Two nations separated by a common goal: comparing the severity of penalties against doctors at disciplinary hearings in the United States and United Kingdom

Gallagher, Cathal Thomas and Allensworth, Rebecca Haw (2025) Two nations separated by a common goal: comparing the severity of penalties against doctors at disciplinary hearings in the United States and United Kingdom. International Journal of Healthcare Management. ISSN 2047-9700
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Superficially, the disciplinary functions for doctors in the United States and United Kingdom are very similar. Complaints are received, parsed and investigated before being adjudicated upon at a hearing. To compare the severity of disciplinary outcomes for doctors accused of misconduct in the US and UK, respectively, disciplinary decisions against doctors from 1 January 2014 through 31 December 2023 were quantitatively analysed. In total, 25,726 cases were included in the analysis, of which 93% occurred in the US and 7% in the UK. Of the cases heard by US State Boards, only 28% resulted in a severe sanction compared to 83% of those heard by the MPTS. The UK system of discipline is more appropriately harsh, and the American system would benefit from reform in line with the UK's post-Shipman-Inquiry model. Disciplinary functions should be separated from boards that govern licensing and ethics to ensure impartiality and avoid conflicts of interest. The UK provides a model with mixed-member panels, unlike US boards, which are typically dominated by professionals from the same field. While some level of self-regulation is inherent to being a profession, the current extent in the US is excessive.


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