2 Revalidation of doctors and remediation
of practice |
Scrutiny of revalidation
15. From 3 December 2012 the doctors registered with
the GMC and licensed to practise medicine in the UK will be under
new requirements to provide evidence of their ongoing fitness
to practise. This
revalidation of doctors is a process designed to provide further
assurance to the public that the doctors the GMC has licensed
to practise medicine in the UK are up to date in their medical
understanding and fit to practise medicine.
16. The GMC had 245,903 doctors on its register in
2011, of which 90,639 (37%) had their place of primary medical
qualification outside the UK (see Table 1). 232,769 doctors were
licensed by the GMC to practise medicine in the UK.
It is in the interests of good medical practice that all licensed
doctors are subject to regular reviews of their practice.
Table 1: place of primary medical qualification
of doctors on the UK medical register, 2011
|Place of primary medical qualification
||Registered doctors, 2011
|EEA or Switzerland
Source: The state of medical education and practice
in the UK 2011, General Medical Council 2012, pp 18-19
*IMGInternational Medical Graduates: doctors
who are either (a) nationals of a country outside the UK, the
EEA or Switzerland who graduated from a medical school outside
the UK or (b) UK nationals who have graduated from a medical school
outside the UK, the EEA or Switzerland.
17. This Committee has over the course of this Parliament
taken a close and continuing interest in the proposals for revalidation
of doctors registered to practise medicine in the UK. We first
examined the issue in October 2010, questioning the General Medical
Council on its response to its consultation Revalidation: the
way ahead which ran from March to June 2010. In our report
on Revalidation of Doctors, published in March 2011, we
indicated that there were a number of aspects of the revalidation
process which required continuing scrutiny as part of the annual
accountability exercise with the GMC, namely:
- What happens in cases where
the performance of an individual doctor gives rise to concern
- The operation of the appraisal system, and its
consistent implementation across the country
- The administrative burden that appraisal and
revalidation place on doctors
- The way in which patients and colleagues are
involved in revalidation
- Where Responsible Officers who are currently
based in PCTs will be sited
- The adequacy of the powers available to the GMC
to ensure that doctors for whom English is a second language are
able to communicate effectively with their patients.
Progress on revalidation
18. The Committee indicated in July 2011 that the
GMC had a considerable amount of work to do before the implementation
of revalidation as proposed in late 2012. In response the GMC
stated that revalidation remained its 'number one priority': "we
are determined and on track to introduce a system by late 2012
(subject to the Secretary of State's approval)".
The Department of Health in England (DH(E)) told us of 'steady
progress towards readiness for implementation [of medical revalidation]
in England', and
the GMC itself stated that it was confident that revalidation
could start in early December 2012, should the Secretary of State
agree to the commencement of the relevant legislation.
Since we held our hearing with the GMC on 4 September the Council
has reported to the Secretary of State that the revalidation system
is ready to be implemented. The Secretary of State announced on
19 October that revalidation would start in December 2012, and
the Privy Council has now enacted the regulations governing the
licensing and revalidation of doctors proposed by the GMC.
19. The GMC told us that following the expected date
of commencement it would inform every doctor on the register of
their expected date of revalidation by the end of 2012. The GMC
expects 20% of licensed doctors to be revalidated between April
2013 and the end of March 2014, with the 'vast majority' undergoing
revalidation by the end of March 2016.
20. We welcome the fact that the system of medical
revalidation is at last ready to be implemented. The purpose of
the system should be to give the public greater assurance that
the medical professionals treating them are being consistently
and regularly appraised for their competence and fitness to practice.
Although commencement of revalidation is a welcome first step
towards providing this assurance, it is essential to recognise
that its benefits will only be realised if the system is effectively
managed and rigorously monitored.
Implementation of revalidation
21. In its 2011 report on revalidation the Committee
identified two principal areas of concern in respect of the organisational
readiness for revalidation:
- the operation of the appraisal
system, and its consistent implementation across the country;
- where Responsible Officers currently based in
primary care trusts will be sited in future.
22. All licensed doctors are to be assigned to a
Responsible Officer (RO), also a registered and licensed medical
practitioner, who is responsible for conducting the revalidation
process. ROs are located in organisations - 'designated bodies'
- such as NHS hospital trusts and (at present) primary care trusts,
medical deaneries and private healthcare providers. The GMC told
us that it had contacted over 600 ROs to date and was assisting
them in scheduling initial revalidation dates and issuing guidance
on helping them to make revalidation recommendations.
