Ceri S Eccles

Preliminary Matters:

Service

1. The Panel was provided with proof that the Notice of Hearing had been sent on 5 January 2021 by email to the email address shown for the Registrant on the HCPC Register. The Panel was satisfied that Notice had been properly served in accordance with the Health and Care Professions Council (Conduct and Competence Committee) (Procedure) Rules 2003 as amended (“the Rules”).

Proceeding in absence

2. Mr Bridges applied to proceed in the absence of the Registrant. He submitted that there had been no engagement from the Registrant and that there were two witnesses in attendance. He submitted that the allegation dated back to 2018 and that it was in the public interest to proceed.

3. The Panel accepted the advice of the Legal Assessor, who took the Panel to the guidance given in the cases of Jones (2003) 1 AC 1, Tait v The Royal College of Veterinary Surgeons [2003] UKPC 34 and GMC – v Adeogba [2016] EWCA Civ 162.

4. The Panel concluded that the Registrant had decided to absent herself from the hearing. She had not requested an adjournment or engaged in any way with the HCPC, and there was nothing to suggest that she would attend if the hearing were to adjourn. In those circumstances the Panel concluded that it was in the public interest to proceed in the absence of the Registrant.

Witnesses and evidence

5. The Panel was provided with statements and also heard live evidence from:

• MJ – The Trust Investigating Officer
• SW – The Registrant’s line manager

6. The Panel was provided with a bundle of documentation, which included:

• A witness statement taken by the Trust from Patient A, signed on 16 May 2018
• A witness statement taken by the Trust from Patient A’s partner, Person B, signed on 7 August 2018
• A witness statement taken by the Trust from CS, a physiotherapist who worked for the Trust, signed on 21 June 2018
• An audit record of entries made by the Registrant on the Trust’s computerised booking system “EMIS”, for 27 March 2018, regarding Patient A
• The Trust’s Podiatry Service Protocol for Undertaking Private Work

Background:

7. At the time of the Allegation the Registrant was employed on a full-time basis as a Band 5 registered Podiatrist by the University Hospitals of Morecambe Bay NHS Foundation Trust (‘the Trust’).

8. On 10 April 2018, the HCPC received a referral from the Trust regarding an allegation that whilst working for the Trust the Registrant had accepted payment for treating an NHS patient.

9. It is alleged that on 27 March 2018, the Registrant charged Patient A £15 for an NHS podiatry appointment conducted by the Registrant at Patient A’s home that morning, which should have been free of charge.

10. It is alleged that the Registrant told CS, at approximately 12:15 on 27 March 2018, that she had just visited Patient A. CS then visited Patient A’s home in the afternoon and noticed that Patient A had already received the relevant treatment. It is alleged that CS was told that £15 had been paid for the treatment received.

11. It is alleged that the Registrant was then asked about the incident by SW on 10 April 2018 and denied receiving any payment for the treatment of any NHS patient.

12. It is further alleged that the Registrant retrospectively misrepresented the timing of the booking and visit to Patient A by means of entries on the computerised appointment booking system, EMIS. The entries for 27 March 2018 showed that the appointment had been booked at 14.56 and the visit conducted at 16.15. It is alleged that on the evidence of CS, both events must have taken place prior to time when CS met with the Registrant on 27 March 2018, namely prior to 12:15.

13. A routine supervision meeting was held by SW with the Registrant on 16 May 2018. During that meeting the Registrant submitted her letter of resignation. Her resignation had been offered to SW verbally at some time before 30 April 2018 because of her continuing difficulties with her line manager, SW. At the time she did not know about the allegation that was to be investigated by the Trust. She was not interviewed about the allegation by the Trust and did not provide any submissions or documentation for the consideration of the Trust or the HCPC.

14. The Trust conducted an audit of all out-patients visited by the Registrant between January 2018 and her resignation. No further allegations emerged.

15. It was accepted by the HCPC that the Registrant was of previous good character, with no previous adverse findings against her name.

Decision on Facts:

16. The Panel accepted the advice of the Legal Assessor, who advised on the burden and standard of proof, the Registrant’s good character, and the definition of dishonesty as established in the case of Ivey v Genting Casinos (UK) Ltd t/a Crockfords [2017] UKSC 67. She provided detailed advice regarding the criteria that the panel should apply when deciding what weight to attach to the hearsay evidence in the case, including reference to Section 4 of the Civil Evidence Act 1995.

