Written evidence from the Recruitment
and Employment Confederation Medical Sector Group (REV 32)|
1.1. This Submission is in response to the House
of Commons Health Committee call for evidence on the Revalidation
1.2. This response outlines the role of the
REC and REC Medical, the interaction between our members, Locum
Doctors and the impact of the revalidation process.
2. ABOUT THE
REC AND REC MEDICAL
2.1. The REC represents around 8,000 recruitment
company branches, estimated to constitute half of all Recruitment
agency branches but a higher proportion by turnover.
2.2. Over 85% of the industry is made up of small
businesses. In 2008-09 the recruitment industry generated turnover
in excess of £22 billion and placed 1 million people in temporary
jobs every week in every sector in the labour market.
2.3. REC Medical is one of 20 specialist groups,
covering the entire Recruitment industry run by the REC. REC Medical
represents agencies who deal primarily with the placement of Locum
Doctors, Nurses and Emergency support staff. The group comprises
of over 3,500 Recruitment Agencies across the UK.
2.4. The REC supports members with their responsibilities
through the provision of free legal services, model contracts
and advice and guidance on setting up and agency. Correct and
ethical recruitment is the prime concern of the REC and all our
members' sign up to a code of professional practice and are subject
to random inspections.
3.1. REC Medical fully supports all measures
to enhance safe and ethical recruitment. The general principles
behind the revalidation of doctors are sound. However, the practical
implementation of revalidation procedures raises specific concerns
for locum doctors working on a number of different sites and often
through several different agencies.
3.2. The REC Medical Sector Group is committed
to finding workable solutions and is already working with the
General Medical Council (GMC) and the Department of Health (DoH)
on these issues.
4. FEEDBACK FROM
4.1. Feedback from REC Members has identified
a series of concerns that would need to be addressed in order
to make the system workable.
4.2. Concerns about Responsible officers; It
is estimated that the total cost of employing a qualified doctor
is in the range of £125,000 to £200,000 on-cost figures.
Whilst the net cost will be lowerthe doctors in question
will be able to practice medicine whilst acting as the responsible
officerthis will ensure increased costs to Recruitment
4.3. These increased costs have a particular
impact on smaller firms who cannot afford to absorb these costs.
Out of the 53 Locum agencies operating within the NHS framework
94% are small or micro size (less than 50 and 10 employees respectively)
and 6% are of medium size (50 or more employees).
4.4. The onus cannot be put solely on agencies.
For instance, it is unrealistic to expect all agencies to have
responsible officers in place within their organisation. While
larger agencies might be able to have built-in solutions, smaller
agencies would find it impossible to have responsible officers
in their organisation.
Whilst the REC welcomes moves towards enhanced standards,
ensuring that the quality of medical practioners is improved,
they are concerned that special considerations need to be made
as regards to the costs of implementing these changes.
5.1. Need to understand the nature of the locum
market; career locum doctors would have very different requirements
to locums who are operating on a temporary basis. Where a locum
works for one agency there must be an effective method of sharing
5.2. It is crucial for the GMC to take the lead
in developing regional lists of Responsible officers ensuring
that they are readily available. REC members have highlighted
the cost and difficulty of reaching a responsible officer, primarily
due to the lack of availability of Consultants. It is also important
that there is an established system whereby Recruitment agencies
would be able to pool Responsible officers to minimise costs without
compromising on quality.
5.3. There needs to be extensive clarification
as to the responsibilities, skills and qualifications of responsible
officers. Their clinical effectiveness and quality must undergo
constant inspection, ensuring that the necessary standards are
5.4. For locums in PCTs, the assessment could
be done through the existing performance register. For locums
in secondary care, the appraisal could be done through a PCT in
the area in which they live. It was also suggested that a mechanism
could see Foundation Trusts get involved in assessing the locums
for a fee.
5.5. Registration of Responsible officers needs
to be portable to ensure that there are not unnecessary delays
to the process of hiring locum doctors. This problem is particularly
acute given existing concerns about the working time regulation
and the effect that this is having on the effective supply of
Doctors to the NHS.
5.6. Assessing non-UK doctors. Questions remain
over the way in which non-UK doctors could be fully assessed.
As a result of some of the staff shortages highlighted above it
is likely that we will continue to see more doctors coming in
from overseas even on short term assignments from other EEA countries.