23. The GMC further reported that 'the vast majority
of designated bodies are ready or very close to being ready for
revalidation', with over 90% of doctors in England connected to
bodies 'ready or very close to being ready' for revalidation.
'Sufficient numbers' of trained appraisers were either in place
or will be in place to provide the capacity for revalidation in
24. The Department of Health in England (DH(E)) reported
the following from the latest revalidation Organisational Readiness
Self-Assessment (ORSA) exercise for the year to March 2012:
- "Almost 100% of doctors
have a responsible officer, 98% have a trained responsible officer
- 73% of doctors had an annual appraisal that meets
the basic requirements for revalidation
- 85% of doctors are in designated bodies with
a medical appraisal policy
- 86% of doctors are in designated bodies with
sufficient numbers of appraisers
- 92% of doctors are in designated bodies which
monitor the fitness to practise of doctors
- 97% of doctors are in designated bodies which
have a process for investigation of capability, conduct, health
and fitness to practise concerns
- 58% of doctors are in designated bodies with
a policy for reskilling, rehabilitation and remediation."
25. Una Lane, the GMC Director for Continued Practice
and Revalidation, told us that the GMC considered the implementation
of revalidation to be "a shared responsibility between the
GMC and the four health departments and healthcare organisations
across the UK". Ms Lane set out the principles which would
underpin the timetable for revalidation of licensed doctors:
Patient safety is paramount. This is not about delaying
taking action in relation to an individual doctor until such time
as a revalidation recommendation is due, so that is an important
principle. We think that in the first year every single healthcare
organisation must be involved in making recommendations to usnot
only organisations in the NHS but organisations right across the
independent sector and locum organisations across the UK so that
no particular group of doctors is left behind. We have also agreed
with all of the organisations making recommendations to us that
the doctors that are recommended in the first year must be representative
of the population of doctors as a whole in each individual organisation.
With that in mind, each of the four health departments [in the
UK] has put together its implementation plans.
In England, Ms Lane expected that the senior doctors
in the Department of Healththe NHS Medical Director and
the Chief Medical Officerand responsible officers in strategic
health authorities would undergo revalidation first of all, followed
in the first quarter of 2013 by all other responsible officers
26. While the GMC was clear that healthcare organisations
across the public, independent and locum sectors should all be
involved in revalidation in its first year, and that the candidates
for revalidation in each organisation should be representative
of the population of doctors in that organisation, Una Lane also
indicated that revalidation was an activity which should be engaging
all its registrants now, irrespective of when they were likely
to receive their dates for revalidation recommendations:
It has always been important for us to get across
to responsible officers and all organisations that revalidation
is not a point-in-time assessment. The point of revalidation is
that it should be a continuing evaluation of a doctor's practice
close to where the doctor provides care in the workplace, in hospital
or in primary care organisations or in GP practices. All doctors
should now be doing what they need to do in order to be revalidated.
They should be participating in appraisal, linking to an organisation
that will support them with their revalidation, evaluating the
information that is available to them in order to understand where
they are and engaging actively in an appraisal process. Organisations
should also be ensuring that they are identifying poor performance
at an early point in the process and not simply waiting for the
point where a revalidation recommendation is due to the GMC.
She further confirmed that responsible officers who
had identified concerns about a doctor's practice before the date
for revalidation were expected to take action on such concerns
27. We welcome the approach which the GMC is taking
to ensure that all organisations responsible for doctors are engaged
in the revalidation process from the outset, and that the doctors
identified for revalidation are representative of the doctors
across each organisation. We recommend that the practical implementation
of this approach is monitored to ensure that candidates presented
for revalidation are in fact properly representative.
28. Revalidation is a process which is designed
to encourage continuing evaluation of a doctor's practice at the
local level. We support the General Medical Council's message
that all doctors should be considering now the steps which revalidation
will require them to take in relation to their practice, irrespective
of the date on which their revalidation recommendation falls due.
Revalidation and doctors
29. In our 2011 report on revalidation we identified
two principal areas of concern in respect of doctors and revalidation:
- what happens in cases where
the performance of an individual doctor gives rise to concern;
- the administrative burden that appraisal and
revalidation place on doctors.