17. The Panel began by considering the quality of the witness evidence that had been provided.

18. The Panel concluded that MJ was a reliable and helpful witness, albeit that his evidence consisted largely of a summary of evidence provided by others.

19. The Panel concluded that SW, the Registrant’s line manager, was an honest witness, but appeared reluctant to disclose the extent of the difficulties she experienced in the course of her relationship with the Registrant, which MJ had spoken of in the course of his evidence. The Panel was concerned that the difficulties in the relationship may have affected the manner in which SW had conducted her conversation with the Registrant on 10 April 2018, with reference to Particular 2 of the HCPC Allegation.

Particular 1:

On or around 27 March 2018, charged Patient A a private fee of £15 for treatment that you provided whilst working as an employee of the Trust.

20. In evidence MJ informed the Panel that on 31 January 2017 the Registrant had signed a “Podiatry Secondary Employment – Paid or Voluntary” declaration form, stating that she would be undertaking secondary employment at a Multiple Sclerosis “MS” group. As part of the declaration she indicated that she had read and understood:

• The Podiatry Private Practice Protocol;
• The Standards of Business Conduct for NHS staff; and
• The Staff Rostering Policy.

21. MJ said that the Registrant also completed a “Declaration of Additional Employment” document, specifying that she held an additional contract of employment outside the Trust, for two hours work per month. MJ said that this was the only secondary employment declaration submitted by the Registrant throughout her time at the Trust, although she had submitted a declaration of interest form prior to this, namely:

• On 25 November 2014 she declared that she was treating two private clients outside of the NHS every three months

• On 2 December 2014 she declared that she was treating two private clients outside of the NHS

22. In her witness statement, CS stated that on 12 March 2108 she visited Patient A at her home address. She noticed that Patient A’s toenails needed cutting, and caused an NHS referral for the Podiatry services to be completed.

23. In her witness statement, CS said that on 20 March 2018, she visited Patient A again and observed that her toenails had not been cut.

24. In her witness statement, CS said that she happened to bump into the Registrant at another patient’s house, on 27 March 2018. She alleged that the Registrant said to her something to the effect of “I have just seen patient A who you are due to see this afternoon”.

CS said that she then visited Patient A to perform physiotherapy treatment and noticed that Patient A’s toenails had been cut. She said that she:
“commented that Patient A's nails had been done and Person B said that they were really pleased with them. Person B was complementary about the individual who had carried out the treatment and said she had been lovely”.

25. In her witness statement, CS said she then asked if the Registrant was the person who had performed the treatment, and Person B confirmed it was. She said that Person B then went on to say that they were surprised with how cheap the service was, in that the service cost “only £15”.

26. In her witness statement, CS said that on 16 April 2018 she visited Patient A again to provide physiotherapy treatment. She asked Person B whether the £15 had been reimbursed. She said that Person B explained that it had been a private arrangement and that it was the Reablement team who had provided the Registrant’s phone number. Person B provided CS access to a phonebook which showed a mobile number next to the name “Kerry”. CS made a record of the mobile number and later emailed it to SW, who confirmed that it was the Registrant’s number.

27. In her witness statement CS said that after she spoke to Patient A on 27 March 2018, she checked Patient A’s file on the electronic computer booking system, EMIS, which indicated that the Registrant had booked a visit to Patient A and attended her address on 27 March 2018.

28. SW informed the Panel that at the relevant time the Registrant was employed by the Trust on a full-time basis, working 5 days a week for a total of 37 ½ hours a week between 8:30 and 17:00.

29. In seeking to prove Particular 1, Mr Bridges relied on the following evidence:

• CW had given evidence that the Registrant was employed at the Trust on a full-time basis, working 5 days a week;
• the EMIS entries made by the Registrant showed that the Registrant attended upon Patient A on the 27 March 2018;
• the Registrant had accepted, when questioned by SW, that she had seen Patient A on the 27 March 2018;
• Patient A had been entered on EMIS as a NHS referral on 12 March 2018;
• in her interview on the 21 June 2018 CS confirmed that the Registrant had seen Patient A prior to 14:00 on 27 March 2018;
• Patient A confirmed in his witness statement, signed on 16 May 2018, that he had paid the Registrant for an emergency private appointment.

