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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