Written evidence from the Academy of Medical
Sciences (REV 30)
The Academy of Medical Sciences welcomes the opportunity
to respond to the Health Select Committee's inquiry on revalidation.
In September 2009 we published a position paper on revalidation,
and in addition to responding to specific consultations on revalidation,
we have engaged closely with the Department of Health, General
Medical Council (GMC) and the Academy of Medical Royal Colleges,
as well as a range of medical constituencies across the university,
industry and healthcare sectors.
The UK benefits from a first-class medical workforce,
with clinicians undertaking diverse roles across a range of settings
that contribute to the development and delivery of clinical service.
It is important that any new reforms serve to protect and further
promote the UK's ability to achieve excellence and do not bring
unintended consequences.
The proposed revalidation proposals are a culmination
of work undertaken by a number of organisations. The Academy views
this an opportune time to carefully review the objectives of revalidation
and ensure that the proposed processes and supporting documents
are proportionate, workable for front line clinical service, and
meet public expectation in a cost effective manner. We therefore
welcome the GMC's response to their consultation "Revalidation:
the way ahead" published on 18 October 2010.
It is essential that sufficient time is allocated
to reviewing and refining the proposed revalidation processes
prior to implementation and therefore we welcome the Secretary
of State's decision to extend the current pilots. We support a
careful, incremental approach; the pilots should not just focus
on clinicians in mainstream NHS posts but include those working
in other settings. The pilots must be robustly evaluated and the
findings shared with the medical community, prior to full implementation
of revalidation.
The Academy's position paper, sets out a number of
principles of revalidation, however we would like to emphasise
the following:
AIMS OF
REVALIDATION
The Academy endorses the GMC's principle that revalidation
should focus on instilling robust local governance across all
areas of medical practice. There are numerous examples of localities
with excellent governance; extending good practice will reap rewards
in strengthening medical workforce management and providing world-class
healthcare. A simple, flexible system that strengthens and empowers
local governance with national support from the GMC is highly
favourable.
IMPLEMENTATION OF
REVALIDATION
The Academy strongly urges the GMC to adopt a simple,
pragmatic and cost-effective approach to revalidation. A streamlined
process is essential to avoid both unnecessary financial and opportunity
costs.
COMPETENCY BASED
ASSESSMENT
As set out in our response to the Academy of Medical
Royal Colleges' consultation on specialist standard frameworks,
it is imperative that revalidation focuses on the competency of
a clinician to deliver their defined and agreed job plan. We have
reviewed the Specialty and General Practice Frameworks and whilst
the proposed standards and attributes for each assessment domain
are uncontroversial, we strongly question the effectiveness of
introducing so many criteria, and the requirement for collecting
vast amounts of detailed supporting information. Clarity is needed
on how some of the information will help to assess whether an
individual doctor is safe and qualified to undertake specialist
practice. Care must be taken to ensure that perceived quality
is not confused with competence.
The frameworks require evidence of participation
in a wide range of clinical activities. This approach could disadvantage
individuals who do not undertake full-time clinical service, including,
but not limited to, those who undertake other roles, for example:
clinical academics and individuals working in the pharmaceutical
industry and public administration. Focusing upon a smaller number
of core domains, each allowing a range of supporting evidence
would help these individuals to demonstrate their commitment.
It would be timely to consider alternative models
of how the current proposals might be incorporated into existing
local assessment mechanisms in a manageable way that brings real
value to both the doctor and their area of practice.
SUPPORTING CLINICIANS
WHO PURSUE
A VARIETY
OF ROLES
The Government's decision to protect investment in
health and medical research in the recent spending review means
that the UK can continue to translate extraordinary advances in
medical science into benefits for patients and society. To support
this translational science agenda, it is vital that the contribution
of clinicians whose work involves a significant component, or
a preponderance, of research, teaching and other academic work
is greatly valued. University Medical Schools and their NHS partners
have well-established mechanisms for jointly agreeing and appraising
the clinical service and research contribution made by clinical
academic staff, and it's important that these relationships are
not compromised by the proposals for revalidation. Careful consideration
must be given to clinicians who are currently working outside
the NHS or established medical centres; individuals working in
other settings must be revalidated equitably.
In developing appropriate mechanisms to revalidate
clinical academics, it is imperative that appraisals adhere to
the Follett principles. It is also essential to define the boundaries
of revalidation; there must be recognition that many of the "non-clinical"
activities undertaken by a clinician might not be relevant to
their professional status. Revalidation should only consider those
aspects of a clinician's activities for which it is a requirement
to be a doctor. Other activities should only be relevant if they
raise concerns about honesty and integrity, for example, research
fraud.
OVERSIGHT OF
REVALIDATION
The GMC must provide national oversight of the revalidation
process in its entirety. The Royal Colleges and Faculties provide
an essential national role in maintaining the standards for the
knowledge base within specialties, by setting the training curriculum
etc. The Colleges and Faculties have an important advisory
role, but involving them directly in the evaluation
and revalidation of individual doctors would be unwieldy
and almost certainly inappropriate. However, we support the proposal
for Colleges and Faculties providing appraisal and Responsible
Officer facilities to specialists who work outside of managed
healthcare environments.
November 2010
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