Written evidence from NHS Employers (REV
1. NHS Employers represents employing organisations
in the NHS in England on workforce issues and helps employers
to ensure the NHS is a place where people want to work. NHS Employers
is part of the NHS Confederation.
2. Our role is to help employers understand
and contribute to changes in the recruitment, training and career
structure of the medical workforce in order to improve the quality
of patient healthcare. This includes providing general advice
and guidance on good practice, as well as representing NHS organisations
to policy makers. Further information on our role is provided
in the appendix.
3. We are fully behind the drive for successful
implementation of revalidation for doctors and we welcome the
Health Select Committee's involvement at this critical stage.
We are pleased to have the opportunity to submit evidence to this
- NHS Employers is at the heart of the discussions
on medical revalidation in England because employers are central
to the design, preparation and delivery of medical revalidation.
- We support the GMC's current plans for taking
revalidation forward as summarised in the GMC and the UK health
departments' statement of intent.
- We support the establishing of the Responsible
Officer (RO) role from 1 January 2011 through the measures set
out in The Medical Profession (Responsible Officers) Regulations
- The appointment of ROs is an essential step in
testing and preparing for revalidation. It should not be delayed
until the whole system is ready. It is over three and a half years
since the concept and underlying principles of revalidation were
set out in the UK Government's White Paper on professional regulations,
Trust Assurance and Safety - The Regulation of Health Professionals
in the 21st Century. There has been enough delay.
- We are conscious that the public expects employers
to assure themselves that their doctors are competent.
- Strengthened medical appraisal and robust clinical
governance systems must be achieved in any event.
- Barriers to successful strengthened medical appraisal
must be identified and addressed.
4. Medical revalidation is about reassuring government
and the public that doctors are competent to do what they are
employed or commissioned to do. Employers carry the vicarious
liability for the competence of their staff, including doctors,
and so are central to the design, preparation and delivery of
medical revalidation. We represent those employers in relation
to medical revalidation.
5. We have summarised our interest and activities
in relation to medical revalidation in an appendix to this evidence.
THE GMC PROPOSES
6. We agree fully with the General Medical Council
(GMC) statement that the purpose of revalidation is to assure
patients and the public, employers and other healthcare professionals
that licensed doctors are up to date and fit to practise.
7. We believe that revalidation should be designed
to build on existing arrangements in an effective, proportionate
and affordable manner.
8. Employers already accept that they have a
responsibility to assure themselves that their doctors are competent.
They believe that strengthened annual appraisal, continued professional
development and robust clinical governance are necessary to ensure
that assurance can be given to patients and the public at large.
We think the public expect that assurance and indeed may be surprised
that such a process does not already exist. These processes build
on existing good practices in preparation for revalidation.
9. The GMC's response of 18 October to their
major revalidation consultation takes on board our key concerns
about keeping the system streamlined and straightforward, and
building on existing systems and clinical evidence rather than
inventing wholly new assessment methodologies. We do not want
to overburden employers or the doctors themselves. We believe
that effective appraisal is key to revalidation, and this should
be linked to organisational and business objectives to ensure
that its introduction is both affordable and cost-effective.
10. Our views on the GMC's response to their
consultation can be read in full at
11. We welcome the commitment that the GMC has
made to streamline the process of revalidation, particularly in
the current climate. We want revalidation to be effective and
cost effective. The promise of support from the GMC, the four
health departments and other organisations to help employers to
get ready is very helpful. The challenge that employers now have
is to ensure their systems of medical appraisal and clinical governance
are ready and robust enough to support revalidation. That will
require the appointment of Responsible Officers to proceed as
soon as possible. Responsible Officers will take responsibility
at Board level for implementing the requirements demanded of Trusts
in supporting medical revalidation.
