Revalidation of Doctors - Health Committee Contents


List of recommendations


Introduction

1.  The current legislation makes the GMC accountable to the Privy Council; in the absence of a mechanism which makes this accountability effective we intend to exercise this function ourselves, on behalf of Parliament. (Paragraph 7)

A history of Revalidation

2.  Now that "late 2012" has been set as the date of implementation, we look to the GMC to ensure that there are no further delays and that the current target date is achieved. (Paragraph 20)

Purpose of Revalidation

3.  Although the Committee agrees that the focus of revalidation for most doctors should be a commitment to practice improvement, it believes that the need to identify inadequate and potentially dangerous doctors must not be overlooked or diminished in the general move to use revalidation to eliminate unsatisfactory practice and improve overall performance. (Paragraph 26)

Doctors whose performance gives cause for concern

4.  The Committee finds it unsatisfactory that so little attention has been given to the issue of how to deal with doctors whose practice gives cause for concern. We regard this as an important weakness in the current proposals which the GMC needs to address if the introduction of revalidation is to help sustain public confidence in the medical profession. (Paragraph 30)

5.  The Committee is concerned that instinctive use of the word "remediation" in cases where a doctor's performance gives cause for concern may have the effect of pre-judging the appropriate response to a particular set of circumstances. While it is important to ensure the rights and legitimate interests of individual doctors are safeguarded, the primary purpose of revalidation is to protect the interests of patients. (Paragraph 31)

6.  The Committee therefore recommends that the GMC publishes clear guidance to Responsible Officers about how they should deal with the cases of doctors whose performance gives rise to concern. (Paragraph 32)

Appraisal

7.  It is clearly unsatisfactory that there is such a degree of variation across the country in relation to appraisal, and unacceptable that some doctors are apparently not subject to appraisal at all. If an adequate appraisal system is not provided for all doctors, then revalidation, as currently envisaged, will not work. The GMC needs to satisfy itself that all organisations which employ doctors have satisfactory, robust and consistent systems of appraisal in place on a timescale that makes possible its objective of introducing revalidation in late 2012. (Paragraph 37)

Requirements on doctors

8.  It is clearly undesirable that doctors should be required to provide an immense amount of documentation for their appraisals. We agree that much of what is required should already be in place, and that if institutions have effective systems for clinical governance then information that is required for that use will also be available for appraisal. (Paragraph 44)

9.  The Committee supports the approach set out in the GMC's consultation review document aimed at making the process simpler and more flexible. In particular we agree that the different components of revalidation should be integrated into a single process, and that the requirements of that process should be integrated into the appraisal and clinical governance systems operated by employers. (Paragraph 47)

Patient and colleague involvement

10.  In its response to the consultation the GMC commits itself to further development of its proposals for colleague and patient feedback. We welcome this commitment; we hope the GMC will undertake a review of best practice in gathering the views of patients and colleagues and develop its proposals in the light of that review. (Paragraph 53)

Responsible officers

11.  We believe the risk of conflicts of interest arising from the dual role of medical directors as Responsible Officers within the revalidation system, and members of the employers' senior management team, is real. (Paragraph 56)

12.  We also believe, however, that this is the inevitable consequence of using appraisal as the basis of revalidation. Appraisal is part of robust clinical governance and is a key requirement of good management; it is therefore, inevitably, part of the responsibility of the medical director of the employer. (Paragraph 57)

13.  In the light of this unavoidable risk of conflicts of interest arising we recommend that the GMC publish clear guidance to Responsible Officers about how such conflicts should be handled. We also recommend that the GMC consider further what safeguards may be desirable to protect the interests of individual doctors in circumstances where they believe a conflict of interest may have influenced the decision of a Responsible Officer. (Paragraph 58)

14.  The GMC needs to satisfy itself within a timescale that will allow introduction of revalidation by 2012 that there is clarity about where Responsible Officers currently based in PCTs will be situated in future. (Paragraph 60)

Doctors with non-standard careers

15.  The Committee welcomes the clarification provided in the Medical Practitioners (Responsible Officers) Regulations 2010. It believes this clarification will resolve many uncertainties, but it looks to the GMC to provide a further detailed response to the other concerns raised on this subject in its consultation. (Paragraph 65)

Doctors from elsewhere in the European Union

16.  We regard the ability of a doctor to communicate effectively with his or her patient as fundamental to good medicine. As the body responsible for revalidation, and with a commitment to introducing it by late 2012, we expect the GMC to satisfy itself that it has the necessary powers to fulfil this role; if it is not satisfied (whether as a result of EU legislation or for any other reason) we expect it to say so publicly and report to Parliament what changes are necessary to allow it to fulfil its function effectively. (Paragraph 68)

Conclusion

17.  As we said at the beginning of this report, as a mechanism to improve the scrutiny of the GMC we now intend to exercise the accountability function nominally held by the Privy Council on behalf of Parliament. (Paragraph 69)

18.  In order to do this, we expect to invite the GMC to give oral evidence on its annual report each year. (Paragraph 70)

19.  We look forward to discussing these and other issues with the GMC at the first of these regular meetings later in the year. (Paragraph 71)


 
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Prepared 8 February 2011