Hmm, Helen. The GOC would consider it improper practice if you implied that you were working more than you actually were. I cannot remember the wording of the declaration we csign every year but it would be seriously unprofessional to lie. Surely a definition of a professional must include honesty and integrity.
Second point, you are required to be registered as a performer with the NHS England Area Team where you undertake most of your work. You have an obligation to ask whoever holds your performer list registration to transfer you. When I was Clinical Adviser with PCT our performer management team checked this every 15 months for GOS, Dentists and Optometrists. It’s easy to check v e cause you have signed GOS forms every time you do an eye exam or c sign a voucher and every individuals activity can be monitored across the country usino Open Exeter, the NHS data collection programme.
If you only do private work the performer list doesn’t apply but equally you cannot reclaim CET money each year.