12. Revalidation should be seen by employers
as contributing to and stimulating their efforts to achieve organisational
excellence and high quality care, rather than as a separate priority
that they need to deliver. Our earlier written submission to the
GMC consultation can be read in full at
THE GMC AND
UK HEALTH DEPARTMENTS'
ON 18 OCTOBER
13. Employing organisations have told us that
they want timetable and milestones published. The statement of
intent does this and sets out the steps employers need to take
to assess their own readiness. After many years of preparation
they are keen to move from the design phase to the implementation
phase. Target dates will help Responsible Officers begin the local
task of ensuring a smooth pathway to revalidation. Indeed the
Responsible Officer role is vital, regardless of the legislative
requirements of revalidation, to make sure that organisations
adhere to strong clinical governance and strengthened medical
14. We intend to test the statement of intent
with employers at our forthcoming NHS Employers' conference (16-18
November 2010) and at the Medical Directors' conference (25 November)
to identify any barriers to successful implementation and what
further support can be provided by the key partners.
15. The pilot exercise is far wider than the
exercises in London and West Yorkshire, which were simply about
the proposed role of the GMC affiliates, a role which employers
have supported as a useful independent addition to the process
of recommending for revalidation or otherwise. We are a key stakeholder
in the Pathfinder Pilot Strategic Oversight Group (PPSSOG) tasked
with evaluating the progress of the pilots and whether the processes
are right, affordable and deliverable for wider revalidation.
We are particularly keen to be sure that any barriers to successful
strengthened medical appraisal are identified and addressed.
2012 AT THE
16. Fortunately many employers already have clinical
governance and appraisal systems in place which provide a practical
platform upon which to implement revalidation. However, the Secretary
of State's decision to extend the piloting period for a further
year will provide a welcome opportunity to ensure that, when a
decision is made to move to full implementation, the system will
be practical and effective. We believe this is critical to ensure
that the revalidation process is effective, proportionate, affordable
and good value.
17. We believe it is also necessary during this
extension period to look in further detail at non-NHS clinical
responsibilities such as duties performed in the independent sector
and the quality assurance of agency medical locums. In both these
areas the sharing of evidence across career pathways and the early
identification of shortcomings and proposed remedial action will
be vital to the overall success of the scheme.
18. We will play our part as partners in revalidation
to provide sufficient evidence to government for them to make
their decision in late 2012 on whether revalidation is effective
and cost effective.
19. However, employers in both the NHS and the
independent sector would welcome, sooner rather than later, a
realistic estimate of the anticipated costs of revalidation based
on the simplified approach which is now preferred, and taking
into account the new organisational structures and lines of accountability
proposed for the NHS, particularly within primary care.
20. While we support a proportionate approach
to revalidation based on existing processes, there will nevertheless
be both immediate and ongoing costs to be met, including the training
and re-training of appraisers, identified remediation costs where
doctors in difficulty are identified across the five year cycle,
and supporting quality multi-source feedback. Employers need to
be able to plan for those costs now in order to meet the significant
challenges they face over the coming years to deploy available
resources to meet increasing demand. The current revalidation
model assumes an employer-led, management-based process when the
future may be less structured.
21. It will be challenging to identify "cost-effectiveness"
arising from revalidation in isolation from other measures designed
to improve quality patient care and productivity through the current
QIPP arrangements. This will also have to be set alongside the
less-quantifiable gains in public protection and confidence in
the profession though a robust revalidation process.
OFFICER (RO) REGULATIONS
22. We have noted that the British Medical Association,
the trade union representing the majority of UK doctors, have
lobbied the House of Lords Scrutiny Committee about The Medical
Profession (Responsible Officers) Regulations 2010. Their submission
was a repeat of their submission to the GMC's consultation The
Way Forward. This consultation was responded to by the GMC
on 18 October 2010 and we were pleased to see the GMC accept most
of the points made by ourselves and by the BMA, for example about
the need to make the processes more straightforward and proportionate
and to reduce the burden on employers and on doctors.
23. We differ from those in the medical profession
who support revalidation in principle but would have us delay
implementation of the RO regulations until we have a "perfect"
system. It is an iterative process; we have to start somewhere
in beginning the revalidation cycle to learn by sharing good practice
and supporting ROs in their local work. We welcome the GMC's announcement
of the formation of a regionalised network of support for ROs
in their work.
