldicott Principles, NHS Records Management requirements (where applicable), and the DMC Information Governance Policy.

Patient information shall only be accessed by authorised individuals with a legitimate clinical or operational need. Referral information, appointment records and imaging reports shall be stored securely using approved information systems.

16. Communication with Referrers

Direct Medicare Ltd recognises that timely and effective communication with referring clinicians is essential to patient care. The organisation shall ensure that referrals requiring clarification are communicated promptly, rejected referrals include a clear explanation, clinically significant findings are escalated in accordance with local escalation procedures, completed ultrasound reports are issued within agreed reporting timescales, and urgent or unexpected findings are communicated without unnecessary delay using established escalation pathways. All communications shall be appropriately documented.

17. Patient Information and Informed Participation

Patients shall receive sufficient information to enable informed participation in their diagnostic episode, including the purpose of the ultrasound examination, expected duration, preparation requirements, any limitations of the examination, privacy arrangements, chaperone availability, how results will be communicated, and contact details for enquiries. Information shall be presented in a format that is appropriate to the patient’s communication needs.

18. Complaints, Concerns and Patient Feedback

Direct Medicare Ltd values patient feedback as an important source of learning and service improvement. Patients shall be informed of how they can raise concerns, provide compliments, make complaints, or request further information. Complaints relating to access to services shall be investigated in accordance with the DMC Complaints Policy, and themes arising from complaints shall be reviewed by the Clinical Governance Committee to identify opportunities for service improvement. Patients shall not experience discrimination or disadvantage as a result of raising concerns regarding their care.

19. Roles and Responsibilities

Managing Director

Has overall responsibility for ensuring that appropriate governance arrangements are in place to support equitable access to commissioned services, including ensuring adequate resources, maintaining compliance with contractual obligations, receiving assurance through governance reports, and supporting continuous service improvement.

Clinical Director

Provides professional oversight of clinical aspects of patient access, including referral appropriateness, clinical escalation and service quality.

Clinical Governance Lead

Oversees implementation of this policy, monitors compliance, reviews incidents relating to patient access, coordinates audits, recommends improvements, and reports findings to the Clinical Governance Committee.

Operations Manager

Responsible for the effective day-to-day administration of referral management and appointment scheduling, ensuring operational processes remain consistent with this policy.

Sonographers and Reporting Clinicians

Responsible for identifying inappropriate referrals, escalating patient safety concerns, providing safe, patient-centred care, documenting clinical findings accurately, and communicating urgent findings in accordance with established procedures.

Administrative Staff

Process referrals promptly, maintain accurate patient records, communicate effectively with patients and referrers, identify patients requiring reasonable adjustments, and maintain confidentiality.

All Employees

Every employee has a responsibility to uphold the principles of this policy, promote equitable patient access, treat patients with dignity and respect, report concerns, and participate in governance and quality improvement activities.

20. Monitoring, Audit and Quality Assurance

20.1 Commitment to Quality Assurance

Direct Medicare Ltd (DMC) is committed to maintaining a patient access system that is safe, equitable, efficient and continuously improving. Compliance with this policy shall be monitored through a structured programme of governance, audit and performance review to ensure that patient access arrangements remain effective, responsive to service demand and compliant with commissioning requirements.

20.2 Audit Programme

The organisation shall undertake regular audits of patient access processes. The annual audit programme may include referral acceptance and rejection trends, referral processing times, appointment booking times, waiting time performance, DNA rates, cancellation rates, reasonable adjustment requests, Accessible Information Standard compliance, complaints relating to patient access, equality monitoring, patient satisfaction, and timeliness of communication with referring clinicians. Audit findings shall be documented and presented to the Clinical Governance Committee.

20.3 Key Performance Indicators (KPIs)

To assure the effectiveness of patient access arrangements, DMC shall monitor a range of KPIs, including:

  • Number of referrals received.
  • Number and percentage of referrals accepted, returned or rejected.
  • Average referral-to-appointment time.
  • Percentage of patients offered appointments within contractual timescales.
  • Number of provider-initiated cancellations and DNA rate.
  • Number of complaints relating to access and patient satisfaction scores.
  • Equality monitoring data and safeguarding concerns identified during the patient access process.

