A Written Warning May Be the First Step.
Where a breach is capable of being corrected and is not considered sufficiently serious to justify immediate suspension, MedCo may issue a written warning. The warning should identify the problem and explain what the expert is required to do to resolve it. This may involve correcting inaccurate registration information, improving administrative procedures, uploading missing case data or providing evidence that a particular requirement is now being followed.
A warning should not be treated as an informal reminder. Failure to complete the required action may cause the matter to escalate, particularly where the expert does not respond within the stated period or cannot demonstrate that the problem has been addressed.
Under the current Direct Medical Expert User Agreement, MedCo may move directly to suspension where it considers that a written warning would not be appropriate.
Failure to Complete Annual CPD.
Continuing professional development is a central condition of MedCo accreditation. Once an expert completes the initial accreditation process, they enter the annual CPD programme. For the 2026–2027 academic year, MedCo has confirmed a requirement of six hours, with the academic year running from 1 June to 31 May.
An expert who does not complete the required hours will have their MedCo status suspended. During that period, the expert will no longer receive instructions to undertake first fixed-cost medical reports through the MedCo system.
The suspension is lifted only when the outstanding hours from the previous academic year have been completed. Those additional hours do not count towards the current year’s requirement, so the expert may need to address the shortfall while also keeping up with the new CPD programme.
The consequences become more serious if the shortfall remains outstanding. MedCo states that an expert who fails to complete the missing hours within six months of the end of the relevant academic year will be withdrawn from the system. Withdrawal is not simply treated as a temporary suspension. The expert must apply again and restart the full initial accreditation process.
An Unsuccessful Audit.
MedCo can audit medical experts to assess whether their procedures, systems and working practices comply with the User Agreement, MedCo Rules, examination guidance and other applicable standards.
An audit does not necessarily end with a simple pass or fail. MedCo may conclude that the expert is broadly compliant but must complete recommendations by specified dates. The expert may be required to introduce new procedures, correct weaknesses and provide evidence showing that the changes have been implemented.
More serious findings can result in an unsuccessful audit. MedCo may suspend the expert’s access to the database for a defined period, require a later re-audit or determine that the findings are sufficiently serious to justify termination of the agreement.
Cooperation is also important. An expert who fails to provide information, refuses to engage with the auditors or delays the process may be suspended until they cooperate. The responsibility rests with the expert to supply sufficient evidence of compliance; it is not for the audit team to reconstruct missing records or repeatedly chase responses.
Examination Practices May Be Reviewed.
MedCo expects examinations to be meaningful rather than treated as a high-volume administrative exercise. Its examination guidelines currently refer to a maximum of 35 examinations in one day and a minimum of 15 minutes of face-to-face time with each claimant. These figures are described as guidelines rather than targets.
Case data uploaded to MedCo includes information about examination dates and duration. Where the data suggests that an expert has regularly exceeded the guidelines, MedCo may request an explanation or refer the matter for peer review. Occasional departure from a guideline may have a reasonable explanation. Regular and consistent departures, particularly where the expert cannot provide a satisfactory account, may lead to suspension or termination.
The underlying concern is report quality. An examination that is too brief or conducted in unsuitable conditions may raise questions about whether the expert obtained an adequate history, considered relevant medical information and had a proper basis for the conclusions expressed.
Data and Administrative Failures.
Experts must accurately upload required case data within the applicable timescales, even during certain periods of suspension. They must also maintain appropriate records, cooperate with reasonable requests for information and ensure that their registration details remain accurate.
Administrative failures may appear less serious than a poor-quality report, but repeated inaccuracies can prevent MedCo from monitoring the system effectively. Missing examination data, unreliable dates, inaccurate practising addresses or a failure to disclose relevant financial links can therefore become compliance matters.
Experts must also maintain appropriate professional registration and insurance. Loss of the relevant professional registration can result in accredited status being withdrawn. Failure to pay applicable MedCo charges may also lead to suspension or termination if the position is not corrected following notice.
Suspension Prevents New MedCo Instructions.
Suspension means that the expert cannot operate normally through the MedCo system or be selected for new qualifying instructions. The precise scope and length of the suspension will depend on the reason it was imposed and what MedCo requires before it will be lifted. The expert may need to complete missing training, provide documents, implement audit recommendations or undergo a re-audit. Suspension should therefore be viewed as a period in which the expert must demonstrate that the underlying problem has genuinely been corrected.
It can also have wider commercial consequences. Medical reporting organisations and instructing firms may be unwilling or unable to allocate further MedCo work to an expert whose status is not operational. Even after reinstatement, a history of non-compliance may affect professional confidence and working relationships.
Termination and Withdrawal.
Termination is reserved for more serious circumstances, including material breaches that cannot adequately be dealt with through a warning or suspension. Once the agreement is terminated, the expert loses access to the MedCo database, subject to any limited access MedCo permits for outstanding data obligations.
Re-registration is not automatic. The MedCo Rules state that an expert whose agreement has been terminated requires permission from the MedCo Board before registering again. The Board may refuse to consider a new application for a specified period, which could be indefinite depending on the reason for termination.
This is different from a short suspension that can be lifted once a defined problem has been remedied.
Referral to a Professional Regulator.
Some breaches may extend beyond MedCo’s own requirements. Dishonesty, misleading information, serious confidentiality failures, poor professional conduct or concerns about clinical competence may justify referral to another organisation.
MedCo’s Ethics Policy states that investigations may lead to suspension or termination and that referrals may be made to bodies including the GMC, HCPC, Information Commissioner’s Office and Insurance Fraud Bureau. Such a referral could have consequences beyond the expert’s ability to undertake MedCo work. It may affect their wider professional registration, clinical practice, reputation and indemnity arrangements.
Responding to a Compliance Concern.
An expert who receives a warning, audit finding or request for information should respond promptly and transparently. Ignoring correspondence, providing incomplete evidence or attempting to minimise an identified problem may make the position worse.
Where a genuine failure has occurred, the strongest response is usually to acknowledge it, identify its cause and provide a realistic corrective plan supported by evidence. If the expert disputes the finding, the disagreement should be raised through the applicable escalation procedure and within the required time limit.
MedCo compliance should form part of the expert’s everyday practice rather than being considered only when an audit is announced. Accreditation, accurate data, suitable examinations, ongoing training and ethical conduct all contribute to the reliability of the reporting system. A minor and promptly corrected error may result only in remedial action. Repeated, serious or dishonest non-compliance can remove the expert from MedCo work altogether.
