Responses to statutory enquiries

The GCC was asked to respond to the Department of Health and Social Care's consultation on proposals to reform the General Medical Council's legislative framework.

The response welcomes many of the proposed reforms and highlights areas where the framework could be strengthened, particularly in relation to public protection, misleading qualifications, professional titles, private healthcare oversight and fitness to practise. The GCC also calls for a more coordinated approach to legislative reform across all healthcare regulators.

The GCC was asked to respond to a request for evidence from the Lord Mann review into tackling antisemitism and other forms of racism in the NHS and healthcare professional regulatory system.

The aim of this review is to examine how the regulatory system for healthcare professionals, from employment through to national oversight and professional regulatory bodies, supports recognition and reporting of antisemitism and other forms of racism, and tackles it at every stage.

At the conclusion of the inquest into the death of Joanna Kowalczyk, the coroner issued a Regulation 28 report to the General Chiropractic Council, recommending that consideration to obtaining medical records should always be given before assessment, particularly where recent medical treatment or investigations has been undertaken.

The GCC was an interested party at the inquest and committed to a thorough review of the issues raised. To support this, an expert group was established, comprising experts from within and outside the profession.

The expert group identified four learning themes that could be taken from the case, and actions that would support the profession in learning from those themes:

Theme 1 – accessing medical records

While “considering” obtaining medical records was felt to be standard practice in the profession, and reflected in standard D1 of the new Code of Professional Practice (2026), it was recognised that there were systemic issues (both real and perceived) – particularly for those in private practice seeking NHS records – which could prevent or dissuade a chiropractor from “obtaining” medical records. These issues could lead to a habitual downplaying of the relevance of the medical records when taking a thorough case history.

Actions:

• The GCC will commission an article acknowledging that chiropractors will ordinarily consider medical history as a matter of course, but prompting registrants to consider if there are further approaches available to them:
  • Does the registrant know how to obtain a medical report or imaging report from the NHS?
  • Can they use the NHS app to access medical history?
  • Are they reviewing medical history with the patient, or relying on completion of a form?

Theme 2 – Understanding and discussions of clinical risk

Patients and chiropractors may both shy away from conversations around rare, but catastrophic, risks. If a patient is not informed of the risks of a particular type of care, then they are not able to provide valid consent, or fully partake in shared decision-making.

Actions:

• The Royal College of Chiropractors (RCC) will produce a Chiropractic Practice Standard around risk and risk management. This will focus on a broad approach to risk and mitigation but will also look at some specific examples some of which would be relevant to this case.
• The RCC will produce a tool or tools to assist chiropractors and patients with shared decision making.
• The GCC will update the “patient portal” on the GCC website to include not only “what to expect” but also to identify reasonable expectations of the patient (to partake in shared decision making, to respect the clinical judgment of the chiropractor). The Professional Associations will consider producing a “safety net” leaflet for their members for use when a patient has been identified as being at a higher risk of stroke following treatment.

Theme 3 – Identifying the risk factors for cervical arterial stroke

The Expert Group set aside questions of causality in favour of a “precautionary principle” position that, as health care providers, chiropractors will encounter patients at risk of stroke. They identified that there was inconsistent understanding of stroke, the symptoms and the risk factors for patients in the profession.

Actions:

• The group will publish a letter to registrants following this case. The letter will avoid questions of causality but, following the precautionary principle, will ask registrants to reflect on their knowledge of stroke.
  The letter will highlight reputable sources of information on the risk factors for stroke – specifically NICE guidance 128 (Stroke and transient ischaemic attack in over 16s: diagnosis and initial management) and the Stroke association website.
  The letter will address the areas of poor understanding and lack of evidence identified by the group, namely:
  • some types of stroke mimic neck pain and headache and can therefore bring patients to seeking care.
  • symptoms of a stroke in progress can appear to improve
  • there is a lack of evidence of the risk of stroke in individuals with connective tissue disorders

Theme 4 – Responding to a stroke in progress

While there is a low probability of any individual encountering a patient suffering a stroke in progress, it is inevitable that someone within the profession will face a similar situation.

• The GCC will (as part of 2025-26 CPD focus on Safety and Quality within Principle B of the Code of Professional Practice) produce newsletter articles prompting registrants to consider:
  • Their own knowledge in recognising and first aid of a stroke in progress – including FAST and the importance of calling 999.
  • Identifying which hospitals local to them have an Integrated Stroke Delivery Network or similar dedicated stroke pathway.
• The RCC (in conjunction with London South Bank University) has updated the emergency referral form (which would be used in case of a stroke or other emergency). All parties will promote the updated form to their constituents.
• The GCC registrar will write to the Royal College of GPs and Royal College of Emergency Medicine highlighting his expectation that a referral from a chiropractor be given appropriate consideration.
• The group will seek to persuade the major clinic management systems to develop the emergency referral form as a standard feature.

The Expert Group

• Terms of Reference

At the conclusion of the inquest into the death of John Lawler in 2019, the coroner issued a Regulation 28 report to the GCC, recommending that First Aid training should be mandatory for chiropractors, and that the GCC should review whether a requirement for pre-treatment imaging may inform whether a patient is suitable for treatment.

The GCC committed to a thorough review of the issues raised.

First Aid

• In January 2020, the GCC issued a special bulletin to registrants asking them to consider their first aid skills.
• In May 2021, the GCC published further guidance on First Aid.
• At the end of the CPD year from September 2019 to August 2020, all chiropractors were required to submit a reflection on their own first aid knowledge and skills.

Diagnostic Imaging

In 2021, an Expert Group was appointed with representatives from the field of radiology and radiography, and from within and outside of the chiropractic profession.

The work of the expert group led to the development of the first edition of the GCC Guidance on Diagnostic Imaging (2021).

Materials created by, or for, the expert group during the development of the guidance:

• Terms of Reference
• Discussion Paper
• Background paper on the development of the Guidance.
• Equality Impact Assessment