30. The Panel was informed by Mr Bridges that no attempt had been made to contact Patient A, Person B or CS with a view to calling them as witnesses in the case. No reason had been put forward for this decision. In those circumstances the Panel gave careful consideration to the weight to attach to the witness statements provided by Patient A, Person B and CS.
31. The Panel took account of the delay that had taken place between the time of the incident and the dates of the witness statements and decided the statements could not be regarded as contemporaneous. The statement of CS contained multiple hearsay. Nevertheless, the Panel concluded that it was highly unlikely that Patient A or Person B or CS would have fabricated the evidence provided. There appeared to be no reason why they should choose to make accusations against the Registrant; to the contrary, it appeared that Patient A and Person B were expressing their contentment with the services they had received from the Registrant, describing them as good value.

32. In those circumstances in considering what weight to give to the witness statements of Patient A, Person B and CS the Panel concluded that it was more likely than not that the evidence they provided was both credible and reliable. The Panel considered the submissions of Mr Bridges. The Panel accepted, on the basis of the evidence of Patient A and Person B, that it was more likely than not that Patient A had paid £15 to the Registrant for services provided. The Panel concluded, from the evidence of CS, that the person who had treated Patient A on 27 March 2018, and therefore received the £15, was the Registrant, because the Registrant told CS that she had visited Patient A on the morning of 27 March 2018. The EMIS report also confirmed that the Registrant had visited Patient A that day. The Trust documentation proved that the Registrant was working full time as an NHS employee at the time and therefore was precluded from charging any such fee.

33. On that basis the Panel found Particular 1 proved.

Particular 2:

On or around 10 April 2018, stated during a conversation with your line manager that you had not received any payment for the treatment provided to Patient A.

34. This Particular was based on the evidence of SW who said in her witness statement that on 10 April 2018 she had a discussion with the Registrant. SW said that she:

“informed Ceri Eccles that I had just had a very strange conversation with a patient who had been charged for NHS treatment and asked whether we charged for any NHS podiatry treatment. Ceri Eccles confirmed that we do not charge for NHS treatment.

I then asked Ceri Eccles if she had ever charged a patient for NHS treatment and Ceri Eccles said she had not. I asked Ceri Eccles if a patient had ever tried to give her money for an NHS treatment and Ceri Eccles said no.

I then asked Ceri Eccles if Patient A's name rang a bell. Ceri Eccles said that it did not. I then showed Ceri Eccles her home visit list from 27 March 2018 and showed her that Patient A was on the list. Ceri Eccles said that she did remember Patient A and that they had been very confused. Ceri Eccles said that she had mentioned this to [CS] following her visit”.

35. In seeking to prove Particular 2, Mr Bridges relied on the evidence of SW.

36. The Panel concluded that the conversation between SW and the Registrant on 10 April 2018 had been conducted in a manner that was unsatisfactory and it would be unfair to place much reliance on the Registrant’s response to questions asked in the context of a casual chat without forewarning of its importance. In any event, regardless of the quality of the evidence, the Panel concluded that the conversation, as relayed by SW, did not meet the charge. It was alleged that the Registrant had stated that she had not received any payment for treatment provided to Patient A, whereas in her witness statement SW said that the Registrant had been asked whether she ever charged a patient for NHS treatment, to which the Registrant had said she had not. SW had asked the Registrant if a patient had ever tried to give her money for NHS treatment and the Registrant said she had not. SW said that it was only then that she took the Registrant specifically to the case of Patient A, at which point the Registrant told her that she “did remember Patient A and that they had been very confused”. The Panel concluded that this conversation did not provide sufficient evidence to prove Particular 2.

37. In those circumstances the Panel found Particular 2 not proved.

Particular 3:

On or around 27 March 2018, retrospectively recorded your visit to Patient A on EMIS and misrepresented the time at which the visit was made, in that you:
a. recorded the appointment booking at 14.56 hours having already completed the visit; and / or
b. represented that you had visited Patient A at 16.15 hours when in fact you had visited Patient A earlier in the day

38. In her witness statement CS said that after she spoke to Patient A on 27 March 2018, she checked Patient A’s file on the electronic computer booking system, EMIS, which indicated that the Registrant had booked a visit to Patient A at 14.56 on 27 March 2018 and visited Patient A at 16.15 on the same day. CS believed this information to be incorrect in that she had attended Patient A’s address at 14.00 on 27 March 2018 and at that point the Registrant had already treated Patient A.

