Revalidation of Doctors - Health Committee Contents

Written evidence from Care Quality Commission (REV 33)


1.1  The Care Quality Commission (CQC) welcomes the opportunity to provide commentary to the Health Select Committee on the revalidation of doctors. CQC responded to the General Medical Council (GMC) consultation on revalidation earlier in the year and would be happy to supply this to the Committee.

1.2  It should also be noted that revalidation is being considered for other professions and similar issues identified below will apply. There is currently a consultation on revalidation of dentists and we are aware that the Nursing and Midwifery Council is considering options for revalidation of nurses and midwives. We believe the Health Select Committee should consider the impact that their recommendations may have on other future revalidation schemes.


2.1  CQC is the statutory regulator of health and adult social care providers in England. All providers must be registered with us; it is the legal entity (whether this is an individual, partnership or organisation, such as an acute trust) that provides the regulated activity to patients that must register, and once registered we will monitor their compliance on an ongoing basis. To be registered providers must meet essential standards of quality and safety. These have been developed by CQC as a result of legislation set out in the Health and Social Care Act 2008 and CQC's (registration) Regulations 2009.

2.2  We have developed and use a risk-based approach to monitor compliance and we are able to use a wide range of enforcement powers to make sure that swift action is taken where services are failing to meet these requirements. All NHS trusts, adult social care, independent hospitals and clinics (which fall within the rules) should now be registered with us. Primary dental care providers will come into registration from 1 April 2011 and primary medical care providers from 1 April 2012.


3.1  It is vital that the systems of regulation for doctors and for healthcare providers must be aligned, while their unique contribution to protecting public well-being are recognised and maintained. There are several key issues that need further development and consideration as revalidation is introduced to ensure that alignment is as effective as possible.

3.2  CQC and the GMC have a good working relationship. We recognise that we have a responsibility to work together, and with other professional regulators, to share information appropriately in order to safeguard the well-being of the public and minimise the burden of regulation.

3.3  There will inevitably be some areas of overlap and issues of mutual interest between the two types of regulation. Where these overlaps occur the regulators must work together to share relevant information and articulate the similarities and differences in order that doctors and/or providers are clear about both sets of requirements. We recognise that those doctors that work on their own or in a very small provider and will need support to understand how they can use information as evidence toward revalidation as well as ongoing compliance with CQC registration requirements.

3.4  Clarity regarding these regulatory systems is essential to ensure that poor practitioners do not fall through the regulatory net, that patients are effectively safeguarded from poor quality care. The public can have confidence in the quality of care offered both by individual doctors and by organisations providing care. This will also ensure that the profession is clear about where regulatory responsibility lies; reducing confusion and enabling doctors to focus on providing high quality patient care.


4.1  We have a close working relationship with the GMC and in May 2010 signed a memorandum of understanding (MoU). The MoU details how we will work together to share information in order to safeguard the well-being of the public. In particular we will share:

  • Information about an individual's fitness to practice.
  • Concerns about GMC approved practice settings.
  • Information that may call into question an organisation's suitability as a learning environment, and
  • Information about the robustness of appraisal and clinical governance systems.

4.2  The MoU will be supported by a specific information sharing agreement.

4.3  The MoU currently recognises the need for cooperation between the GMC and CQC in developing the system of revalidation of doctors. There are a number of key issues that need to be taken into account as revalidation is implemented, and the MoU will be amended accordingly.


5.1  When the Health Select Committee is considering the implementation of revalidation we believe it is important to recognise the different roles of registration and revalidation. Registration provides assurance that an organisation delivering services meets essential standards of quality and safety. However, it does not provide assurance that every individual doctor delivering those services is clinically and professionally competent to undertake their specific role. This is the role of professional regulation, and thus revalidation.

5.2  It is not CQC's role to assess the competence of individual doctors. However, it may be more likely that concerns about individual competence will not be addressed in an organisation where governance arrangements are poor or where staff are not adequately supported. These organisations may also be at risk of not implementing appropriate appraisal and revalidation systems and processes. Our compliance monitoring should identify organisations where these risks exist. For this reason, information about an organisation's registration will be of interest to the GMC. For example, registered providers must meet essential standards about ensuring that:

  • staff have the right qualifications, skills and experience and are fit to do their job;
  • staff receive appropriate support, supervision and training, and
  • the quality and safety of services is monitored, learning is taken on board and improvements are made.

5.3  As revalidation is implemented we will look at the systems and processes that organisations have in place to support revalidation in relation to the essential standards identified above. We will need to work with the GMC and responsible officers to share information about concerns that may either: impact on a provider's compliance with essential standards; or vice verse, that may affect the quality of appraisal and revalidation decisions.

5.4  As well as systems to support doctors, and other staff, there are others ways in which the registration essential standards and the standards that must be met by individual doctors for revalidation cover similar issues. For example, in order to comply with essential standards a registered provider is required to ensure that care delivered follows evidence based guidelines. Similarly, appraisers and responsible officers, as part of the revalidation process, will want to be assured that an individual doctor's practice is evidence-based.

5.5  Given that there is some overlap between the expectations of registration and the content of professional standards it is important that both organisations are able to clearly articulate the benefits of each system.

5.6  We recognise that doctors that work independently, or within a very small provider, may feel that the process of revalidation and registration together will be burdensome. We are committed to supporting these doctors to use the evidence they have for both purposes where overlap exists. We also hope that effective partnership working between ourselves and the GMC will, where concerns are identified, allow us jointly to take decisions about the appropriate response.

5.7  We are aware that the Department of Health is reviewing the scope of registration for some private doctor's services. We expect that the role of revalidation will be considered as part of this review. We will work with the Department and the GMC to ensure that an appropriate and proportionate solution can be found.


6.1  The complementary regulatory systems delivered by CQC and the GMC will offer patients and the public greater assurance about both the professional standards of the doctor and the quality of care of the provider they visit. Patients will, in future, be cared for by registered providers, where registration means the organisation is meeting essential standards and safety; and by revalidated doctors, where revalidation means that the doctor is competent to undertake their role.

6.2   We hope that the Health Select Committee is assured that the two regulatory bodies will continue to work closely to share information appropriately, both to safeguard patients and reduce burden on providers and doctors, as registration develops and revalidation is implemented.

November 2010

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