Freedom of Information request Outsourced Radiology Reporting Arrangements

Freedom of Information Request – Ref: FOI 178-2026

Thank you for your recent Freedom of Information request. Please find our response below.

You asked:

We write in our capacity as solicitors specialising in medical negligence and patient safety issues and write in connection with matters arising from radiology reporting services provided to patients of your Trust. We make this request pursuant to the Freedom of Information Act 2000 (FOIA) and, where applicable, the Environmental Information Regulations 2004.

We respectfully draw the Trust’s attention to its statutory obligations under section 1(1) FOIA to confirm whether the requested information is held and, if so, to provide it to us. We ask that the Trust address each question individually and provide the information in a clear and organised format.

Notice regarding exemptions

Before setting out our questions, we make the following observations regarding commonly cited exemptions, which we respectfully submit do not apply to the requests below:

Section 12 (Cost Limit): Each question below is drafted to be specific, time-limited and focused. The information sought is operational data which ought to be capable of retrieval from existing records systems without undue burden. We respectfully invite the Trust, before claiming this exemption, to engage constructively with a narrowed or reformulated version of any question it considers disproportionate, in accordance with the ICO’s guidance on exceeding the cost limit.

Section 22 (Future Publication): We do not accept that the public interest in deferring disclosure of information relating to patient safety and clinical governance outweighs the immediate public interest in transparency. We request that the Trust not rely on this exemption in relation to information concerning serious incidents, audit results or complaint data.

Section 36 (Prejudice to Conduct of Public Affairs): Given the strong public interest in NHS transparency and patient safety accountability — recognised by the Information Commissioner and the Upper Tribunal — we submit that this exemption is unlikely to be engaged or, if engaged, that the public interest in disclosure substantially outweighs any prejudice. The qualified person must apply genuine and specific reasoning, not a generalised assertion.

Section 41 (Information Provided in Confidence): Where commercial contracts are in issue, we acknowledge that individual commercially sensitive clauses may properly be redacted. However, the existence of a contract, its general scope, KPIs, SLAs and patient safety provisions do not, in our submission, constitute information imparted in confidence in a manner actionable at law, particularly where those arrangements directly affect patient care. We invite the Trust to apply any redactions narrowly and to provide a schedule of redactions with reasons, rather than withholding entire documents.

We respectfully ask that, before declining to answer any question, the Trust considers whether it would be proportionate to reformulate, narrow or provide partial information, consistent with its duty to provide advice and assistance under section 16 FOIA.

Part A: Outsourcing arrangements

Please answer the following questions in relation to the six complete financial years ending 31 March 2026 (i.e. 2020/21 to 2025/26) unless otherwise stated.

A1. Identity of Outsourced Providers

Please provide a list identifying each external or outsourced radiology reporting provider engaged by the Trust during the relevant period, stating for each:

(a) the company name and registered address;

(b) the contract commencement and expiry or termination date; and

(c) the imaging modalities covered (for example, MRI, CT, plain film/X-ray, ultrasound, nuclear medicine, or other). Where a single provider covered multiple modalities under separate arrangements, please list each separately.

A2. Annual Expenditure on Outsourced Reporting

Please state the total actual expenditure incurred by the Trust on outsourced radiology reporting services for each of the six financial years specified above, expressed as an annual figure. Please confirm whether the figures provided are inclusive or exclusive of VAT.

A3. Volume Split: Outsourced versus In-House Reporting

Please provide, for each of the six financial years specified above, the total number of radiology reports generated and the proportion fulfilled by

(a) outsourced providers

(b) in-house NHS radiologists, expressed both as absolute numbers and as a percentage of total volume. Where data is held by modality type, please provide the breakdown accordingly.

PART B: GOVERNANCE AND QUALITY ASSURANCE

B1. Quality Assurance Policies

Please describe the quality assurance processes and standards applied by the Trust to radiology reports produced by outsourced providers, including any minimum reporting standards, turnaround time requirements, and escalation procedures. Please provide copies of any written policies, protocols or frameworks currently in force, or those in force at any time during the relevant period.

B2. Audit of Outsourced Reporting Accuracy

Please describe how the Trust audits or otherwise monitors the clinical accuracy and quality of reports produced by outsourced providers. Please provide copies of the findings, outcomes and recommendations of any such audits or quality reviews carried out during the relevant period, including any discrepancy rates identified.

