Five governance gaps I keep seeing in new clinics.
I've written governance frameworks for clinics of different sizes, been through inspections with them, and reviewed a good few belonging to other people. The same five gaps turn up again and again, and none of them are hard to close.
Plain English
Clinical governance is the set of habits a clinic uses to make sure care is safe and keeps getting better. The gaps that most often let patients down are: screening that's a form rather than a judgement, a review meeting that agrees with everything, no structured follow-up, patient information that misses the practical things, and nobody checking their own work. If you're choosing a clinic, it's reasonable to ask who screens you, who reviews the decision, and who you'll speak to after you start.
What do regulators expect from clinical governance in a UK cannabis clinic?
Clinical governance is the system a clinic uses to keep care safe and to show that it is safe. Each part of the UK has its own regulator and its own rules.
- England. The Care Quality Commission checks clinics against the fundamental standards. These include Regulation 17, good governance, of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. The CQC's guidance says providers need systems such as regular audits to assess, monitor and improve the quality and safety of their service.
- Scotland. Independent clinics must register with Healthcare Improvement Scotland. It inspects against The Healthcare Improvement Scotland (Requirements as to Independent Health Care Services) Regulations 2011, the Health and Social Care Standards and its own Quality Framework.
- Wales and Northern Ireland. Independent healthcare providers in Wales register with Healthcare Inspectorate Wales. In Northern Ireland, independent clinics register with the Regulation and Quality Improvement Authority (RQIA).
For a service prescribing unlicensed cannabis-based medicines, the evidence inspectors ask for falls, in my experience, into five areas:
- clinical screening before anyone sees a prescriber
- a multidisciplinary review that records its reasoning
- structured follow-up
- written patient information on driving, work and travel
- an audit cycle, with incident and complaints logs that people actually use.
Those five areas are also where the gaps below turn up. This is professional opinion, not regulatory advice. (Checked 17 October 2026.)
New clinics are usually started by people with real expertise: a consultant who believes in the medicine, a pharmacist who understands the supply chain, an investor who can see the demand. What's sometimes missing is experience of running a regulated service day to day. Here's where the gaps tend to appear.
1. Screening that's a form, not a judgement
Almost every clinic has an eligibility questionnaire. Far fewer have a clinician who reads it, asks the follow-up questions and makes a decision before the patient is booked. The gap shows up as consultations that shouldn't have happened, patients paying to be told no, and, occasionally, a patient with an untreated psychotic illness or a serious dependency reaching a prescriber without anyone having noticed.
Close it by making screening a clinical role. A nurse who owns pre-assessment, uses validated tools every time, records the reasoning and has a clear line to a doctor when something's unclear. It's also a sensible use of consultants' time.
2. A multidisciplinary review that agrees with everything
Most clinics know they should have one. The General Medical Council's information for doctors points to NHS England guidance that a decision to prescribe should "generally be agreed by the multidisciplinary team". Some clinics have turned their MDT into a weekly list read out and nodded through. An inspector will ask to see the minutes, and they'll want to see evidence of real discussion.
A working MDT has a pharmacist and a nurse in it as well as doctors, records what was discussed rather than just the outcome, occasionally says no or "not yet", and feeds what it learns back into the criteria. It doesn't need to be long. It needs to be honest.
3. Follow-up that depends on the patient chasing
The first prescription is the beginning, not the end. Titration goes wrong, side effects appear, products go out of stock, and patients quietly stop. In clinics without structured follow-up, the ones who struggle are the ones you never hear from again, and the outcome data you need to defend the service never gets collected.
Close it with a named follow-up plan for every patient, booked before they leave the first consultation, and a nurse-led review service that does the routine work so consultants see the patients who need them. Measure outcomes at each review with the same tools every time.
4. Patient information that skips the awkward bits
Most clinics write well about the medicine itself. It's easier to miss driving law, workplace drug testing, travel, storage at home, what to do when a product is unavailable, and how to stop safely. Those are the things patients ring about, and the things that cause problems later when nobody explained them.
Close it by writing the practical leaflets: plain English, covering the real risks, given before the first prescription and available on the website. Then check patients have actually seen them, and record that you did.
5. Nobody checking their own work
An audit programme is the difference between a clinic that thinks it's safe and one that can show it. The gap is often a policy that mentions audit and a calendar that doesn't. Add to that incident reporting that nobody uses because nothing "serious" has happened, and a complaints process that sits in one person's inbox.
Close it with a short annual audit cycle that people will actually complete: consent, screening, prescribing against criteria, follow-up attendance, outcomes. A simple incident log with a monthly look at it. A complaints process with a clear owner and a route for escalation. Regulators don't expect perfection. They expect you to know where you're weak and to be doing something about it.
Why this matters beyond the inspection
Every one of these gaps is, in the end, about a patient. The one who paid for a consultation they were never going to pass. The one whose prescription was approved without a second thought. The one who stopped taking it and told nobody. The one stopped at the roadside. Good governance isn't paperwork; it's the habit of noticing those people early. If your clinic has all five in place, that's a strong position. If not, they're fixable, and I'd be glad to help.
Professional opinion drawn from experience of UK clinics, not legal or regulatory advice. Requirements differ between the CQC, Healthcare Improvement Scotland and HIW, and change over time.