selected medical practitioner

Survey Results – R.E.S.P.E.C.T.—why some doctors are not getting any

iodpa morale, selected medical practitioner
Survey Results – R.E.S.P.E.C.T.—why some doctors are not getting any

“R-E-S-P-E-C-T!!! Find out what it means to me”― Aretha Franklin

Our straw poll would never receive awards for being scientifically robust, but it provides an overview to the opinion of serving and retired officers towards those doctors (aka force medical advisors) employed by police forces – and that overview certainly seems to be at odds to how doctors are viewed by the public at large.

Generally in the United Kingdom, which has been hit by an unprecedented number of medical scandals and transgressions in recent years, doctors still top the polls as the most trustworthy and hardworking of all professionals.   An Ipsos MORI recent polling found that doctors were the most trusted profession, with 90 per cent of respondents trusting them to tell the truth. In contrast, just 16 per cent of respondents trusted politicians and 22 per cent trusted journalists to do likewise.

Our survey (for all it’s faults) had representation from all forces except Lincolnshire (perhaps there is Democratic People’s Republic of Lincolnshire that clamps down on Internet access and purposefully prevents its citizens from communicating with the outside world – or more likely maybe there isn’t an issue with ill-health retirements in this force, so there is no incentive for those to look at related social media).

Only 8% of respondents trust their force medical officer.

Do you trust your force medical adviser?

 

 COUNT PERCENT
No 277 66%
Don’t know him/her 107 26%
Yes 34 8%

Strip out the ‘don’t knows’ and you can see the stark realism that 89% do not trust their force doctor.

rplot-yesno-survey

And what forces have least trust in the force doctor and mostly make up the blue “no’s”?rplot-no-surveyAnd those with the most trust in the force doctor?  Due to the low numbers we can show all 34 votes and the vote’s corresponding force individually.

rplot-yes-survey

What this all suggests is that police officers at their most vulnerable have no faith in some of these occupational health doctors.

Those clinicians tasked with duties such as promoting healthcare policies and initiatives and advice on medical, health and welfare matters, are neglecting their core duty – to care for people.

There is no sane reason why force medical officers should not have the same high satisfaction rates as their peers in other specialities.  However, it seems some have misplaced loyalties to the pleasing of the employer and not the patient or  to the furthering of medical excellence.

When they are needed most they are causing deep pain and prolonged suffering . With notable exceptions, some are no longer regarded as the paternalistic figures they once were, but rather as a technical bureaucrat or a gatekeeper with an over-riding deigned reluctance – who begrudges having to deal with those police officers the Job has injured, discarded, disabled and defeated.

Why Things Hurt

iodpa morale, police injury award, selected medical practitioner, smp
Why Things Hurt

“Of pain you could wish only one thing: that it should stop. Nothing in the world was so bad as physical pain. In the face of pain there are no heroes.”
― George Orwell, 1984

This post is about the complexity of pain and the observation that the doctors used by police pension authorities are not able to comprehend how the world of a previously fit and high-achieving police officer collapses once they are injured on duty.  It shows that the consultants, GPs and clinicians of the former officer -who know of and have treated the individual – heavily out-guns the opinion of any given selected medical practitioner.

You haven’t had any contact with the police for years and now they want to reduce their financial commitment by reviewing your injury award .  There has been no change, in fact you’re worse now than ever.  You just want to be left alone to live your life.  Or you are a serving officer struggling on long term sick leave and currently the victim of an UPP.

How can an occupation health doctor make a valid judgement on your health in a 60 minute ‘interrogation’ – don’t fool yourself into thinking it is anything but an inquisition: imagine Tomás de Torquemada assisted by the full incompetence of a HR department.

An injury on duty can involve both body and mind and quite likely both.  A physical injury has psychological consequences. PTSD (Post Traumatic Stress Disorder), is caused when a person experiences an ordeal that causes physical harm or mental harm. The individual was either harmed, someone close to them was harmed, or they experienced events that was imprinted in their brains.  In PTSD, there are two main parts of the brain that are affected and also where all the chemical imbalance in the disorder is located at. The two main parts are the Hippocampus and the amygdala.

http://www.chemistryislife.com/the-chemistry-of-post-traumatic-stress-disorder

The hippocampus is a part of the brain that is located inside one of the folds of the brain so it is not identifiable by the human eye but the way we can find it is that it is located at the temporal lobe which lies right under the temple of the human body. An important function that the hippocampus does is that it makes information into memory and stores it in the brain. So, for example, someone experiences a traumatic event in their life and they can’t forget about it even though they try really hard to. The hippocampus has taken this traumatic event that this person has and stored it in their brain as a memory which explains how PTSD works. This part of the brain can also send connections to the amygdala which then could explain the beginning of strong emotions triggered by specific memories or events. But it is not just for making memories. It also plays a huge roll in the making of creating new brain cells for the brain. The hippocampus may look intimidating but it can be affected very easily. Alzheimer’s Disease, Epilepsy, and little blood flow are just some of the injuries the hippocampus could have.

The other big part of PTSD is the amygdala. Like the hippocampus, it is also part of the limbic system and is also inside the brain just above the hippocampus and the lateral ventricle. This is the epicenter of emotional behavior, emotions, and also motivation. A lot of signals from the other brain parts go to the amygdala because it then makes those signals into emotion. The amygdala can produce components of emotion such as heart rate changes, blood pressure changes, and also respiration changes in the body. While the hippocampus makes memory, the amygdala takes those memories and combine them with emotion which could explain why certain memories produce certain emotions for us such as happiness and fear. This is where the “fight-or-flight” mechanism comes into play. Since so many alarm circuits of the human body are located in the amygdala, there is a lot of triggers that can activate the “fight-or-flight” response.

Sufferers of PTSD are prone to chronic pain and sufferers of the chronic pain of debilitating physical injuries are liable to suffer from PTSD-like chemical imbalances.

The author of this post has a physical injury that has also manifested itself psychologically.  Chronic pain does that.  A life not lived; a career cut short. Over time, to treat the condition, nociceptive prescription pain medication is supplemented with neuropathic medication.  But we are still dragged in front of a SMP and demanded to explain ourselves.  Questioned in a hour window on why we are no longer the high achievers we once were.

This video gives an interesting insight into pain but reveals a terrible dilemma.  We are all individuals,and as IODs, all our circumstances are different.  Herein lies one of the complexities that makes understanding and treating chronic pain so difficult.

