Revalidation of Doctors - Health Committee Contents

Written evidence from the Association of Anaesthetists of Great Britain and Ireland (REV 37)

1.  The AAGBI welcomes the opportunity to submit written evidence to the House of Commons Health Select Committee inquiry into the revalidation of doctors. The AAGBI is a voluntary, professional, representative organisation founded in 1932. It has in excess of 10,000 members; more than 85% of NHS consultant anaesthetists are members. It also represents the majority of NHS Intensive Care and Pain Medicine consultants. The two primary objectives of the AAGBI and its charitable arm, the AAGBI Foundation, are to "advance and improve patient care and safety in the field of anaesthesia and disciplines allied to anaesthesia" and to "promote and support education and research in anaesthesia, medical specialties allied to anaesthesia and science relevant to anaesthesia".

2.  The AAGBI's principle concerns about revalidation are:

(a)  The real purpose of revalidation.

(b)  Resources (time and funding) for effective appraisal including 360 degree appraisal relevant to anaesthesia.

(c)  Revalidation relevant to individual practitioners.

(d)  The role and competing interests of the Medical Royal Colleges.

(e)  The role and competing interests of Responsible Officers.

(f)  The lack of evaluation of current pilot schemes.

(g)  The timing of introduction of the final scheme for revalidation.

(h)  The need for continuing evaluation and modification.

(i)  The need for an effective and transparent remediation process.

3.  The AAGBI remains uncertain of the aims of revalidation. If it is to be a positive affirmation of the ability of doctors safely to care for patients, then the current proposals, based on a rigorous appraisal process will be adequate. However if the intention is to detect "rogue" doctors such as Shipman and Ledward, it is unlikely to succeed. The AAGBI has seen little evidence for the detection of "rogues", most of whom come to light after critical incidents, complaints or criminal investigations. There must be honesty as to the true purpose of revalidation lest politicians and the public receive false re-assurance.

4.  For revalidation to be effective the underlying process of appraisal must be rigorous and not, as may happen for many at present, a simple "tick box" exercise. This is particularly important at a time when public spending is facing justifiable review. Doctors must be given the time to achieve their personal Continuing Professional Development (CPD) needs, and adequate funding. Medical CPD of quality is not cheap, and study leave budgets provided by employers are often insufficient. At a time when health employers wish to meet financial challenges, any reduction in the opportunity and funding of CPD will make meaningful revalidation impossible. 360 degree multi-source feedback must be validated and relevant to the practice of the individual, rather than simply an "off the shelf" commercial package.

5.  Revalidation must be relevant to the work any individual doctor does (although there are core skills and knowledge pertinent to all medical practitioners which would allow relicensure). Most AAGBI members will be Fellows of the Royal College of Anaesthetists (FRCA) (or equivalent) but may then pursue very different careers within Anaesthesia, Intensive Care or Pain Medicine, or combinations of these. Many anaesthetists go on to careers in senior medical management. The AAGBI is concerned that the CPD requirements are relevant to the individual's job plan; much of the syllabus of the FRCA may be irrelevant to, say, a Consultant in Chronic Pain; too broad a requirement may mean that limited CPD resources are effectively wasted.

6.  At present Royal Colleges advise the General Medical Council (GMC) of the specialty requirements for CPD for revalidation. Those Colleges may also validate the educational content of meetings and material of other providers against the CPD requirements (and may charge a fee for this). The same Colleges may also be providers of CPD, which they self-validate. There is the distinct possibility of a clear competing interest.

7.  The AAGBI agrees with its close partner the British Medical Association (BMA), whose evidence it has seen through representation on BMA's Central Consultants and Specialists Committee Anaesthetic Sub-Committee that there are concerns about the roles, responsibilities and appointment of Responsible Officers (ROs). Medical Directors are already busy individuals; it is difficult to see that any could take on the additional time and responsibility of the RO role. As Board Members of employers they would have clear conflicting interests, and duties of confidentiality, in the support and management of individual doctors through revalidation, particularly doctors who may be experiencing difficulties. Although of less relevance to members of the AAGBI, other current government proposals for Strategic Health Authorities and Primary Care Trusts will make the appointment of ROs for doctors employed directly or indirectly by these organisations extremely difficult.

8.  The AAGBI would support the current extension of the pilot schemes for revalidation, even though this will defer implementation of the final scheme. The poor experience of the "big bang" introduction of radical changes in medical employment such as Modernising Medical Careers and the Medical Training Application Scheme should serve as examples of how not bring about reform. The current government has vowed to stop "top-down" changes. If revalidation is to be successful, it must have the support of doctors. This means careful evaluation, and if necessary re-evaluation of resultant changes, to produce a system that is workable and achieves what was intended. It is surely better that revalidation works than its implementation by any specific, and arbitrary date? Once introduced revalidation must the subject of continual re-assessment, re-evaluation and modification; it is unlikely that any scheme will be perfect from the start.

9.  For most doctors appraisal and revalidation will be a straightforward process. However it is thought that about 1% to 1.5% of doctors will have concerns raised about their performance. These individuals will need some participation in remedial activity to revalidate. The AAGBI is concerned that a robust process for remediation is not available. The AAGBI is concerned about the role of the Royal Colleges in this process. There is a possibility that the existing relationship between the Colleges and their Members/Fellows members may change and a formal role in remediation would lead to the Colleges assuming a more regulatory function. It is vital that adequate remediation support is in place before the introduction of revalidation. This process will need to be monitored robustly.

10.  The AAGBI would be happy to present oral evidence if this would assist the Committee's enquiry.

November 2010

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