Revalidation of Doctors - Health Committee Contents


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 this aspect.

3.  THE RCR'S APPROACH TO REVALIDATION

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 SUGGESTIONS

(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.

AN EXAMPLE OF A SIMPLE SYSTEM

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, and praise.

(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.

RCR REVALIDATION TEMPLATES AND TOOLS

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.

CONCLUSION

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.

15.  REFERENCES

1.  Department of Health. Trust, Assurance and Safety. The Regulation of Health Professionals in the 21st Century. London, 2007.

2.  http://www.rcr.ac.uk/content.aspx?PageID=1511 (last accessed 26/10/2010)

November 2010


 
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