Professor Lorimer has the advantage of being on the top of his game.  He has a successful career in clinical Neurosciences. His lecture is factually correct.  Experience doesn’t always match the explanation.

For the individual chronic pain is a reinforcing web of pain signals, personal history, seeking security in what you know (pain) and limited ability to envisage a future.  It is life consuming and this is why the Regulations are there to compensate for work-related injuries.

SMPs are not equipped to understand how the brain creates and perpetuates pain.  They will always fail to make a valid judgement on your health in an allotted 60 minutes.  For this reason if you are ever unfortunate to go in front of a SMP, for whatever reason, go prepared.  Make them understand the complexity of your illness.

Bogeymen

iodpa NAMF, National Attendance Management Forum, police injury award, selected medical practitioner, smp
Bogeymen

“If there is anything more annoying in the world than having people talk about you, it is certainly having no one talk about you.”
― Oscar Wilde

A bogeyman (also spelled bogieman, boogeyman, or boogie man) is a monstrous imaginary figure. But it seems that some HR Departments believe he is real and even now stalks the land in human form.

The bogeyman of legend and fairy tale has no specific appearance. Children are told stories of shadowy shapes that flit into the corner of one’s eye and then disappear. The bogeyman might live under the bed, or in the wardrobe, or might be lurking in the dark overgrown bushes at the bottom of the garden. No matter where he hides, he is out to get you, so beware. Hurry home, children, dive into bed and pull up the covers so he can’t seize you by the toes and drag you off to his lair.

HR managers give the bogeyman more corporeal form and substance. They seem to think that the bogeyman appears in the borrowed shape of disabled former police officers. A guise quite at odds with the spirit of the legends and, as a modern take on a traditional myth, is really very inventive and clearly the product of a disturbed mind.

The etymology of the word “bogeyman” is uncertain, as is when it first appeared in the English language. Some sources date it to the 16th century, while others to around 1836, as a term for the Devil.

The Devil is now, according to the rumour mill being circulated by some police forces, stalking and abusing, not children, but stoical adult medical practitioners who work for police forces.  By these accounts one force in particular is telling people, ‘that a doctor has been subject to stalking and that threats have been made against FMAs [Force Medical Advisors] by a campaign group’.

We at IODPA are extremely shocked and concerned at this revelation.  Apparently there is a militant and anarchist campaign group out there that is actively seeking out and physically targeting force medical advisors (selected medical practitioners were not mentioned).   The force spreading this malicious and unsubstantiated gossip mentions FMAs, plural – as in more than one single incidence.  The source of this fairy tale we suspect to emanate from the National Attendance Management Forum, which is where HR managers and others gather together, safety in numbers, to exchange gossip and misinformation.

The unsubstantiated Chinese whispers we have heard are that the stalking typically involves a sped-up chase scene involving a crew of scantily-clad injured persons hobbling with their canes and struggling with their mental illness, with a doctor being the one chased, due to silly predicaments that he himself caused.  A take-off on the stereotypical Keystone Kops chase scenes.

In all seriousness, we are in IODPA a cooperative made up solely of responsible, adult, medically retired police officers, who were all injured in the execution of their duty.  It is generally known that it takes a high standard of character to be recruited into the police and that police work can be dangerous. Our members were all injured through no fault of their own and are now disabled members of the public with a strong core of moral code.  We have been subjected to unlawful behaviour by police pension authorities but we will never reciprocate like with like. Injustice cannot be overcome with injustice.

The injuries of our members range from physical to psychological.  Quite often the physical injuries have psychological repercussions.  The psychological injuries are often extremely severe.

Perhaps IODPA is being too precious, but we hope that the Devil that these forces believe is stalking doctors is not meant to be a reference to us.

We therefore challenge any FMA, SMP or HR person to produce concrete proof of these allegations. If any person has been stalked, tell us who, when and where. If there was evidence of harassment, abuse and threats then any competent and  independent person would expect there to be a criminal investigation and a prosecution.  It speaks volumes that there has been no such thing.  All police forces should be above the childish playground behaviour of spreading rumours.

In the meantime, we will take these bogeyman tales as no more than a foul ploy to divert attention away from the very real, and evidenced accounts of harassment and, yes, stalking, of disabled former police officers by police forces.

The fact is, members of our association have been stalked.  There are instances where people with IOD awards have been put unlawfully under surveillance. We can never forget the case of the West Midlands consultant psychiatrist, Dr Nicholas Cooling, who personally hired a team of private detectives to stake out and video an injured police officer.  The GMC suspended him over that little lapse of ethics.

Another tale of harassment concerns a former South Wales officer whose police career ended after he was severely traumatised following the 2002 clash between Cardiff City and Leeds United fans, and who won a victory in 2009 against South Wales Police, which had kept him under surveillance for months.  The Police Medical Appeal Board (PMAB) was highly critical of South Wales Police, which had claimed he was not entitled to an injury award. The Appeal Board adjudication said video evidence of him was irrelevant. Material disclosed subsequently showed that 11 officers from South Wales Police and the neighbouring Dyfed-Powys force were used to spy on him for months in an operation estimated to have cost more than £100,000.

There have been too may instances to list here where a person with an IOD award has been abused and harassed over a course of years not just by a SMP but also by the bullying machinations of a zealous and uncaring HR department.

We will mention one incident, which concerns a very ill retired former officer who was summoned to be reviewed. Two friends drove him to the appointment at the force’s occupational health offices, and waited for him in the car-park.  When the review was under way a uniformed police officer with their epaulettes removed came out of the building and blatantly took photographs of the waiting vehicle and the occupants.   Here was no RIPA authority, nothing that allowed this intrusion into civil liberty.  Not prepared to be taken at a disadvantage, the occupants themselves took a picture or two of the uniformed officer taking pictures.  Then a doctor came out of the building, walked up to the car and spoke to those within saying, ‘Do you want a close up?’

We know of another incident where a person with complex psychological issues was forced to undergo a review just because he was a band four.  Despite his condition down-turning and his clinicians warning the force and evidencing his severe deterioration during the months of delay cause by the police pension authority, the force in question kept up their sanctimonious fishing trip.  This sorry episode was reported in this blog post.

Driven to the realms beyond madness he told his crisis clinician during a mental health crisis team counselling session that he wanted to kill those who he saw were harming him.  This clinician took the threats seriously and was duty bound to escalate his concerns to the relevant authorities.  There are always two sides to every story.

