Revalidation of Doctors - Health Committee Contents

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 of Doctors.

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.


2.1.   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.


4.1.   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 lower—the doctors in question will be able to practice medicine whilst acting as the responsible officer—this will ensure increased costs to Recruitment Agencies.

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 that information.

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 maintained.

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.

November 2010

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