Practice Business Manager dismissed for claiming £15,900 overtime from COVID-19 fund without authorisation
A Practice Business Manager with 16 years' service was fairly dismissed for gross misconduct after claiming overtime from the COVID-19 Support Fund without partner approval. The tribunal rejected her claims of whistleblowing and unfair dismissal.
1 min read · Last updated 18 May 2026
Case details
- #covid-fund
- #overtime-authorisation
- #protected-disclosure
- #whistleblowing
- #gross-misconduct
Key facts
- Mrs Morris claimed overtime for herself from the COVID-19 Support Fund without prior partner authorisation.
- The overtime claims totalled around £15,900 for 428 hours between March and September 2020.
- Mrs Morris made a protected disclosure about extended hours funding in October 2020.
- The Practice dismissed Mrs Morris summarily for gross misconduct on 24 December 2020.
- The dismissal was upheld on appeal.
Timeline
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Started employment
Mrs Morris started as Practice Business Manager at Holdenhurst Road Surgery.
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Practice merger
Holdenhurst Road Surgery merged with Shelley Manor Medical Centre to form the Practice.
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COVID-19 Support Fund established
UK Government established the CSF for GP practices; Mrs Morris began submitting claims.
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Meeting with Dr Zahedi
Mrs Morris discussed extended hours rotas; alleged protected disclosure not found.
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Asked about overtime
Mrs Morris asked Dr Walker-Date if she could continue overtime after fund ended.
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Instructed not to do overtime
Dr Walker-Date instructed Mrs Morris not to do further overtime due to welfare concerns.
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Meeting with Doctors Walker-Date and Yeoman
Mrs Morris was told an investigation would be carried out; she made a protected disclosure about extended hours.
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Investigatory meeting
Ms Kerry Tibble conducted the investigation; allegations were about unauthorised overtime and non-COVID claims.
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Disciplinary hearing
Mr Carl Tudor conducted the hearing; recommended summary dismissal for gross misconduct.
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Dismissal
Mrs Morris was summarily dismissed for gross misconduct.
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Appeal hearing
Ms Gina Bayliss heard the appeal; recommended dismissal of appeal.
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Appeal dismissed
The Practice wrote to Mrs Morris dismissing her appeal.
The legal issue
The tribunal had to decide whether the dismissal was automatically unfair because it was for making a protected disclosure (whistleblowing), or whether the real reason was the claimant's misconduct in claiming unauthorised overtime from the COVID-19 Support Fund.
The outcome
The tribunal dismissed all claims of unfair dismissal, automatic unfair dismissal for whistleblowing, and wrongful dismissal.
The key reasons were:
- The tribunal found that the claimant did not make a protected disclosure before the disciplinary process began; her concerns about extended hours funding were not in the public interest and were raised after the overtime issue had already come to light.
- The Practice had a genuine belief in the claimant's gross misconduct based on a reasonable investigation. The claimant, as Practice Business Manager, had authorised overtime payments for herself totaling approximately £15,900 for 428 hours without prior partner approval, which was a serious breach of trust.
- The dismissal procedure was fair overall, despite some minor procedural issues, and the outcome was within the range of reasonable responses.
No compensation was awarded as the dismissal was found fair. The only payment ordered was £2,050.68 by consent for untaken time off in lieu, which was not part of the unfair dismissal claim.
Lessons & takeaways
- Senior employees with financial authority must ensure they have explicit approval before claiming overtime or expenses, especially from government funds.
- Whistleblowing claims require the disclosure to be in the public interest; internal grievances about funding arrangements may not qualify.
- A fair dismissal process with a reasonable investigation and appeal can protect an employer even if the employee has long service and a good record.
- Making a protected disclosure after misconduct has already been discovered will not automatically make a dismissal unfair.
What this case shows in practice
This case demonstrates that even long-serving, senior employees can be fairly dismissed for misconduct if they overstep their authority, particularly when public funds are involved. The claimant, a Practice Business Manager with 16 years' service, was summarily dismissed after claiming £15,900 in overtime from the COVID-19 Support Fund without prior partner approval. The tribunal accepted that the Practice had a genuine belief in her gross misconduct, as she had authorised her own payments—a clear breach of trust for someone in her position.
What the losing side could have done differently
The claimant argued that her dismissal was automatically unfair because she had made a protected disclosure about extended hours funding. However, the tribunal found that her concerns were raised after the overtime issue had already been identified, and they were not in the public interest—they were essentially a dispute about internal funding arrangements. To succeed in a whistleblowing claim, the disclosure must be made in the public interest and must be a reason for the dismissal. Here, the misconduct was the real reason.
Why the result matters for similar claims
This case reinforces that employers can rely on a reasonable investigation and a genuine belief in misconduct, even if the employee has a long service record. It also highlights the importance of clear authorisation procedures for overtime and expenses, especially when using government funds. Employees in managerial roles should be particularly cautious about self-authorising payments, as this can be viewed as a fundamental breach of trust justifying summary dismissal.
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