39. In seeking to prove Particular 3, Mr Bridges relied on the following evidence:

• The witness statement of CS, who confirmed that the Registrant must have seen Patient A at some time prior to 2pm on the 27 March 2018.
• The EMIS record for Patient A which demonstrated that the Registrant entered the appointment onto EMIS at 14.56, hence after the appointment had taken place.
• The EMIS record stated that the appointment took place face to face at 16.15 when it did not.

40. The Panel took account of the evidence of MJ that all domestic visits were recorded retrospectively on the EMIS system. The Panel concluded that it was clear from the stem of the Particular that what was being alleged was not limited to a suggestion that the Registrant had retrospectively recorded the visit, but went further, in that it was asserted that this was a misrepresentation on her part. The Panel could see no reason why the Registrant should choose to misrepresent the position in this regard. By making the entry, the Registrant did not succeed in showing that the visit was made outside NHS hours. The Registrant had nothing to gain from these entries. The Panel concluded that if the Registrant had wanted to conceal her actions she could have refrained from entering any information onto the system. The Panel concluded that there was insufficient evidence with which to conclude that there had been concealment or misrepresentation on the Registrant’s part.

41. In those circumstances the Panel found Particular 3 not proved.

Particular 4:

Your actions were dishonest in relation to particulars 1 and/or 2 and/or 3

42. The Panel considered the issue of dishonesty in the light of the decision of the Supreme Court in Ivey v Genting Casinos (UK) Ltd t/a Crockfords [2017] UKSC 67. It noted the part of the judgment of Lord Hughes:

“When dishonesty is in question the fact-finding tribunal must first ascertain (subjectively) the actual state of the individual’s knowledge or belief as to the facts. The reasonableness or otherwise of his belief is a matter of evidence (often in practice determinative) going to whether he held the belief, but it is not an additional requirement that his belief must be reasonable; the question is whether it is genuinely held. When once his actual state of mind as to knowledge or belief as to facts is established, the question whether his conduct was honest or dishonest is to be determined by the fact-finder by applying the (objective) standards of ordinary decent people. There is no requirement that the defendant must appreciate that what he has done is, by those standards, dishonest.”

43. In seeking to prove Particular 4 in relation to Particular 1, Mr Bridges submitted that in knowingly seeing Patient A on a private basis, for a fee of £15, whilst she was in the paid employment of the Trust, the Registrant had acted dishonestly.

44. The Panel weighed in the Registrant’s favour the fact that she was of previous good character, and that she had worked for the Trust for some 18 years with no other complaint. The Panel had found Particular 1 proved. The Registrant had provided no evidence to indicate what had been going through her mind at the time of accepting the £15. In those circumstances, the Panel could think of no legitimate reason for the Registrant asking for and accepting payment. The Panel concluded on the balance of probabilities that the Registrant knew at the time of charging Patient A the fee of £15 that she should not have been doing so, because she was an employee of the Trust undertaking NHS treatment. The Panel concluded that ordinary decent people would regard such behaviour as dishonest.

45. Accordingly, the Panel found Particular 4 in relation to Particular 1 proved.

46. The Panel had found Particulars 2 and 3 not proved, and it followed that Particular 4 in relation to Particulars 2 and 3 were also not proved.
Submissions and Advice on Grounds and Impairment

47. Mr Bridges submitted that the Registrant’s behaviour had breached Standards 1, 2, 9 and 10 of the HCPC Standards of Conduct, Performance and Ethics (January 2016). He submitted that the Registrant’s behaviour would be regarded as deplorable by fellow practitioners and amounted to misconduct.

48. Mr Bridges submitted that the Registrant’s dishonest misconduct had breached a fundamental tenet of the profession and had brought the profession into disrepute. He submitted that the Registrant’s fitness to practise is currently impaired.

49. The Legal Assessor advised the Panel on the meaning of misconduct. She referred to the cases of Roylance –v- General Medical Council No 2 [2001] 1 AC p1 and Nandi v GMC [2004] EWHC 2317 (Admin). She advised the Panel to ask whether the Registrant’s behaviour had fallen seriously below the standards to be expected of a registered Podiatrist in the circumstances, and whether her behaviour would be regarded as deplorable by fellow practitioners.