24. Some may argue that an RO recommendation
not to revalidate is in some ways career limiting. We believe
this can be mitigated by having an open, fair, collaborative process
based on mutual trust where it is in the interest of both the
employer or commissioning body and the doctor to satisfy themselves
that they can both provide the best possible care to patients.
If there is a dispute then there should be the means to resolve
this through the constituent parts of the process (e.g. dispute
resolution in appraisal) before the RO makes a recommendation.
NHS EMPLOYERS' INTEREST
(a) Employers recruit, deploy, train, motivate
and reward doctors in the NHS. They provide opportunities for
training to the doctors of the future, from medical student placements
through postgraduate training to the employment of specialty practitioners
in the hospital sector, and the contracting of General Practitioners
in primary care.
(b) They aim to do this in a supportive learning
environment which provides quality assurance to patients through
robust clinical governance systems, backed by regular appraisal
and continued professional development of the doctors themselves.
(c) From the outset of the policy decision to
introduce a licence to practise in the UK supported by a system
of regular revalidation, employers have sought and delivered engagement
in the design of the system and helping employers to prepare for
(d) We have provided evidence to the GMC's consultation
exercise and were very pleased to see that their 18 October response
broadly agrees with that evidence on the question of streamlining
and proportionality, and the centrality of the employers in making
the process work effectively.
(e) We believe it is now time to move from "design"
to "doing" and we have therefore communicated with employing
organisations in the NHS by:
- Producing a briefing paper (June 2009) for employers
on what revalidation means
- Having regular input into the GMC's revalidation
communications strategy by making sure that messages are targeted
toward employers and clearly understood by them
- Maintaining up-to-date web-based information
for employers on revalidation: see
- Supporting regional workshops on revalidation,
notably in London, Yorkshire and the Humber, and in the North
- Worked hand in hand with the NHS Revalidation
Support Team (established by the Department of Health) to provide
ongoing evaluation of the pathfinder pilot projects
- Holding well-attended sessions on revalidation
at the NHS Employers' annual conference in 2008 and 2009. Another
such session is scheduled for 17 November 2010.
(f) We have represented the voice of employers
through the various workstrands established to support revalidation,
including the UK Revalidation Programme Board, its Executive Board,
its workstream on remediation, through to the Department of Health
Professional Standards Board, the England Delivery Board and the
Pathfinder Pilot Oversight Group (PPSSOG).
23 RESPONSIBLE OFFICER (England).
Subject to parliamentary approval of The Medical Profession (Responsible
Officers) Regulations 2010, on 1 January 2011 it is intended that
all designated healthcare organisations (Trusts) will have appointed
a Responsible Officer (RO) who will often, though not necessarily,
be the medical director. All doctors working for the Trust (secondary
care) or who are included on its performers list (PCO's) will
come under the RO's remit and all working doctors will be required
by the GMC to relate to a specific RO. Advice on finding an RO
will be available. The ultimate function of the RO will be to
help doctors prepare for Revalidation and make a recommendation
to the GMC once every five years, through a recommendation to
the Trust Board, about an individual doctor's readiness for Revalidation.
In order to be able to make and justify a recommendation, the
RO will need to have robust systems in place within their Trust.
The RO will take responsibility at Board level for implementing
the requirements demanded of Trusts in supporting medical Revalidation.
They will be responsible for the systems needed to support it
and will be accountable for the recommendations that are ultimately
made to the GMC, about an individual doctor's readiness for Revalidation.
They will need to ensure that, over the five year Revalidation
cycle, that an annual appraisal is carried out to a sufficiently
high standard and that the appraisal system links adequately with
other Trust systems, ensuring clinical governance data is available
to support a review of a practitioners work and inform service
They will work with doctors in addressing any shortfalls identified
- including offering support in addressing the underlying causes
whether educational, performance or health related, ensure any
concerns or complaints have been addressed, and collate this information
to support a recommendation on revalidation of individual doctors
to the GMC. Back