Written evidence from the Royal College
of Radiologists (REV 18)|
1. The Royal College of Radiologists (RCR) has
approximately 8,300 members and Fellows worldwide representing
the disciplines of clinical oncology and clinical radiology. All
members and Fellows of the College are registered medical or dental
practitioners. The role of the College is to advance the science
and practice of clinical oncology and clinical radiology through
a range of activities, including setting and maintaining the standards
for entry to, and practise in, the specialties of clinical radiology
and clinical oncology, and arrangements for continuing professional
development (CPD) in both specialties.
2. This response outlines the RCR's views and
approach to revalidation. The RCR has consistently advocated a
straightforward, proportionate and practicable concept of revalidation.
The RCR piloted this approach in 2008. This response details our
views on revalidation and outlines the method of our revalidation
pilot and the outcome. We conclude that a workable and equitable
system of revalidation should be implemented to maintain the confidence
of doctors and patients in the process.
It accepts that revalidation will occur through a
system of strengthened medical appraisal and we do not address
3. THE RCR'S
The RCR has remained consistent in its approach to
this subject since the publication of the White Paper: Trust,
Assurance and Safety (1) in 2007. It believes that the process
should be straightforward, easy to integrate into a doctor's normal
working life and, without undue expenditure for the health service
or stress for the individual, provide reassurance to patients
and employers that a doctor has no problems to address in either
their general professional performance or specialist practice.
4. We believe this to be the essence and spirit
of revalidation, rather than the provision of reams of documents
which allow much variation in the evidence and could actually
mask an underlying problem. We contend that a uniform approach
and simple system is eminently feasible. The current RST pathfinder
pilots use a complex system, which early reports suggest is very
cumbersome from an IT perspective; in addition the general attributes
of a doctor and the specialist aspects of their performance within
the pilot are completely separate, and most importantly, the evidence
is not the same for all doctors.
5. This variation in the type and quantity of
evidence runs the risk of introducing unfairness, which if allowed
to propagate through into the revalidation system risks producing
legal challenge, potentially discrediting the system. Variation
has been difficult to overcome because Colleges had made specific
plans for recertification, in some cases quite complex, involving
the building of electronic portfolios and appraisal systems, prior
to it being merged back into a single process of revalidation.
The Medical Royal Colleges were asked by the GMC to set out how
doctors in each specialty should revalidate. They developed specialist
frameworks which were "bolted on" to the RST developed
pilot system, and are being tested in the pathfinder pilots. Reports
from pilot sites suggest that the system is unwieldy. The RCR
suggested to the Academy in July of this year that it would be
better to streamline the frameworks into one generic template
which embedded and incorporated specialty data within the generic
questions. The Academy agreed with this suggestion and has subsequently
liaised with the GMC about it.
6. In the current pilots there is a complex system
of electronic mapping of all the evidence across to the GMC 12
attributes which is again not uniform, and appears cumbersome.
7. THE RCR'S
(a) There now needs to be firm leadership of
this process, as it is currently unclear to doctors at least,
who is in charge. Early reports from the pilot scheme risk reducing
confidence in the process developed by the Revalidation Support
Team, the GMC has consulted but not yet given any specific guidance,
and the profession has not yet been able to develop a suitable
scheme, agreed by all.
(b) Clarity of the roles and responsibilities
of the various bodies would be helpful at this stage, although
it would not be unreasonable to suggest that the GMC should dictate
the system by which it would accept a recommendation to renew
a doctor's licence. We therefore suggest the GMC should lead,
whilst working closely with the NHS in the four UK countries and
the Academy. However we hope that complex mapping systems to GMC
attributes can be avoided.
(c) It is necessary to develop a much simpler
system with a single set of evidence for every doctor as soon
as possible, without waiting for detailed feedback from the pilots.
(d) The process for assessing those whose conduct
or professional capability is questioned should be clear before
revalidation is introduced, as should the methods of remediation.
8. In 2008 the RCR piloted a process of what
was at that time still recertification. This included a small
number of volunteers (31), but the returns were evaluated by a
panel at the RCR which included a patient representative (chair
of the RCR Clinical Radiology Patients' Liaison Group). The conclusion
of the assessors following analysis of the anonymised returns
was that this system would allow a judgement to be made on whether
there were likely to be any significant performance or behavioural
issues to address.
9. The pilot was based on the simple premise
that an adequately performing doctor should be able to demonstrate:
(a) Satisfactory peer/colleague and, where appropriate,
patient judgement of performance.
(b) Evidence that they acknowledge, and interact
with colleagues to learn from error.
(c) That they monitor and can demonstrate their
own personal performance.
(d) That they keep up with developments in their
specialty or area of practice.
10. This translated into four core pieces of
evidence which would capture all specialist performance and could
be customised for any specialty or any type of practice.
(i) Multisource feedback, and where appropriate,
patient feedback once in five year cycle
(ii) Annual evidence of reflection on discrepancy,
learning cases or error examples could include: reflection
on an individual error or learning case, attendance at morbidity
and mortality or radiology discrepancy meetings, reflection on
incidents or near misses.
(iii) One piece of evidence annually on their
own professional performance (Colleges and professional bodies
should advise on these) but examples could include personal audit
or outcome results, peer review, online self-testing results,
personal review of cases or team audit. The choice should be tailored
to individual practice, possibly with advice from the appraiser
on an annual basis in the personal development plan to ensure
sampling of whole practice.
(iv) Satisfactory Continuing Professional
Development (CPD) record.
11. These pieces of evidence cover, we believe,
all the requirements of the recertification part of revalidation,
and much of the relicensing requirement. To address all revalidation
criteria we would suggest the addition of, for example, the following
very straightforward information:
(v) Jobplan and workload.
(vi) Record of complaints, significant incidents,
(vii) Health record and personal statement.
(viii) Statement of probity.
(ix) Mandatory training record.
This system or some variant thereof would, we contend,
be proportionate, fair, and workable for all doctors.
12. The RCR has provided guidance on how to produce
the relevant evidence for appraisal/revalidation, together with
simple tools and templates, mostly on a single sheet, to be completed
for the doctor's record (2). They can be downloaded and stored
electronically by the individual, uploaded into any appraisal
system, or indeed printed out for paper-based appraisal. Such
tools could however be nationally developed for the generic aspects
of a doctor's practice, with a choice of specialty specific templates
produced by relevant Colleges and professional bodies.
13. The RCR's view is that revalidation should
be uniform across the profession and requires the same type of
evidence for all doctors; that relevant evidence should not be
difficult to obtain or time consuming to complete, and taken together,
would capture the doctor's whole practice in relation to their
obligations under the GMC's definition of Good Medical Practice.
It would provide reassurance for most doctors that they remained
fit to practise. To maintain the confidence of doctors and patients
in this process after such a long gestation period, it is important
that a workable and equitable method for revalidation should be
developed without undue further delay.
14. It is also important that a clear route for
the further assessment, and, where appropriate, robust and fair
systems to deal with retraining and remediation, of those whose
performance is called into question should be in place by the
time revalidation is implemented. Without this, major problems
are likely to arise for appraisers, responsible officers, employers,
those doctors whose practice is in some way called into question
and the patients they care for.
1. Department of Health. Trust, Assurance and
Safety. The Regulation of Health Professionals in the 21st Century.
(last accessed 26/10/2010)