The shameful outcome of this shameful event is the force ‘deferred‘ the review (a made up thing that does not exist in the Regulations), saying the former officer is too ill and that he should be reviewed again in 3 months, ‘when he is better’.

A review isn’t a benign thing.  It damages people.  And if they are damaged already they become more and more unstable.  IODPA does not condone unlawful behaviour.  That said, we can understand why someone with complex PTSD isn’t always in control of their own responses.

When a force proclaims that a campaign group is physically threatening Doctors, and it uses this as an excuse to withhold information, it tarnishes everyone.  This circus show encourages guilt by association, and seeks to demonise all disabled former officers. We say, you hypocrites, first take the plank out of your own eye, and then you will see clearly there is no speck in our brother’s eye.

IODPA only asks for fairness, respect and the fundamental and lawful following of the Regulations.

Those injured former officers who contribute to this association are all law abiding citizens.

If only those that administer the police injury award scheme were as conscientious as we are.

 

Bad Medicine

iodpa selected medical practitioner
Bad Medicine

“Men will always be mad, and those who think they can cure them are the maddest of all.”

“Doctors put drugs of which they know little into bodies of which they know less for diseases of which they know nothing at all.”
― Voltaire

The College of Policing released a report in 2015 concerning an inquiry it arranged into the Injury on Duty process. This post will discuss how that report revealed issues concerning the Occupational Health clinicians who are used by forces in the role of ‘duly qualified medical practitioners‘ as required by the Regulations which govern police injury pensions.

Each of the quotes used below are excerpts from the College’s report.

Before I begin, I need to mention the structure of the College.

It is perhaps not quite the independent seat of learning and academic rigour which one might naturally expect of anything calling itself a ‘college’. It is currently a private limited company, with but one shareholder, who is the Home Secretary. It’s own web site tells us that,

‘As the College is currently a company limited by guarantee, as well as an Arm’s Length Body of the Home Office, all members of the Board are Company Directors. ‘

In plain language, the College is the Home Office pretending to be an academic institution.

Being arm’s length is a bit like the Mafia setting up apparently legitimate shell companies to launder its money and to give the appearance of respectability. With the Home Office it is not dirty money which needs to be laundered, but dirty, disrespectful ideas which seek to undermine the law of the land.

Just as the College is not quite what it would like us to think it is, much the same sort of misdirection applies to the odd little off-shoot of the medical profession known as Occupational Health.

By some self-publicising accounts Occupation Health is a, ‘multi-disciplinary approach to developing and ensuring compliance with safe working practices, and maintaining the health and well-being of those employed in a particular occupation or workplace’.

Phew. Quite a mouthful.  One has to wonder quite what that has to do with regards to administration of the Police Injury Benefit Regulations. Yet the situation is that forces have been persuaded to accept that any SMP must hold a minimum qualification in occupational health.

Occupational Health clinicians like to get people back to work, or help prevent them getting injured or ill in the first place. That is their raison d’etre. Notwithstanding that a police officer is not an employee (they are holders of office), once medically retired a former officer injured on duty is no longer employed in any sense of the word – they are retired via incapacity – so it is hard to see quite what value an occupational health clinician can bring to the area of police injury pensions.

Injury on Duty awards are governed by Regulations, which mention not a single word about duly qualified medical practitioners needing to have a qualification in occupational health. All that the Regulations require is the selected medic is actually qualified to practice – which means they must be registered with the GMC.

So, how is it that IOD pensioners are now faced with having to be assessed by medics whose chosen ‘specialisation’ has effectively removed most of them from the actual day-to-day practice of ‘real’ doctoring? The answer is that some few years ago, the now-defunct Police Negotiating Board, whose remit was to negotiate the details of pay and conditions for serving police officers, strangely decided to issue a joint circular, with the Home Office, in which it agreed that all ‘duly qualified medical practitioners’ who were to make decisions under the Regulations should hold a minimum qualification in occupational health.

The effect of this has been to narrow the pool of duly qualified medical practitioners who might work as ‘selected medical practitioners’ (SMPs) down from the approximately 236,000 doctors who are licensed to practice medicine in the UK, to a measly handful of doctors who have bothered to qualify for what most mainstream doctors regard as the utterly irrelevant specialisation of occupational health.

The small number of potential doctors who can be selected by a police pension authority has been further diminished by the interference of the National Attendance Management Forum which has seen fit to produce a list of doctors it claims ‘have shown an interest in’ working as SMPs. This is, of course, typical new-speak meaning that these doctors are the sort who are either gullible enough or corrupt enough to see the Regulations as no more than a general guide which can be ignored.

Disabled former officers have been powerless to prevent the erosion of the role of what was intended by the Regulations to be performed by independent, experienced medical professionals. Instead, they now face the prospect of the level of their pension income being in the dubious hands of doctors who are on the very bottom tier of the medical profession, and who have shown themselves to be variously incompetent, corrupt or ignorant of what the Regulations require of them.

IODPA has seen examples of SMPs knowing full well that a former officer is a 100% band 4 but still, with perverse logic, and directly contrary to the Regulations, give the retiree a figure of 85% in order to provide some forlorn future ‘hope’ of a recovery to the disabled person. Similarly, SMPs have looked to the future and speculated about what jobs a retiree may be able to do – thus completely missing the point that an assessment of degree of disablement is supposed to be based the extent the disabling effects of duty injury have – past tense – had on the individual’s capacity to work. In other perversions, SMPs ‘decide’ that an individual is, say, 50% disabled, only for some HR pen-pusher with no medical qualifications take a short list of wages which might be earned, compare them to either the former police salary earned, or some nominal figure plucked from the data on national earnings produced by the Office of National Statistics, and then – wait for it – take one from the other to determine a ‘degree of disablement’ then take the 50% off the resultant figure.

This sort of manipulation is without a doubt completely unlawful. IODPA gives fair warning to HR managers, SMPs and Chief Constables that this issue will be dealt with in the High Court in due course.

Given that considerable doubt has been cast on the professional competence of SMPs, on their independence, and on the unwarranted and illegal interference with their decisions by HR personnel, any reasonable police pension authority would cease the practice of wage comparison at once. Of course, we at IODPA know full well that police pension authorities will do what they always do and deny there is anything wrong.

Just as occupational health qualifications have no part to play in the role of SMP so is reason, common sense and decency absent from the small number of Chief Constables who continue to allow their wayward HR managers to abuse disabled former officers and stick two fingers up to the Regulations.