21. Clinical Governance Oversight

Oversight of this policy shall be provided through the Clinical Governance Framework. The Clinical Governance Committee shall receive regular assurance reports relating to patient access, including waiting time performance, referral trends, DNA analysis, complaints relating to access, equality monitoring, audit outcomes, significant incidents affecting patient access, patient feedback, and service improvement initiatives. Where performance falls below agreed standards, corrective actions shall be identified, implemented and monitored.

22. Risk Management

Risks associated with patient access shall be managed through the DMC Risk Management Framework, including delayed appointments, incorrect referral acceptance, inappropriate rejection of referrals, failure to identify urgent referrals, communication failures, failure to provide reasonable adjustments, insufficient clinical capacity, system failures affecting appointment booking, and data quality issues. Significant risks shall be entered onto the organisational Risk Register, assigned a responsible owner and reviewed at appropriate governance meetings until satisfactory mitigation has been achieved.

23. Service Improvement

DMC is committed to continually improving patient access through systematic evaluation of service performance. Service improvement initiatives may be informed by audit findings, patient feedback, staff suggestions, complaints and compliments, incident reporting, commissioner feedback, peer review, clinical governance meetings, and changes to national guidance or local commissioning requirements. Improvement plans shall be proportionate, evidence-based and subject to ongoing evaluation.

24. Records Management

Records relating to referrals, appointment scheduling, waiting times, cancellations, complaints and audit shall be maintained securely in accordance with the organisation’s Records Management Policy. Records shall be accurate, contemporaneous, complete, retrievable, securely stored, and retained in accordance with legal, contractual and organisational retention requirements. Access shall be restricted to authorised personnel with a legitimate operational or clinical need.

25. Policy Review

This policy shall be reviewed every three years, following significant changes to legislation, following changes to NHS commissioning requirements, following changes to CQC regulatory requirements, where service redesign significantly affects patient access arrangements, or following identification of significant governance concerns relating to patient access. The Clinical Governance Committee shall be responsible for recommending amendments prior to approval by the Managing Director.

26. References

This policy has been developed with reference to the following legislation, regulations and guidance where applicable:

  • Health and Social Care Act 2008.
  • Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.
  • Equality Act 2010.
  • Data Protection Act 2018.
  • UK General Data Protection Regulation (UK GDPR).
  • NHS Constitution for England.
  • Accessible Information Standard (SCCI1605).
  • Care Quality Commission (CQC) Fundamental Standards.
  • NHS Standard Contract (where applicable).
  • Relevant Integrated Care Board (ICB) service specifications and contractual requirements.
  • Professional guidance issued by the HCPC, GMC, NMC, and the Society and College of Radiographers (SoR), as applicable to staff roles.

Appendices

Appendix A – Patient Access Pathway

1

Referral Received

↓
2

Administrative Validation

↓
3

Clinical Review / Triage (where required)

↓
4

Referral Accepted

↓
5

Patient Contacted

↓
6

Appointment Offered

↓
7

Reasonable Adjustments Confirmed

↓
8

Ultrasound Examination Performed

↓
9

Report Issued to Referrer

↓
10

Diagnostic Episode Closed

Appendix B – Referral Acceptance Principles

A referral shall normally be accepted where it falls within the commissioned scope of service, sufficient clinical information has been provided, the examination requested is clinically appropriate, the referral originates from an authorised referrer, and no exclusion criteria apply. Referrals that do not meet these requirements shall be returned to the referring clinician with a clear explanation and, where appropriate, advice regarding alternative referral pathways.

Appendix C – DNA Management Pathway

1

Patient Does Not Attend

↓
2

Attendance Confirmed

↓
3

Review Patient Circumstances

↓
4

Consider Safeguarding, Communication Needs, Vulnerability, Attendance History

↓
5

Decision: Rebook / Discharge / Refer Back

↓
6

Document Outcome

Appendix D – Monitoring Schedule

Indicator Frequency Responsible Lead
Referral Processing Times Monthly Operations Manager
Waiting Times Monthly Operations Manager
DNA Rates Monthly Service Manager
Complaints Quarterly Clinical Governance Lead
Patient Satisfaction Quarterly Clinical Governance Lead
Equality Monitoring Annually Clinical Governance Lead
Policy Compliance Audit Annually Clinical Governance Lead

Document Approval

Role Responsibility
Author Clinical Governance Lead
Policy Owner Clinical Governance Lead
Reviewed by Clinical Governance Committee
Approved by Managing Director
Next Review Three years from approval or sooner if required