B3. Registration and Professional Standards Requirements

Please confirm whether the Trust requires, as a contractual condition or as a matter of policy, that all radiologists engaged by outsourced providers hold:

(a) full registration with the General Medical Council (GMC) with a licence to practise; and/or

(b) Fellowship of the Royal College of Radiologists (FRCR) or equivalent qualification.

If different or lesser requirements are applied, please specify what standards are required and on what basis.

B4. Verification of Individual Radiologist Competency

Please describe the process by which the Trust verifies, at the time of contract award and on an ongoing basis, the qualifications, subspecialty expertise, revalidation status and clinical competency of the individual radiologists engaged by outsourced providers to report on Trust patients’ imaging. Please include details of any approved list, credential framework, or sign-off process used.

PART C: PATIENT SAFETY INCIDENTS AND REPORTING DISCREPANCIES

C1. Serious Incidents and Patient Safety Events

For each of the six financial years specified in Part A, please state the total number of Serious Incidents (SIs) or patient safety events recorded on the Trust’s incident reporting system (including Datix or any successor system) in which a radiology report was identified as a causative, contributory or associated factor, as follows:

(a) incidents involving a report produced by an outsourced provider; and

(b) incidents involving a report produced by an in-house radiologist.

For each category, please provide the year of occurrence, the incident category or classification applied, and the recorded outcome or learning.

C2. Peer Review Discrepancy Findings

Please confirm the number of significant or clinically relevant discrepancy findings identified through peer review, retrospective review, or multi-disciplinary team processes in relation to outsourced radiology reports, assessed by financial year and by provider name.

A ‘significant discrepancy’ should be understood to mean a finding that resulted in, or had the potential to result in a change in patient management.

Please also provide the equivalent figures for in-house reporting for comparison, where held.

C3. Contract Suspensions or Terminations on Patient Safety Grounds

Has the Trust at any time suspended the use of, or terminated a contract with, any outsourced radiology provider due to concerns about patient safety, clinical quality or reporting standards? If so, please provide for each instance:

(a) the name of the provider concerned;

(b) the date of suspension or termination;

(c) the stated reason(s); and

(d) any action taken to notify or review the care of patients whose imaging was reported by that provider during the period of concern.

Part D: Complaints

D1. Formal Complaints Relating to Radiology Reporting

Please state the total number of formal complaints received by the Trust under the NHS Complaints Procedure (as set out in the Local Authority Social Services and National Health Service Complaints (England) Regulations 2009) during each of the six financial years specified in Part A, which wholly or in part concerned radiology reporting, as to:

(a) complaints relating to reports produced by outsourced providers; and

(b) complaints relating to reports produced by in-house radiologists.

Please also confirm the number of those complaints that were upheld or partially upheld.

Part E: Clinical negligence claims and litigation

E1. Claims Involving Radiology Reporting

Please state the total number of clinical negligence claims notified to the Trust (whether under the Clinical Negligence Scheme for Trusts, NHS Resolution, or otherwise) during the six financial years specified in Part A, in which a radiology report was identified as a causative or contributory factor, as to:

(a) claims involving a report produced by an outsourced provider; and

(b) claims involving a report produced by an in-house radiologist.

Please note that we do not seek details of individual claims or any information from which a living individual could be identified.

E2. Value of Settled Claims

Please state the total quantum of damages and costs paid in respect of settled clinical negligence claims during the six financial years specified in Part A, where

(a) outsourced radiology reporting and

(b) in-house radiology reporting was identified as a causative or contributory factor.

Where the Trust does not hold this information, please indicate whether it is held by NHS Resolution and provide signposting accordingly.

E3. Referring Clinical Specialties in Outsourced Radiology Claims

In respect of clinical negligence claims involving outsourced radiology as a causative or contributory factor (as identified in question E1(a) above), please identify the clinical specialties that were the primary referring specialty, ranked in order of frequency. This information is sought in aggregate and anonymised form only.

Part F: Clinical integration and communication protocols

F1. Access to Prior Imaging and Clinical Information

Please describe the protocols and systems in place to ensure that outsourced radiologists, at the time of reporting, have access to:

(a) prior and comparator imaging held by the Trust or available via national image-sharing infrastructure;

(b) relevant clinical history and indication for the examination; and

(c) electronic patient records or relevant clinical documentation. Please provide copies of any written protocols or guidance currently in force.

F2. Communication of Urgent and Critical Findings

Please describe the Trust’s policy and procedure for the communication of urgent or critical imaging findings from outsourced reporting providers to the responsible clinical team, including:

(a) the Trust’s target timeframe for communication of a critical result;

(b) the actual recorded average or median timeframe for such communication during the relevant period, where data is held; and

(c) the escalation pathway if communication is not acknowledged within the target timeframe.