We need now to return to the inquiry which the College of Policing completed, to get a glimpse of the full, disturbing picture of the shambles that is the administration of police injury pensions.

Shockingly, the College admits that that some forces take delight in the subversion of the Regulatory process by influencing the SMP. Moreover some SMPs take delight in being influenced to do the subversion – what better way to keep the paymaster happy!

In the event of incidents of force subversion of the regulatory process, considering SMPs are on the whole employees of occupational health providers working under contract with the force, there is a clear conflict of interest for the companies in question in the event that a SMP raised concerns. – paragraph 19.10

That is no surprise to us. Add together a force willing to subvert a lawful process with a SMP whose occupational health mindset is such that they only sees their role as being to get someone back to work and you have a rather a monstrous double-sided conflict of interest.

The College reveals there is little attraction in working as a SMP.

In addition to this there is a general perception articulated by a number of clinicians who engage with this review that the police service is not a desirable employer. At the heart of this issue appears to be concerns over vulnerability to baseless complaints, or threats of complaints, by officers or former officers, to the GMC in order to obtain more favourable pension settlements. Other SMPs report perceived pressure from management to obstruct the process and influence decisions – paragraph 19.7

It is the involvement of and bastardisation of ‘guidance’ by the National Attendance Management Forum, and the fact that it has produced a list of doctors, and companies providing doctors who are willing to act as SMPs that has meant a small pool of lowly occupational health clinicians now have a monopoly. The NAMF has its set list of preferred SMPs – a list that, we repeat, has had the consequence of further stifling the available pool of competent clinicians. SMPs are now given work just because they have been working as SMPs and not because their judgements are sound.

Otherwise excellent doctors are either barred from becoming SMPs or see the role as beneath them, and dangerous to their professional reputation to boot.

Many forces are experiencing increasing difficulty in identifying suitable doctors to perform this role. The role of the SMP is a specialist one and at the time of writing the available resource is limited. Historically, when the relevant regulations were written, many SMPs worked as Force Medical Advisors (FMA) in other forces. However ongoing changes to occupational health delivery has resulted in the vast majority of forces now obtaining clinicians from private companies with no prior background of the police service.- paragraph 19.3

 

One of the problems relating to the difficulties in obtaining suitable doctors as SMPs is cost. Whilst SMPs can represent a significant cost resource to Forces, SMP work is relatively poorly paid compared to other roles clinicians can obtain both in the field of occupational medicine and in the private sector. In addition to this, the General Medical Council (GMC), in their 2014 edition of our annual ‘state of medical education and practice’ report, recognises the decline in the number of doctors choosing to go into occupational medicine and reports that occupational health has more doctors aged over 50 than any other speciality. – paragraph 19.5

On one hand the College is saying there is a shortage of SMPs and on another they say they are underpaid. Market forces do not work this way. A rare resource can charge an inflated amount; what the College fails to report is that a cabal of SMPs have a monopoly and all the available work is taken by a small number of well-paid ‘guns for hire’.  We know, for example, of one SMP who was paid over £45,000 for conducting fewer than a dozen reviews. These ‘established’ names suffocate competition and prevent new blood from entering the profession.

We have to also comment that it seems the College is saying that becoming a SMP is really the last chance saloon for occupational health clinicians who have failed to make a living elsewhere.

The situation, according to the College, is that these rather pathetic failures are thrown in the deep end when they take on the role of SMP.

There is at present no recognised training or qualification for Force Medical Advisors (FMA) attempting to manage these complex issues, or for SMPs, who must make statutory, quasi-judicial decisions.- paragraph 15.3

It is not the Regulations which are complex. In fact, as statutory instruments go, they are concise and clear. The esoteric fog only exists because the police pension authorities have, in the words of the College, repeatedly attempted to subvert the process. It has fallen to the judiciary to undo the damage the Home Office and individual forces inflict on the Regulation’s interpretation.

Perhaps the raw truth is more like the College has heard forces moan to them that they are finding it difficult to undermine the Regulations. That, having dreamed up a cunning plan to control the supply of doctors who can act in the role of SMP, some forces now find they have contracted people who are so useless as to not even be capable of perverting the Regulations convincingly.

The PNB guidance states that in order to perform the role of a SMP a doctor must be competently trained to effectively assess a police officer’s medical condition and disability. However the role of the SMP also requires them to understanding the complex regulations and case law and make arbitrations on evidence. These requirements lie outside the normal skill set of a professional clinician and are more associated with the role of a legal professional. – paragraph 15.4

Again the College is seeking to excuse the poor administration of Injury Awards by repeatedly proclaiming that the Regulations are complex – conveniently forgetting that it is those who administer the Regulations who have forced the wealth of case law into existence as a result of their inability to do things right.

Any competent holder of a medical degree will take huge offence at the College’s assertion that making decisions based on arbitrations of evidence is beyond their skill-set. Given the regulatory demands of any aspect of the medical profession such understanding is surely a core skill.

To date there are limited training opportunities available and no centrally accredited SMP qualification. Individual SMPs are therefore reliant on their experience of the work, personal endeavour and any ad hoc training they have been given by their employers. – paragraph 15.5

The Regulations in their current form have been in existence since 1987. Almost 30 years have passed and the College brazenly declares that there is still no gold-standard to measure the competency of a SMP.

Again the College conveniently forgets that the current chaos of poor and shady SMPs had its birth in Home Office circular 46/2004 which contained guidance from the Home Office which was an unlawful carte blanche attack on the Regulations. It took a courageous IOD pensioner to drag the Home Office to the very door of the High Court before the Home Office caved in and accepted the guidance was unlawful and agreed to withdraw it.

The guidance has been erased but the perversions of the Regulations continue, with some forces inventing ever more complex ways of manipulation so as to produce decisions which reduce the amount of pension paid.

It is no wonder that even decent SMPs are hopelessly confused or find their genuine efforts to apply the Regulations properly are frustrated.

The review has found little to no evidence of the private companies who are contracted by forces to provide both occupational health provisions and SMPs providing formal training for SMPs. Furthermore it is questionable whether consideration of training was included in tendering when obtaining SMPs through occupational health companies. – paragraph 15.9

Even the business school mantra of, ‘If in doubt outsource it’ is called into question by the College. By hiring a company to provide a SMP a police pension authority will lose any in-house experience but at least they can blame a private company when it all goes wrong. Or not. The private companies become bigger and bigger and as they do so they become less fit for purpose. The College fails to address why all this public money is given to occupational health companies who fail to evidence competency in the tendering process.

