Memorandum by the General Medical Council
The objective of the GMC is to protect, promote
and maintain the health and safety of the public.
We do this by the exercise of our functions
(a) Establishing standards of good medical
practice, which reflect what society, and the profession,
expect of doctors.
(b) Assuring the quality of basic medical
education in the UK and co-ordinating all stages of medical education.
(c) Setting and administering fair systems
for entry to and remaining on the medical register.
(d) Dealing firmly and fairly with doctors
whose fitness to practise is questioned. The "fitness to
practise" procedures are the legal processes which the GMC
applies to cases where a doctor's continued right to registration
is called into question because of alleged serious deficiencies
in their fitness to practise, that is, their conduct, health or
The GMC was established under the Medical Act
1858. The GMC's duties and powers continue to be conferred and
regulated by primary and secondary legislation. The current powers
derive from the Medical Act 1983, as amended.
The GMC is committed to promoting equality and
valuing diversity and to operating processes and procedures that
are fair, objective, transparent and free from discrimination.
In June 2001 the Charity Commission announced
that it had decided on 2 April 2001 to recognise the GMC's charitable
status. On 9 November 2001 the GMC was formally registered as
The GMC does not regulate the pharmaceutical
industry and has not researched, or developed a corporate policy
on, the industry's impact on medical practice.
Our guidance on professional standards covers
both the therapeutic use of medicines and medical research. We
give general guidance in our core booklet Good Medical Practice
and more specific advice in Research: the role and responsibilities
of doctors. Copies of both booklets are enclosed.
Good Medical Practice establishes the
principles which should underpin all doctors' professional work.
This includes putting patients' interests first, including when
prescribing, keeping up to date, and reporting any adverse drug
reaction. (See paragraphs 3 and 10-11). Good Medical Practice
also warns doctors against involvement in any relationships
with pharmaceutical or other companies which could raise, or be
seen to raise, a conflict of interests (see paragraph 55). This
is intended to cover matters such as accepting hospitality or
gifts from pharmaceutical companies, other than those which are
trivial. Our guidance does not, of course, operate in isolation,
but is just part of the regulation of this area of practice. The
Medicines (Advertising) Regulations 1994 and the Code of Practice
issued to the pharmaceutical industry provide further controls
over the hospitality or gifts which may be offered to doctors
by pharmaceutical companies.
Good Medical Practice also makes clear
that doctors must be honest and open about any financial or commercial
interests they have in pharmaceutical companies and ensure that
those interests do not affect their independent judgement in providing
and arranging patient care (paragraphs 56-57).
We give more detailed guidance on how the principles
established in Good Medical Practice apply in research
in our booklet Research: the role and responsibilities of doctors.
You may be interested to note in particular the statement
of principles set out in paragraph 5 of the booklet, and the paragraph
on conflicts of interest in paragraph 13.
The booklet also emphasises the need for openness
and honesty in all financial and commercial matters, and in particular
the obligation to make clear to research ethics committees, and
participants in research, how research is funded and the fees
or other payment or rewards to be made to researchers.
It is unusual for the GMC to receive complaints
about doctors asking for or accepting inappropriate fees or hospitality
from pharmaceutical companies. However, cases relating to the
honesty of doctors involved in clinical drugs trials are more
frequent, and many lead to the doctor being struck off, or suspended
from the register. Such cases often involve doctors inventing
patients and data relating to their care, or involving "real"
patients in clinical trials without consent. Our concerns are
with these actions in themselves and with their effect on research
data available to other practitioners, rather than whether, for
example, the methods of payment for such work, have an influence
on, or affect, doctors' conduct.
Alongside its role in setting standards for
medical practice, the GMC issues guidance and sets outcomes for
medical education and training. We ensure that the outcomes are
met through our programme of Quality Assurance of Basic Medical
Education which includes visits to medical schools. Tomorrow's
Doctors sets out the competencies required for graduation
and admission to the provisional register. We have been revising
our guidance on the Pre-Registration House Officer year that follows
graduation and aim to publish a new edition of The New Doctor
later this year. This will set out the competencies required
to complete PRHO training and achieve full registration. We have
recently published new guidance on Continuing Professional
Development, which is often funded by the pharmaceutical industry.
Our website includes a list of organisations that can help doctors
to undertake appropriate CPD. Throughout our educational guidance
we stress the importance of clinical competence alongside probity
and patient-centredness in medical practice and research.
Some doctors do fail to maintain the standards
that we expect. We work closely with the NHS and the National
Clinical Assessment Authority, and with other organisations, to
ensure that problems are dealt with at the appropriate level in
the best interests of patients. Where necessary we can take action
on doctors' registration. We summarise the results of fitness
to practise cases in GMC News, which is distributed to
all doctors on the medical register. Our fitness to practise work
contributes to the environment in which we develop our guidance
on standards of medical practice and the outcomes required of
those undertaking medical education and training.
While acting within our statutory role and functions,
we can therefore promote medical practice which puts patients
first and is not compromised by external pressures or financial