50. The Legal Assessor advised the Panel that if, in its judgment, the facts found proved amounted to misconduct, the Panel should consider whether the Registrant’s fitness to practise is currently impaired by reason of that misconduct. The Legal Assessor advised on the meaning of impairment. She referred to the cases of Cohen v GMC [2008] EWHC 581 and Council for Healthcare Regulatory Excellence v (1) Nursing and Midwifery Council (2) Paula Grant [2011] EWHC 927, in which Mrs Justice Cox encouraged decision makers tasked with the issue of impairment to consider the following:

• whether the Registrant had presented and/or continues to present a risk to patients/service users;
• whether the Registrant had brought and/or is liable to bring the profession into disrepute;
• whether the Registrant had breached and/or is liable to breach one of the fundamental tenets of the profession;
• whether the Registrant had acted dishonestly and/or is liable to act dishonestly in the future.

51. The Legal Assessor encouraged the Panel to consult the Practice Note entitled, “Finding that Fitness to Practise is ‘Impaired’” issued by the HCPTS.
Decision on Grounds:

52. The Panel considered the evidence in the case and the submissions of Mr Bridges. It accepted the advice of the Legal Assessor.

53. The Panel concluded that the Registrant’s dishonest behaviour, as found proved in Particular 4 in relation to Particular 1, amounted to a serious departure from the standards of conduct that could properly be expected of a Podiatrist performing the role that the Registrant was employed to perform at the time. It also concluded that her behaviour would be regarded as deplorable by fellow practitioners.

54. In so concluding, the Panel found that the Registrant had breached Standard 9 of the HCPC Standards of Conduct, Performance and Ethics (January 2016):

• 9. Be honest and trustworthy

55. Accordingly, the Panel determined that the facts found proved amounted to misconduct.
Decision on Impairment:

56. The Panel considered the evidence in the case and the submissions of Mr Bridges. It accepted the advice of the Legal Assessor.

57. The Panel approached the issue of impairment on the basis that the misconduct amounted to a single isolated event in the context of the Registrant’s lengthy and unblemished career.

58. The Panel considered the criteria set out in the case of Grant, and concluded that through her dishonest misconduct the Registrant had brought the profession into disrepute and had breached a fundamental tenet of her profession.

59. The Panel noted that the Registrant had neither engaged with the Trust investigation, nor with the HCPC as her regulator and had provided no evidence of remorse, insight or remediation. In those circumstances it was the judgment of the Panel that it could not be said that it was highly unlikely that the Registrant would repeat her misconduct.

60. The Panel concluded that the Registrant’s dishonesty, which had taken place in the course of her professional duty, required a finding of impairment to uphold proper professional standards and maintain public confidence in the profession and its regulator.

61. Accordingly, the Panel concluded that the Registrant’s fitness to practise is currently impaired on both the personal and public components.

Submissions and Advice on Sanction

62. Mr Bridges submitted that sanction was a matter for the judgement of the Panel. He reminded the Panel of the Panel’s findings regarding the Registrant’s lack of engagement, remediation and insight.

63. The Legal Assessor advised the Panel to consider any aggravating and mitigating features of the case. She advised that the purpose of sanction is not to be punitive but is to protect the public and the wider public interest, which includes the maintenance of public confidence in the profession and declaring and upholding proper standards of conduct and behaviour.

64. The Legal Assessor encouraged the Panel to consult the current Sanctions Policy published by the HCPC. She advised the Panel to apply the principle of proportionality, weighing the Registrant’s interests against the need to protect the public and the wider public interest. She advised the Panel to consider the least restrictive sanction first.

Decision on Sanction:

65. The Panel considered the submissions of Mr Bridges and accepted the advice of the Legal Assessor.

66. The Panel concluded that the Registrant’s misconduct was serious, in that she had dishonestly accepted payment for services rendered in the context of a private arrangement at a time when she was employed to work for the NHS. The Panel concluded that there were no aggravating factors. It was not suggested that the Registrant had misled Patient A into paying for treatment; it was clear from the statements that Patient A had knowingly entered into a private arrangement in order to expedite treatment rather than opting to wait to receive NHS treatment free of charge.

67. The Panel concluded that the Registrant’s misconduct was mitigated by the fact that this was an isolated incident in the context of a nine year unblemished career.