So, where is all this going? What actually lays behind the Home Office encouraging the College to make its enquiry? Why is the Home Office apparently content so see exposed so many failures by forces, their HR departments and SMPs?

Bear in mind when pondering this apparent own goal that the College is an arm’s length body of the Home Office. The College is the Home Office.

The report contains a blatant clue as to what the Home Office hopes to achieve. It raises the spectre of complaints against SMPs and it puts forward the suggestion that, when performing their roles under the Regulations, SMPs should have immunity from GMC standards.

It is noted that in separate correspondence to the Home Office representations have been made to suggest judicial exclusion for the role of the SMP. Furthermore legal opinion obtained as part of this review suggests that a medical authority appointed under the Regulations may be covered by the doctrine of
judicial privilege.- paragraph 19.2

Who made these ‘representations’ and what motivated them being made? It is an astounding suggestion – that doctors which the Regulations require do nothing more complicated or demanding than make independent medical assessments and decisions should need to be elevated to the status of a Crown Court Judge.

This immunity is contrary to the guidance of the GMC who state …

.

The first duty of a doctor registered with the GMC is to
make the care of their patient their first concern. The
term ‘patient’ in this guidance also refers to employees,
clients, athletes and anyone else whose personal
information you hold or have access to, whether or not
you care for them in a traditional therapeutic
relationship. – Section 2

A SMP is always a medical doctor first and therefore is answerable to the GMC. Under the Regulations their role is primarily medical in nature and purpose. A SMP must comply with the Regulations. Yes, decisions a SMP makes form part of a quasi-judicial process, but the College is in error when it suggests the SMP should become a judicial figure, for that element and responsibility is already present and rests with the office of police pension authority.

The report is nothing more that a sham. It is not the independent, impartial, academically rigorous enquiry it purports to be. As a dissertation it would be torn apart, for its entire purpose is to provide support for an idea. It is an exercise in propaganda.

Appendix D of the report contains the ugly truth of the Home Office’s purpose. The Home Office likes appendices. It was appendix C to Home Office circular 46/2004 which tried to encourage forces to act unlawfully. Here we have yet another appendix intent on much the same objective.

Appendix D offers a vision of a future arrangement when Regional Centres manage all aspects of the administration of injury awards. Forces, and SMPs, will completely lose the independence of thought and action which the Regulations are intended to ensure. The Home Office will have recreated the infamous Volksgerichtshof, the ‘people’s courts’ of the Third Reich, which were intended to provide that regime with an apparently lawful way of side-stepping the inconvenience of an independent judiciary.

Various benefits to such an arrangement are touted, but the plain truth is that if regional centres are created then they will be controlled entirely by the Home Office, no doubt through another shell company – sorry, an arm’s length body – which will ensure that all doctors hired as SMPs are compliant, corrupt and whose purpose will be to subvert the Regulations to the very great detriment of the brave men and women who were disabled in the line of duty.

 

In the here and now

iodpa caselaw, Regulation 37, selected medical practitioner
In the here and now

“It’s being here now that’s important. There’s no past and there’s no future. Time is a very misleading thing. All there is ever, is the now. We can gain experience from the past, but we can’t relive it; and we can hope for the future, but we don’t know if there is one.”
― George Harrison

Imagine, if you will, that you are a 37 year old male police constable with 15 years service.  You weigh 75 kilos and have 32″ waist.  You have just run to work at a brisk 6 minute mile pace, performed a 14 hour shift and run home (or if you prefer cycling, you cycled the detour of 15 miles in a spritely average of 20 mph).  You are basically immortal.  Then you have an on duty injury, and after 18 months and numerous surgical interventions you are retired with an IOD award.

What relevance would your medical notes be at the time you were 37 and able to run the 5 miles to work in 35 minutes (or cycle 15 in 45 minutes) to  start that early turn?  How would looking to that past allow for an impression on your capacity to earn on the day you were retired?

Following this train of thought, how can your fitness or lack of it 3 months or 3 years ago be an indication of your present degree of disablement?  It can’t be.

Speculation into the future is forbidden when an IOD is awarded, and this speculation similarly is not allowed at a review.  The degree of disablement in relation to earning capacity shall be determined at the time of the decision and not make any reference to potential future earning capacity (South Wales Police Force vs Anton and Crocker)

The starting point is Regulation A12(3) [of the Police Pensions Regulations 1987]. It requires an assessment of how earning capacity “has been affected”, not of how it is likely to be affected. (1)

It goes without saying that a lot of people will have reports from the SMP saying, rather hackneyed, ‘might be capable of work in the future’ or at review, the vapid ‘has worked in the past’.  These opinions are unwarranted and contrary to the above case-law.  It is how you are now, not how you were before the review started, or 12 months ago, or in 12 months time.

This is important as the above melds  two things: (1), the argument that a great number of SMP decisions are unlawful if the above comments have been used to lower a band, with (2), the reason FOR a review.  If earning capacity in the ‘here and now’ is zero then the award should be 100% and if in the ‘here and now’ the former officer is still unable to work there is no legitimation to review.  At a review, past medical records do not speak of the ‘here and now’ – arguably very recent records do, but historical records do not.     The positive duty to review is a figment of the Police Pension Authorities’ imagination.  The duty not to refuse a review if circumstances change does exist and if in the ‘here and now’ there is substantial change then the award can be revised.

The regulations are not there for any force to regularly spend over a year punishing a former officer by dragging them through a protracted review.

Interestingly, how can a force make a decision 8 months after that person saw the SMP?  Surely after such a time of procrastination any decision can be appealed with an automatic appeal of  ‘change of medical condition’.  Life has moved on, health has ‘moved on’ but the SMP report looks in the past.  The person can not be reviewed again as an immediate review consecutive to the last is not a suitable interval.  The ‘here and now’ is important.

A review is time sensitive and should be finalised within a month of the assessment (if required) with the SMP.  Otherwise time makes a non-finalised review obsolescent.  It can not be any other way – if the detailed examination of the elements were conducted 6 or 8 months ago then the ‘here and now’ has ‘been and gone’.  The “[…]  assessment of how earning capacity [ ] has been affected”  is twisted into “will be affected” and this distortion does not conform to the regulations and is explicitly denied by case-law, so therefore is unlawful.

Any  decision made based on superannuated assumptions can and shall be appealed on basis of time without any need to question the content of the decision.