F3. Clinician Query and Clarification Process

Please describe the process available to a referring clinician who wishes to query, seek clarification on, or formally dispute the content of a report produced by an outsourced radiologist. Please specify any timeframe within which the outsourced provider is required to respond, and how such queries are documented.

Part G: Oversight, contractual standards and regulatory findings

G1. Key Performance Indicators and Service Level Agreements

Please provide copies of the Key Performance Indicators (KPIs) and Service Level Agreement (SLA) provisions contained within written contracts between the Trust and each outsourced radiology provider during the relevant period.

We acknowledge that certain commercially sensitive pricing provisions may be appropriately redacted; however, we request that KPIs, quality standards, discrepancy thresholds, turnaround times and patient safety provisions be disclosed in full. We invite the Trust to provide a schedule of any redactions made, with brief reasons.

G2. NHS Resolution and Regulatory Recommendations

Has NHS Resolution, the Care Quality Commission, NHS England, the Royal College of Radiologists, or any other regulatory or advisory body made any formal recommendations, findings, risk notices or improvement notices in relation to the Trust’s use of outsourced radiology reporting at any time during the relevant period? If so, please provide details including the date, the body concerned, the nature of any findings, and the Trust’s response or actions taken.

G3. Named Clinical and Managerial Responsibility

Please provide the job titles (but not the personal names) of the individual(s) who hold named clinical and managerial responsibility within the Trust for:

(a) oversight of the quality and safety of outsourced radiology reporting; and

(b) contract management and performance monitoring of outsourced radiology providers.

G4. Policies Governing Reporting Standards

Please provide copies of any policies, frameworks or standard operating procedures in place to ensure that outsourced radiology reporting is carried out to the required clinical and professional standard, including any minimum competency requirements, escalation policies, and processes for addressing identified underperformance.

G5. Participation in MDT and Discrepancy Meetings

Are outsourced radiologists required or invited to participate in multi-disciplinary team (MDT) meetings, radiology discrepancy meetings, morbidity and mortality meetings, or internal clinical investigations involving their reports?

Please describe any such arrangements and the policy basis for them.

G6. Process for Addressing Identified Errors

Where a clinically significant discrepancy or error is identified in a report produced by an outsourced radiology provider, please describe:

(a) the process by which the Trust notifies the outsourced provider of the finding;

(b) the process for reviewing whether other patients reported by the same radiologist may be affected;

(c) any duty of candour obligations engaged and how they are discharged; and

(d) the mechanism for feeding findings back into the quality assurance framework.

Compliance and response

We request that the Trust acknowledges receipt of this request promptly and provides its response within the statutory period of 20 working days from the date of receipt, in accordance with section 10 FOIA.

If the Trust considers that any question requires clarification before it can be answered, we respectfully ask that it contacts us at the earliest opportunity rather than allowing the statutory deadline to expire. We are available to discuss the scope of any request and to assist in narrowing or clarifying any question.

If the Trust intends to rely on any exemption in respect of any part of this request, we ask that it:

(a) identify clearly which question or part of a question is affected;

(b) specify the exemption(s) relied upon;

(c) where a qualified exemption is engaged, set out the public interest balancing exercise applied; and

(d) confirm whether the information is held.

A blanket or non-specific claim of exemption will not be regarded as compliant with the Trust’s obligations under FOIA.

Where information is provided in redacted form, please provide a schedule of redactions identifying what has been withheld and the statutory basis for doing so.

We draw attention to the right to request an internal review under section 50 FOIA and to refer any complaint to the Information Commissioner’s Office if the Trust fails to comply or relies on exemptions we consider improperly applied

Yours faithfully

Our response:

Next steps:

Should you have any queries in relation to our response, please do not hesitate to contact us. If you are unhappy with the response you have received in relation to your request and wish to ask us to review our response, you should write to:

Louise Moss
Head of Legal Services / Associate Director of Corporate Governance
c/o Gloucestershire Health and Care NHS Foundation Trust
Edward Jenner Court
1010 Pioneer Avenue
Gloucester Business Park
Brockworth, GL3 4AW
E-mail: louise.moss@ghc.nhs.uk

If you are not content with the outcome of any review, you may apply directly to the Information Commissioner’s Office (ICO) for further advice/guidance. Generally, the ICO will not consider your case unless you have exhausted your enquiries with the Trust which should include considering the use of the Trust’s formal complaints procedure. The ICO can be contacted at: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.