68. In view of the seriousness of the misconduct, namely dishonesty, the Panel concluded that to take no further action or to impose a Caution Order would be insufficient to protect the public or maintain confidence in the profession and the regulatory process. In considering the criteria set out in the HCPC Sanctions Policy the Panel concluded that whilst the misconduct was isolated, it could not be said that it was minor in nature, or that the risk of repetition was low, or that the Registrant had shown good insight or that the Registrant had undertaken appropriate remediation.

69. The Panel considered a Conditions of Practice Order but concluded that this would not be appropriate due to the nature of the misconduct. Such an order would not be workable in the light of the Panel’s finding of dishonesty, for which conditions could not be devised, and in the light of the Registrant’s disengagement from the proceedings, meaning that the Panel could not be satisfied that the Registrant would abide by any conditions it may see fit to impose.

70. The Panel considered a Suspension Order. The Panel took account of the fact that this was an isolated incident that had occurred in the context of an unblemished career. However, by failing to engage at any level, either with the Trust investigation or with these HCPC proceedings, the Registrant had placed the Panel in the regrettable position of being presented with no evidence of remediation, remorse, or insight. In those circumstances the Panel concluded that none of the positive factors set out at Paragraph 121 of the Sanctions Policy indicating the suitability of a Suspension Order were present, in that there was no evidence of insight, it could not be said that the dishonesty was unlikely to be repeated, and there was no evidence to suggest that the Registrant is likely to be able to remedy her failing. In those circumstances the Panel concluded that a Suspension Order was not sufficient to protect the public or the wider public interest, and the Panel was compelled to move on to consider a Striking Off Order.

71. The Panel understood that a Striking Off Order is the most punitive of all orders. The Panel took account of the isolated nature of the dishonesty, and of the Registrant’s good character hitherto. The Panel also took into account material in the bundle which suggested that the Registrant had been regarded as a good clinician. However, the Registrant had been dishonest in the course of her employment. Since then she had done nothing to assist her cause. She had not engaged with her employer nor had she engaged with her regulator. She had provided no evidence of remediation, apology, remorse or insight into her past actions. The Panel had received no assurance that she would not repeat her dishonest conduct. In those circumstances the Panel could not be satisfied that she would not repeat it. The Panel concluded that it was in the public interest to impose a Striking Off Order in circumstances of dishonesty such as this with no engagement whatsoever on the part of the Registrant. Such an order was required to maintain and uphold standards in the profession and to maintain confidence in the Registrant, her profession and her regulator.
72. Accordingly, it was the judgment of the Panel that the appropriate order in this case is a Striking Off Order.

That the Registrar is directed to strike the name of Ms Ceri Eccles from the register on the date this order comes into effect.

Right of Appeal

You may appeal to the High Court in England and Wales against the Panel’s decision and the order it has made against you.

Under Article 29(10) of the Health Professions Order 2001, any appeal must be made within 28 days of the date when this notice is served on you. The Panel’s order will not take effect until the appeal period has expired or, if you appeal, until that appeal is disposed of or withdrawn.

Interim Order Application:

1. Following the announcement on sanction, the Case Presenter applied for an Interim Suspension Order for a maximum period of 18 months to cover the appeal period.

2. The Panel was satisfied that it was appropriate to consider the HCPC’s application for an interim order in the absence of the Registrant because she had been informed in the Notice of Hearing that such an application might be made, and yet had voluntarily absented herself from these proceedings.

3. The Panel was satisfied that the need for an Interim Order to protect the public interest outweighed the Registrant’s interests in this instance, for the same reasons as those set out by the Panel in reaching its substantive decision. The Panel was satisfied that the misconduct is so serious that public confidence in the profession would be seriously harmed if the Registrant were to be allowed to remain in unrestricted practice.

4. The Panel concluded that an Interim Conditions of Practice Order would not be appropriate in the light of the nature of the misconduct, namely dishonesty and given it has made a striking off order. In those circumstances the Panel concluded that the appropriate form of interim order is an Interim Suspension Order.

Interim Suspension Order:

The Panel makes an Interim Suspension Order under Article 31(2) of the Health Professions Order 2001, the same being necessary to protect the public interest.

This order will expire: (i) upon the expiry of the appeal period, if no appeal is made against the Panel’s decision and Order or (ii) upon the final determination of an appeal if an appeal is brought. The maximum length of this order is 18 months.

History of Hearings for Ceri S Eccles