(1)

Expiration of Consent

iodpa Freedom of Information, selected medical practitioner
Expiration of Consent

“Nobody can hurt me without my permission.”
― Mahatma Gandhi

Often the occupational health file of a former officer contains disclosed medical records; records that were obtained via consent for a specific purpose, be it the original decision or the last review.  The GP medical records do not belong to the force – they were collated for a reason and should be disposed of once that reason has ended.  Does the force have the right to dip in and out of these medical records as they chose?

Here is a response from the Information Commissioner’s office regarding the limitations of consent:

Case Reference Number ENQ0571696

In your email you ask questions about third parties gaining consent to access your medical records from your GP.

Question: […] once consent is  given, is that consent infinite until explicitly withdrawn? In other words once consent is so given is the passage of time, whether that be days, weeks, months or years irrelevant ?.

ICO answer: Consent would need to gained with each request.

Question: […] once that consent has been given in writing for a third party (as above) to access a patients medical records, at the point those records are provided (accessed), does that specific consent then expire?

ICO answer: The consent would last until the records were accessed by the third party.

Question: To clarify that, can that given consent be exercised more than once or continuously ?

ICO answer:  Consent would need to be gained with every request.

Question: Would any request made now be considered a fresh request and any attempt to use a historical consent be denied ?.

ICO answer:  If there is going to be a new request for your medical data, consent would need to be gained.

Question: Would any registered medical practitioner be acting unethically if they made such a request based on an historical consent ?.

ICO answer:  A medical practitioner needs to comply with the Data Protection Act 1998(DPA) and could not use a historical consent.

Question:  Would the ICO position be if such a historical consent was attempted to be used or presented as being valid (despite the passage of time and previous access) that any registered medical practitioner should reject such a request as invalid and require a ‘fresh and current consent’ from the patient ?.

ICO answer:The GP would be required to gain consent upon every request.

Question: Any consent should be subject to informed consent and valid, a gap of years surely must be contrary to the original informed consent ?.

ICO answer: The third party need to obtain consent from yourself, every time they wish to access your medical records. Requesting consent every time would mean the third party would be complying to the first principle of the DPA. The first principle is about processing fairly and lawfully and with respect to one of the conditions outlined in the act.

To clarify, this means that an organisation must:

have legitimate grounds for collecting and using the personal data; not use the data in ways that have unjustified adverse effects on the individuals concerned; be transparent about how they intend to use the data, and give individuals appropriate privacy notices when collecting their personal data;handle people’s personal data only in ways they would reasonably expect; and make sure they do not do anything unlawful with the data.

Information Commissioner’s Office

That seems very unambiguous.  Once consent is given that consent  has to be timely and relevantly exercised; subsequently, new consent has to be obtained to allow for further use of the data.  So a force is unable to delve into the medical records enclosed in a occupational health file at their whim;  they are unable to approach a GP practice and ask for further disclosure using previous consent without expressly renewing the consent.

Some forces are under the misapprehension that once they have copies of medical records, they own the data and their access to it is then infinite.  This is incorrect.  To give a clear view of this mistaken belief, here is the fallacy of what Avon & Somerset thinks historical consent allows:

Police Medical Pensioners Medical Record Authority Timescale – a Freedom of Information request to Avon and Somerset Constabulary

In respect of Police medical pensioners. When an authority to release medical records from General Practitioners, specialists and consultants in relation to that Officer has been submitted to the Force, how long in timescale does that authority last? Is it days, weeks, months, or years. Please be specific.

Private Our Reference 089/15

Philip Piper Your reference

[1][FOI #249845 email] Date 17 February
2015

Dear Mr Piper

I write in connection with your request for information dated 23^rd
January concerning medical records.

Specifically you asked:

In respect of Police medical pensioners.
When an authority to release medical records from General Practitioners,specialists and consultants in relation to that Officer has been submitted o the Force, how long in timescale does that authority last? Is it days, weeks, months, or years. Please be specific.

The authority lasts until consent is withdrawn.

Yours sincerely

C Quartey

Freedom of Information Officer

Corporate Information Management Department

No it doesn’t Mr/Mrs C Quartey.  The consent lasts until the the records are accessed.  Once that access is completed then the consent expires.  Any decision made without valid permission for those records to be accessed is therefore unsound.

It is quite frightening that a Police Force has such disregard for data belonging to former officers.  What liberties is it taking with data of other members of the public?

An interesting point is raised if the review is unlawful for reasons given on earlier posts.  Here is an extract from the ICO’s website

In brief – what does the Data Protection Act say about handling personal data fairly and lawfully?

The Data Protection Act says that:

Personal data shall be processed fairly and lawfully and, in particular, shall not be processed unless –

(a) at least one of the conditions in Schedule 2 is met, and

(b) in the case of sensitive personal data, at least one of the conditions in Schedule 3 is also met.

This is the first data protection principle. In practice, it means that you must:

  • have legitimate grounds for collecting and using the personal data;

  • not use the data in ways that have unjustified adverse effects on the individuals concerned;

  • be transparent about how you intend to use the data, and give individuals appropriate privacy notices when collecting their personal data;

  • handle people’s personal data only in ways they would reasonably expect; and

  • make sure you do not do anything unlawful with the data.

So if consent is provided and then the force revisits causation and applies apportionment then they are, by default, acting unlawfully.  The corollary is their unlawful action invalidates the consent.  This follows in revisiting previous disclosed medical records – if they try to look at any medical history prior to the last final decision they are contrary to the regulations, and not only is there no implied consent anyway the illegality is a block in the first instance.  The ICO is able to impose severe fines for such breaches.

Do No Harm.

iodpa selected medical practitioner
Do No Harm.

“Primum non nocerum. (First do no harm)”
― Hippocrates

Doctor Philip Johnson is our least favourite medical practitioner.  Single-handedly this man is making the nefarious agenda of the HR department (well, their business manager Wood and her underling Jones) a reality. A gynaecologist by trade, he thinks the case law of the Regulations allows him to have access to the medical records of private citizens since birth. It does no such thing. When he is asked to do his part of a review of a police injury pension he is only entitled to decide whether there has been any alteration in an individual’s degree of disablement since the last time that was decided. Delving into medical records which pre-date that decision is not permitted. It is an abuse of the Police (Injury Benefit) Regulations 2006 and an abuse of his profession.

As far as knowing the law is concerned, the not-so-good doctor Johnson falls short. What he is rather better at is knowing how to behave in a way which has forced mentally ill former officers to seek help from their crisis teams after seeing him. What sort of a doctor is it who carelessly damages the health of a patient?

