Physician Disciplinary Action Procedures in UK NHS - Better than USA?

Being interested in a comparison between disciplinary action procedures in the US to those in other countries, I looked into the UK NHS. It appears that there is an inclination to correct and prevent recurrence rather than to punish.  Also there is a clear attempt to implement due process.  I do not know, in reality, how that works and whether the rules can be exploited as much as in the US for bad-faith purposes (sham peer reviews).  Here is the link:

http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/Browsable/DH_5279462

Read what it says...

Managing the risk to patients

4. When serious concerns are raised about a practitioner, the employer must urgently consider whether it is necessary to place temporary restrictions on their practice. This might be to amend or restrict their clinical duties, obtain undertakings or provide for the exclusion of the practitioner from the workplace. Where there are concerns about a doctor or dentist in training, the postgraduate dean should be involved as soon as possible.

5. Exclusion of clinical staff from the workplace is a temporary expedient. Under this framework, exclusion is a precautionary measure and not a disciplinary sanction. Exclusion from work ("suspension") should be reserved for only the most exceptional circumstances.

6. The purpose of exclusion is:  to protect the interests of patients or other staff; and/orto assist the investigative process when there is a clear risk that the practitioner's presence would impede the gathering of evidence.It is imperative that exclusion from work is not misused or seen as the only course of action that could be taken. The degree of action must depend on the nature and seriousness on the concerns and on the need to protect patients, the practitioner concerned and/or their colleagues.

7. Alternative ways to manage risks, avoiding exclusion, include:  Medical or clinical director supervision of normal contractual clinical duties;Restricting the practitioner to certain forms of clinical duties;Restricting activities to administrative, research/audit, teaching and other educational duties. By mutual agreement the latter might include some formal retraining or re-skilling.Sick leave for the investigation of specific health problems.8. In cases relating to the capability of a practitioner, consideration should be given to whether an action plan to resolve the problem can be agreed with the practitioner. Advice on the practicality of this approach should be sought from the National Clinical Assessment Authority (NCAA). If the nature of the problem and a workable remedy cannot be determined in this way, the case manager should seek to agree with the practitioner to refer the case to the NCAA, which can assess the problem in more depth and give advice on any action necessary. The NCAA can offer immediate telephone advice to case managers considering restriction of practise or exclusion and, whether or not the practitioner is excluded, provide an analysis of the situation and offer advice to the case manager.

Details can be found in the website "Maintaining high professional standards in the modern NHS"