What is PAG?
Performance Advisory Group
For many colleagues the first they hear of PAG is when they’ve been referred to it. It is a faceless acronym we have no knowledge of during our normal work. There are many reasons you can be referred to the Performance Advisory Group:
- GDC investigation
- BSA audit report
- CQC inspection
- Patient or staff complaint
- Ill health concerns
But what does it mean?
It’s the performer list equivalent to a employment disciplinary procedure
PAG is the first part of NHS England’s Performance management process. It is a group that considers what, if any, action is to be taken as a result of concerns raised. It is made up of representatives from NHS England’s commissioning and medical directorates, along with a dental specific member, often a dental practice advisor. NHS England follow a document “Framework for managing performer concerns“. It’s the performer list equivalent to a employment disciplinary procedure, but since dentists aren’t employed, their suitability to work for the NHS is covered by the Performer List Regulations.
When PAG receive concerns about the practitioner they look at the evidence and decide whether to investigate further, monitor, or pass it to another regulator eg. the GDC. This will depend on how the concern was raised, whether it relates to fitness to practice or just NHS work etc. The NHS does not look at your fitness to practise, but your fitness for purpose ie. working for the NHS. This is broader and covers more than the GDC.
Investigations
PAG will define the terms for the investigation, and commission, usually a dental practice advisor (DPA), to look into the concerns that have been raised. For example if a BSA audit flagged poor record keeping, the DPA may come to the practice to audit further records. The results of the investigation will then be considered by PAG.
No Action / Monitoring
If the concerns raised turn out to be unwarranted, or it is clear the practitioner has already remedied them PAG may choose to take no further action. It is however possible they will look at the practitioner again, eg. re-audit in 3 months, to ensure there are no further issues.
Undertakings
PAG may wish the concerns to be addressed by the practitioner, but are satisfied this can be done less formally. They will draft some undertakings which the practitioner agrees to, eg. additional training, improving policies and procedures, etc. These undertakings will then be monitored by PAG until they are satisfied the practitioner is no longer a risk to the efficiency of the service.
Referral to PLDP
Where serious concerns exist a practitioner may be suspended pending hearing
If the concerns are serious, or the practitioner is not cooperating with PAG, they may choose to refer to the Performer List Decision Panel. This panel is made up of a lay chair, a medical director (or deputy), a discipline specific member, and a representative with responsibility for safety (usually from the Nursing Directorate). PLDP will look at any of the work undertaken by PAG and convene a hearing. Practitioners are given 28 days notice and are entitled to representation. The potential conclusions of the hearing are given in advance, where serious concerns exist a practitioner may be suspended pending hearing. Following the hearing, if the concerns are deemed to be substantiated, PLDP may impose conditions of inclusion, or remove a practitioner from the list. Conditions are similar to undertakings, but are formally added and failure to comply can result in removal from the list.
What to do?
If you find yourself under investigation this can be incredibly stressful. Seek support from LDC colleagues early who can give you face to face support, and point you in all the right directions. If there are issues, addressing these in advance of a PAG meeting can help show insight and reduce the concern level. Above all – don’t face it alone – contact us.