Johnson has declined, or is unable to make a decision in any of the reviews he has conducted so far. He then takes great delight in trying to blame that state of affairs on the disabled former officers who have, quite rightly, raised concerns about his blunders. This man is a champion of the art of procrastination and a leader in the field of shifting blame. He desperately wants to earn his fee by doing what his paymasters require -which is to manipulate the review process so as to reduce pension payments, yet he he wants to do this with no stain on his character and no possibility of being in the firing line when there comes the inevitable run of cases in the Administrative Court over maladministration of injury pensions.

The tenet of ‘first do no harm’ means only one thing to doctor Johnson – do no harm to oneself and stuff the rest of you.

And you may well ask ‘where is your evidence to make so bold a statement about the ‘good’ doctor?  There is the fact that there are recorded transcripts of  reviews where Dr Johnson is heard stating that he can see no change and that the condition is obviously no better.  But this train of thought is lost when he makes his first report back to HR.  Rather janus-faced, he now insinuates in the report to his paymasters that there may perhaps be change and its up to the HR department to decide how much.  Or how-about the letter Dr Johnson wrote after a review saying there is no change and then 2 weeks later sending a follow-up report, stating in fact there maybe some change, and he needs now to have job profiles to see how much.  The inference is perhaps that Dr Johnson wants to defer the ultimate decision to his bosses in HR and if they aren’t happy with his first view then that view has to change to become the view of HR.   Or last but not least, the classic letter where Dr Johnson says he can’t make a decision and writes as such to both the former officer and HR.  But then still HR claims that its not as though Dr Johnson has decided not to give a decision, it’s just that Dr Johnson has decided to not decide to give a decision.  All these transcripts and letters exist.

Remember these ‘professionals’ are dealing with former officers, injured on duty and with severe disablement to their earning capacity AND who has had no contact from said force for over 12 years.

“Dr Wallington, I presume”

Dr Johnson isn’t alone in his willingness to apply his own tough love to those unfortunate to be in receipt of an IOD award.  Dr Cheng, the resident Met SMP, is of the circular view (and Joseph Heller of Catch-22 fame would grudgingly admire Dr Cheng’s logic) that a band four IOD award is an oxymoron, as to get a band four the former officer should be so debilitated that they shouldn’t even have the capacity to apply for an IOD award in the first place.

Then there is the infamous Dr Broome  of Northumbria.  He who reduced 75 former officers on higher bands to band 1 in a single afternoon.  He is still in post despite all the case-law that names him.

Dr Nightingale is an ubiquitous SMP who seems to focus her work around the Midlands.  She quite often sees herself as an all-powerful judicial authority and demands responses by 16:12 hours exactly or she will record non-compliance in a rather Borg like manner.  This doctor is often mentioned in Pension Ombudsman findings.

And to end the post, I’ll mention Dr Wallington.  Remember NAMF?  Well Dr Wallington is the head of the police medical appeals board (PMAB).  He has overseen more PMABs than anyone in recent times

34242.pdf

This is an HTML version of an attachment to the Freedom of Information request ‘ Police Medical Appeal Board’.

No. of Boards sat on 
from 01/01/2013 – 
Doctor 
GMC Number 
01/01/2015 
Dr David Wallington
2311212
64
Dr Lanre Ogunyemi
4571061
25
Dr Daphne Pereira
1625857
58
Dr Ian Lambert
2271118
12
Dr Prassana Krishnan
4186951
34
Dr Rosemary Waddy
1462942
7
Mr Anthony Robinson
2493684
1
Dr Adil El-Nujumi
3388422
1
Dr Paul Holmes
3604397
1
Mr John Plewes
666422
6
Dr Karim Rajput
4184289
27
Dr John Nehaul
1380264
5
Dr Abdel Salih
3448908
9
Mr Michael Smith
1467693
65
Dr Mark Groom
3124949
26
Dr Michael Forbes
1469217
7
Dr Philip Steller
1582994
9

5.  Please indicate ANY member of the listed PMAB members (lay or medical) who have
attended ANY NAMF (National Attendance Management Forum) meeting in the past three
calenders years to date (that is 2012, 2013, 2014).

Dr David Wallington 

So why does the lead of an independent appeals board attend NAMF meetings?  Is it to ‘first do no harm’?  Or to see how much harm can be done.

What they know …

iodpa Regulation 37
What they know …

Do you know what is in your occupational health?  Could there be a memo. a letter or some handwritten notes that show that the force did not act within their lawful duty when they made the decision to retire you?

It is foolhardy to attend a review they have instigated upon you without knowing what information they have on you beforehand.  A Subject Access Request (SAR) under the Data Protection Act is a method to get full disclosure of personnel records and occupational health files and should be the first action if ever called to a review of your injury on  duty award

https://ico.org.uk/for-organisations/guide-to-data-protection/principle-6-rights/subject-access-request/

Once submitted with a form of identification (such as a photocopy of a passport)  and a £10 cheque, you should receive within 40 days the required information. Then you will not be entering the process blind.  Indeed there may be something within the file that indicates that any previous decisions were unsound.

A template letter can be found here:

https://ico.org.uk/for-the-public/personal-information/

There is nothing stopping you from putting in a SAR once notified they are starting a review process and then another SAR once the review has completed.  The second request should specify all handwritten notes made by SMP during the assessment.

You might also discover that they have destroyed your personnel file under some internal  retention policy.  If so it can be argued how they are going to compare your skill set when they have no record of what skills you gained during your service.

The function of the SMP

iodpa selected medical practitioner, smp
The function of the SMP

What does a duly qualified medical practitioner (selected medical practitioner or ‘SMP’) bring to the table?  Firstly it is peremptory that any final decision made under Police Injury Benefit Regulations 2006 is a medical decision.  It is not a legal question or an occupational assessment – it is a medical question and therefore can only be answered by a medical doctor.  ‘Suitably qualified’ has no specific definition under the regulations other than the implied possession of  medical degree so a general practitioner or a surgeon could perform the task.  However it is the praxis of police pension authorities to have interpreted the suitable qualification as being a member of the Faculty of Occupational Medicine.

This hugely narrows the pool of suitable potential SMPs.  Forces are deliberately hiring a specific type of medical professional.  Quite often the SMP belongs to an umbrella  limited company that contracts the occupational health doctors back to several forces in a consortium pact.  This insular arrangement is amplified by use of the NAMF’s white list of approved providers.  An otherwise excellent medical practitioner is barred from working as a SMP if not a member of this closed club, further adding to the erosion of the independence of SMPs.

