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Medical & aesthetics

GP state indemnity (CNSGP) and private work, explained

The Clinical Negligence Scheme for General Practice (CNSGP) is the state indemnity scheme that meets clinical negligence claims arising from NHS general practice in England since 1 April 2019. It matters for insurance because it stops at the edge of NHS work: private patients, aesthetics, medico-legal reports, inquests and regulatory proceedings all fall outside it, yet the law still requires a licensed doctor to hold appropriate cover for everything they do.

In short

CNSGP was set up by the National Health Service (Clinical Negligence Scheme for General Practice) Regulations 2019 and is administered by NHS Resolution for the Secretary of State. It automatically covers GPs and practice staff in England, without a subscription, for clinical negligence in NHS primary medical and ancillary services where the act or omission was on or after 1 April 2019. NHS Resolution says private practice is not covered, nor are regulatory proceedings, inquests, complaints without a claim, or non-clinical liabilities. Section 44C of the Medical Act 1983 requires licensed doctors to hold appropriate cover for their practice, so those gaps still need filling.

What CNSGP is and how it works

Last reviewed 7 October 2026 by the Apex professional indemnity team.

CNSGP is a statutory scheme, not an insurance policy you buy. The National Health Service (Clinical Negligence Scheme for General Practice) Regulations 2019 (SI 2019/334) were made under section 71 of the National Health Service Act 2006, came into force on 1 April 2019 and apply only to services provided as part of the NHS in England.

What sits outside the scheme

NHS Resolution’s CNSGP FAQ is direct: “Any activities relating to your private practice are not covered”, and you need suitable indemnity or insurance for that work. It also lists these as outside the scheme:

The GMC says the same from the regulator’s side: NHS indemnity schemes cover clinical negligence claims only, and doctors need cover elsewhere for non-NHS or private work, inquests, and regulatory and disciplinary proceedings. The GMC adds that private work needs adequate and appropriate cover even when it takes place on NHS premises.

These examples are illustrative. A GP partner who runs a Saturday private menopause clinic in the surgery building, a salaried GP who gives aesthetic injectables at a clinic, and a locum who writes paid reports for solicitors are all doing work CNSGP does not reach.

Covered, not covered, and where cover usually comes from

This is a general map based on NHS Resolution and GMC guidance. Each arrangement depends on its own terms.

ActivityUnder CNSGP?Where cover usually comes from
NHS GMS, PMS or APMS patient care in England, incident on or after 1 April 2019Yes, for clinical negligenceCNSGP, automatically
Private patients and private clinics, including aestheticsNoA medical defence organisation or a medical malpractice or treatment risks insurance policy
Paid reports, insurance medicals, medico-legal workNo, unless directly tied to a clinical negligence claimDefence organisation membership or professional indemnity insurance that names this work
GMC investigations and disciplinary hearingsNoDefence organisation support or a policy with regulatory legal costs cover
Inquests and complaints with no compensation claimNoDefence organisation support or a policy section for these costs
Employment disputes, defamation, other non-clinical liabilityNoSeparate covers, such as employment practices or the practice’s liability policies
Incidents before 1 April 2019NoThe existing liabilities scheme, if transferred, or the doctor’s former provider

The legal duty: Medical Act 1983, section 44C

A licensed doctor who practises must have an indemnity arrangement in force that provides appropriate cover for practising. That is section 44C(1) of the Medical Act 1983, in its current form since 17 July 2014.

The GMC says you need cover for the full scope of your practice, that it can check a practising doctor’s cover, and that responsible officers often check through the appraisal probity statement. For a GP, state indemnity answers part of that duty; private and non-NHS work has to be answered by something else.

Discretionary indemnity vs contractual insurance

Private work is usually covered in one of two ways, and they are not the same thing.

DHSC published a summary of consultation responses in December 2022 and said it would report further progress through its response to the Paterson inquiry. Many doctors combine routes, for example defence membership for advice, regulatory and inquest support, alongside an insurance policy for a private clinic. Which mix suits you depends on your work, and the terms of each.

The position in Wales

Wales has its own state scheme. General Medical Practice Indemnity (GMPI) provides clinical negligence indemnity for providers of GP services in Wales for incidents from 1 April 2019. NHS Wales Shared Services Partnership Legal & Risk Services operates it, commissioned by the Welsh Government, and describes it as a discretionary scheme, as it says the English scheme is.

Its FAQs say paid-for or private work is not captured by GMPI, that claims not related to clinical negligence are outside it, and that GPs will need appropriate professional indemnity cover with a medical defence organisation for the rest of their practice.

What to check

Doing private work alongside the NHS?

If this affects your business, these are the points a broker will ask about:

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Cover for your private work, reviewed by a named broker

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How Apex places this cover

Apex Insurance Brokers is an independent insurance broker based in Bristol, established in 2009 and authorised and regulated by the Financial Conduct Authority. We are not tied to one insurer: we work with over 30 markets, including Lloyd’s syndicates through wholesale brokers, and every client has a named broker who handles the placement, mid-term changes, certificates for clients and the renewal.

Related guides

Sources

Frequently asked

Does CNSGP cover private work?

No. NHS Resolution’s CNSGP FAQ says any activities relating to your private practice are not covered and that you need suitable indemnity or insurance for that work. The scheme only meets clinical negligence liabilities connected with NHS primary medical services and certain ancillary NHS services in England, for incidents on or after 1 April 2019.

Do GPs still need indemnity if they have state indemnity?

Usually, yes. CNSGP covers NHS clinical negligence only. The GMC says doctors still need cover from a defence organisation or insurer for non-NHS or private work, inquests, and regulatory and disciplinary proceedings, and section 44C of the Medical Act 1983 requires cover appropriate to the full scope of a licensed doctor’s practice.

Does CNSGP cover GMC investigations or inquests?

No. NHS Resolution lists regulatory and disciplinary proceedings as outside the scheme, and says inquests and complaints are for your defence organisation in the first instance, with NHS Resolution involved only if a clinical negligence claim is intimated or likely. Cover for these costs usually comes from defence membership or a policy that includes them.

Is a GP doing aesthetics covered by CNSGP?

Not for privately funded treatment. Aesthetic injectables or other cosmetic procedures paid for by the patient are private healthcare, which NHS Resolution says falls outside CNSGP. A GP doing this work needs separate indemnity or a treatment risks or medical malpractice policy that names the procedures, subject to its terms.

Does CNSGP apply in Wales, Scotland or Northern Ireland?

CNSGP applies only to NHS services in England. Wales has its own General Medical Practice Indemnity scheme for GP services from 1 April 2019, operated by NHS Wales Shared Services Partnership, which also excludes private work. Arrangements in Scotland and Northern Ireland are separate and are not covered on this page.

What is the difference between discretionary indemnity and insurance?

Under discretionary indemnity, the provider decides whether to help with a claim; DHSC has described these providers as having no contractual obligation to meet a claim’s cost. An insurance policy is a contract that must respond to claims within its terms, and UK insurers are regulated. Both are allowed under section 44C.

Ready to compare cover?

The online treatment proposal takes about five minutes, and a named Apex broker reviews it and comes back to you on cover for your private and non-NHS work. Or call 0117 325 0027.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information, not advice on your individual circumstances. Cover is always subject to the insurer’s acceptance and the policy terms, and this page does not guarantee that cover will be available or on what terms.