A Written Warning May Be the First Step.
Where MedCo considers a breach capable of correction and not serious enough to justify immediate suspension, it may issue a written warning.
The warning should identify the concern and explain what action the expert needs to take. This may involve correcting inaccurate registration information, improving administrative procedures, uploading missing case data or providing evidence that the expert now follows the relevant requirement.
Experts should not treat a warning as an informal reminder. Failure to complete the required action may cause MedCo to escalate the matter, particularly where the expert misses the stated deadline or cannot demonstrate that they have resolved the problem.
Under the current Direct Medical Expert User Agreement, MedCo may move directly to suspension where it considers a written warning inappropriate.
Failure to Complete Annual CPD.
Continuing professional development forms a central part of MedCo accreditation.
After completing the initial accreditation process, an expert enters the annual CPD programme. For the 2026–2027 academic year, MedCo requires six hours of CPD between 1 June and 31 May.
If an expert fails to complete the required hours, MedCo will suspend their status. During the suspension, the expert will no longer receive instructions for first fixed-cost medical reports through the MedCo system.
To regain active status, the expert must complete the outstanding CPD from the previous academic year. Those additional hours do not count towards the current year’s requirement, so the expert may need to address the previous shortfall while also completing the new annual programme.
The consequences become more serious when an expert allows the shortfall to continue. If the expert fails to complete the missing hours within six months of the end of the relevant academic year, MedCo can withdraw them from the system.
At that point, the expert cannot simply reactivate their previous accreditation. They must apply again and repeat the full initial accreditation process.
An Unsuccessful Audit.
MedCo can audit medical experts to assess whether their systems, procedures and working practices comply with the User Agreement, MedCo Rules, examination guidance and other applicable standards.
An audit does not always produce a simple pass or fail result. MedCo may conclude that the expert broadly complies with the requirements but still needs to make improvements within specified timescales.
The expert may need to introduce new procedures, correct weaknesses and provide evidence showing that the necessary changes have taken place.
More serious findings can lead to an unsuccessful audit. MedCo may suspend access to the database, require a later re-audit or decide that the findings justify termination of the agreement.
Cooperation also matters. If an expert fails to provide information, refuses to engage with auditors or repeatedly delays the process, MedCo may suspend them until they cooperate.
The expert carries responsibility for demonstrating compliance. The audit team should not have to reconstruct missing records or repeatedly chase information that the expert should already maintain.
Examination Practices May Be Reviewed.
MedCo expects experts to conduct meaningful medical assessments rather than treat examinations as a high-volume administrative exercise.
Current examination guidelines refer to a maximum of thirty-five examinations in one day and at least 15 minutes of face-to-face time with each claimant. MedCo describes these figures as guidelines rather than targets.
Case data submitted to MedCo includes examination dates and duration. If that data indicates that an expert regularly exceeds the guidelines, MedCo may ask for an explanation or refer the issue for peer review.
An occasional departure may have a reasonable explanation. However, repeated departures without satisfactory justification can result in suspension or termination.
The main concern relates to report quality. If an expert spends too little time with a claimant or conducts the assessment in unsuitable conditions, questions may arise about whether they obtained an adequate history, considered the relevant medical information and had a sound basis for their conclusions.
Data and Administrative Failures.
Experts must upload required case data accurately and within the applicable timescales. These responsibilities may continue during certain periods of suspension.
They must also maintain appropriate records, respond to reasonable requests for information and keep their registration details accurate.
Administrative failures may appear less serious than problems involving a medical opinion, but repeated inaccuracies can interfere with MedCo’s ability to monitor the reporting system.
Missing examination data, unreliable dates, inaccurate practising addresses or failure to disclose relevant financial links can therefore become significant compliance concerns.
Experts must also maintain appropriate professional registration and insurance. If an expert loses the professional registration required for MedCo work, MedCo may withdraw their accredited status.
Failure to pay MedCo charges may also lead to suspension or termination where the expert does not resolve the position after receiving notice.
Suspension Prevents New MedCo Instructions.
Suspension prevents an expert from operating normally through the MedCo system and from receiving new qualifying instructions.
The reason for the suspension will determine its length and what the expert must do before MedCo restores full access.
The expert may need to complete missing training, provide documents, implement audit recommendations or undergo another audit. During this period, the expert must show that they have genuinely corrected the underlying problem.
Suspension may also create wider commercial consequences. Medical reporting organisations and instructing firms may be unable or unwilling to allocate further MedCo work while the expert’s status remains inactive.
Even after reinstatement, repeated compliance problems may affect professional confidence and future working relationships.
Termination and Withdrawal.
MedCo may terminate an agreement where it identifies a serious breach that a warning or temporary suspension cannot adequately address.
Once MedCo terminates the agreement, the expert loses normal access to the database, although MedCo may allow limited access where outstanding data obligations remain.
Re-registration does not happen automatically.
An expert whose agreement has ended through termination must obtain permission from the MedCo Board before registering again. The Board may also refuse to consider a new application for a specified period. Depending on the circumstances, that period may extend indefinitely.
This differs significantly from a short suspension, where the expert can usually regain active status after correcting a defined problem.
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 allows investigations to result in suspension or termination and permits referrals to organisations such as the GMC, HCPC, Information Commissioner’s Office and Insurance Fraud Bureau.
Such a referral can have consequences well beyond MedCo work. It may affect the expert’s professional registration, wider clinical practice, reputation and indemnity arrangements.
The seriousness of this possibility means that experts should treat ethical and professional concerns as more than administrative compliance issues.
Responding to a Compliance Concern.
An expert who receives a warning, audit finding or request for information should respond promptly and openly.
Ignoring correspondence, providing incomplete evidence or attempting to minimise an identified problem may increase the seriousness of the matter.
Where a genuine failure has occurred, the expert should acknowledge it, identify its cause and set out a realistic corrective plan. They should also provide evidence showing what they have done to prevent the problem from recurring.
If the expert disagrees with MedCo’s finding, they should raise the disagreement through the appropriate escalation process and within the required time.
Experts should make MedCo compliance part of their everyday working practices rather than thinking about it only when an audit or complaint occurs.
Accurate data, appropriate examinations, continuing training, sound administration and professional conduct all support the reliability of the reporting system.
A minor error that the expert identifies and corrects promptly may result only in remedial action. Repeated, serious or dishonest non-compliance can ultimately bring an expert’s MedCo work to an end.