But what is the remit of a SMP?  Firstly the SMP is bound by the ethics of the GMC guidance which determines how its members are allowed to act in such positions (Confidentiality_disclosing_info_2009.pdf.)  The GMC guidelines dictate that any person the doctor has access to in such an event is still their ‘patient’ and it is irrelevant whether they are giving therapeutic treatment or not – as their patient, the well-being of the person is their first concern.  In partnership with their medical duty, there is the legal duty of the SMP to abide by the statutory instrument  enacted by the regulations. So the SMP assesses the disability and it’s effect on earning capacity together with factors such as rank and length of service. The SMP then makes the award which falls into four bands (Band one is the least).  The bands are simplified into 4 to make it easier for a medical expert (not a HR manager) to decide a suitable degree of disability.  When some SMPs use rounding to 2 decimal places in order to put an IOD retiree into a lower threshold (49.95%), they clearly haven’t taken the ‘decision in the round’.  This was talked about in the post concerning the PAEM & Bad maths.  As mentioned, although the SMP is employed by the Police Authority/Commissioner/Force, the function should be an independent one.

On the original decision (when the award is first given) the SMP may ask for full medical records as well as accompanying report from specialists.  There is no given power that enables the SMP to demand things – indeed no legal powers are inferred on the role of the SMP – he/she can ask but accordingly there is no obligation to acquiesce.   They are not coroners with common law or statute powers – the statutory role is to answer a question – the referred question; they are not empowered in anyway to act other than as a doctor.  Of course, the SMP is entitled to make an informed  judgement on the available evidence and non-cooperation does allow the SMP to infer something.  The final decision is the SMP’s alone to make.  The procedure should be an evidenced based approached.  In injury cases in particular it is important that the SMP should satisfy him or herself that the evidence presented about the circumstances surrounding the injury and the disablement in question is not accepted uncritically from either party. It is for the SMP to test and weigh the evidence given in the light of the other evidence provided and in the light of his or her own medical knowledge and reasoning. In deciding whether a statement put to him or her as a matter of fact is to be accepted as such, after having duly tested and weighed it, the SMP should apply the balance of probabilities and not a higher evidential test.

Such questions the SMP considers are (but not exclusive of):

  • The Regulations specify that whether the injury includes any injury or disease, whether of body or mind
  • That disablement is deemed to be the result of an injury if the injury has caused or substantially contributed to the disablement
  • It is necessary to establish a direct causal link between the permanent disablement and service as a police officer:
  • In cases where the permanent disablement through injury was the result of a single, significant incident the question will be a relatively simple one – was the injury received in the execution of duty
  • An injury does not have to be received though a single, significant incident; where no single moment of injury can be identified.  The question for the SMP is whether the permanent disablement through injury was caused by, or received in, the execution of duty as opposed to domestic or other circumstances not related to police duty – bearing in mind the following points:
    • police duty should not be given a narrow meaning; it relates to all aspects of the officer’s work;
    • the Court of Appeal has held that stress-related illness through exposure to police disciplinary proceedings does not count as an injury received in the execution of duty;
    • police duty does not extend to a sporting activity for the police while not carried out on duty, unless where the injury was due to the officer being known to be a constable.
  • There may be an issue as to whether there was a single injury or more than one injury which contributed to the disablement. This can affect the calculation of degree or disablement where a relevant injury was not received in the execution of duty. Where this is relevant the SMP’s findings as to whether there is one injury or more than injury should be clearly stated (apportionment).

If the decision is not accepted it can be challenged within 28 days and an appeal lodge with the Police Medical Appeals Board.  This a panel of 3 medical specialists on a Home Office list.  Before Laws V PMAB historically a PMAB panel rubber-stamped the decision of the SMP using the HO guidance 46/2004 – an example of Home Office officials keeping the bien pensant stance and ensuring the Home Office guidance is followed to the letter (despite the subsequent withdrawal due to the guidance being unlawful).

The role of the SMP in a review situation is the sole question of substantial alteration of the degree of disablement (earning capacity not physical disability) since the last final decision.  Has the medical condition substantial improved or substantial deteriorated?  Is there jobs available to the individual that were not available at the last final decision?

A review therefore should be a benign event.  As circumstance dictate (and not routinely), the submission of medical records, partially disclosed of dates between the last decision and the date of the review.  A quick face to face meeting IF and ONLY if there are points in the medical notes that need clarifying.  If there is no evidence of change then the person should not even be put in front of a SMP.  That’s it.  Nothing more.  If the SMP acts like a Gestapo officer, forensically examining medical history and interrogating the retiree for close to 2 hours during a review then it is obvious that there is an agenda.  How will other IODs react when they get called?  Defensively, no doubt.  Where’s the motivation to engage in a demeaning and unlawful process.

There is no excuse for any review to last from May 2014 and still be continuing in mid-March 2015.  That suggests that the police pension authority and the SMP are considering facts that are beyond their legal duty.  Rather like Avon & Somerset’s current reviews…

SMP has left disabled former officers adrift…

iodpa Federation, HR, selected medical practitioner
SMP has left disabled former officers adrift…

Allegedly Dr Philip Johnson is no longer working for Avon & Somerset Constabulary as their nominated Selected Medical Practitioner.  Given there are 15 band 4s, under amoral intent referred to Dr Johnson for his consideration of substantial alteration to their medical condition, who saw said SMP over 3 months ago and still not received a decision, it is a shocking indictment of the arrogance of Avon & Somerset Constabulary.

So, what are the options open to the police pension authority now?

They have an obligation, indeed a legal duty to complete the review process. There is nothing in the Regulations which covers the circumstances where a SMP refuses to decide or can’t decide. The Regulations say that the PPA ‘shall refer for decision’ the statutory question of degree of disablement. Having referred it, and having got no decision, then the process is complete and it is shocking that severely disabled civilians have had no letter explaining the delay; no update, nothing but total silence, as if the HR department at Portishead are pretending as if nothing has happened.  At the least, the police pension authority and those delegated in its administration are culpable of serious maladministration; at most there is a case to be answered for Misfeasance in a public office.

A review is a highly stressful life event and this has affected the lives of those concerned since 29th May 2014.  Almost a year.  Some of the 16 have had serious relapses of their mental and physical health others have had surgical operations.  Why is the federation not asking questions?  Why is the force being so opaque?  The answers will be heard.