30. The GMC told us that almost 7,000 doctors had
helped with the revalidation model, through pilots and other means.
Close working with the medical royal colleges and faculties, in
part based on the example set by the Society for Cardiothoracic
Surgery (as this Committee recommended in 2011) had led to the
issue of specialty guidance for doctors providing supporting information
for annual appraisals and eventual revalidation. As a result the
process was said to be 'proportionate, effective and valuable
for doctors'. 73%
of doctors in England had had an annual appraisal in the year
to March 2012.
31. Una Lane indicated that concerns around the performance
of doctors would be addressed initially at the local level, as
at present, and ought to be addressed by the responsible officer.
In addition the GMC had put in place a group of 16 employer liaison
advisers "right across the UK" who could support responsible
officers in dealing with "emerging concerns" about doctors
and providing advice as to when the GMC ought to engage with the
matter and examine a doctor's registration.
32. Although the GMC was keen to stress that the
thresholds for referrals of concern to the GMC should be applied
by responsible officers in the same way as they had hitherto been
applied by medical directors responsible for performance, Niall
Dickson acknowledged that the revalidation process might well
identify concerns about a practice which would not have been picked
up previously: "we believe that we are putting in place something
that really will help to drive up the quality of medical practice
in this country".
33. The introduction of employer liaison advisers
to support responsible officers in assessing concerns around a
doctor's practice is welcome. We expect this initiative to support
earlier and more robust action in identifying such concerns and
ensuring that they are appropriately dealt with.
34. In our 2011 report on revalidation we raised
concerns about how Responsible Officers were expected to deal
with the cases of doctors whose performance gave rise to concern.
35. The purpose of revalidation is stated by DH(E)
to 'provide a positive affirmation that licensed doctors are up
to date and fit to practise'.
Nevertheless the Department acknowledges that the system will
identify 'a small number of doctors who fall short of the high
professional standards expected and whose practice gives cause
for concern". DH(E) convened a remediation steering group
chaired by Professor Hugo Mascie-Taylor which reported in December
2011 on the current processes for remediation of clinical competence.
This report states that:
"The need for a good and consistent approach
to remediation is independent of the new regulatory process of
revalidation that will be introduced by the GMC for all licensed
doctors. However, improved clinical governance and the more robust
annual appraisal processes which will underpin revalidation may
well mean that, at least in the short-term, more doctors are identified
who have a clinical competence and capability issue, and are in
need of remediation."
36. The GMC's role in remediation is concerned with
a doctor's fitness to practise. The Mascie-Taylor report states
that "A doctor may be required by the GMC, through a fitness
to practise process, to undertake a course of remediation as a
condition of remaining on the register. The responsibility to
ensure that the remediation happens rests with the doctor and
they are re-assessed after any remediation as a pre-cursor to
returning to full independent practice."
37. The British Medical Association, while expressing
overall support for the aims and implementation of revalidation,
has raised significant concerns over the potential financial burden
on the colleagues of those doctors required to undertake remediation
procedures resulting from the revalidation process.
It is argued that such colleagues will have to make arrangements
for the work of the doctor under remediation to be covered, which
will incur a financial burden which those doctors should not have
to shoulder. Mascie-Taylor estimated the cost of locum cover for
doctors unable to practise as a result of remediation to be as
much as £200,000 per doctor per year. The BMA has pressed
the Department of Health to develop a 'consistent, fair and equitable
approach' to funding remediation activities.
38. The Royal College of Radiologists, in its evidence
to us, criticised the lack of effective systems for the remediation
or retraining of doctors where appraisal or revalidation has identified
a need for such support.
It considered the conclusions of the Mascie-Taylor report to be
lacking any clear solution, and questioned the apparent failure
of the GMC to actively address the lack of remediation processes.
39. We were concerned to learn from the Department
that only 58% of doctors were affiliated with designated bodies
which had introduced a policy for reskilling, rehabilitation and
remediation, meaning that almost half of the GMC's registrants
are practising in bodies where there is no such explicit policy
40. Professor Sir Peter Rubin, Chair of Council at
the GMC, suggested that the lack of a defined policy in so many
designated bodies was not necessarily a cause for concern for
doctors who took their professional responsibilities seriously:
[ . . . ] as a doctor, I and all doctors have a responsibility
to keep ourselves up to date and fit to practise and not to get
into that position [of requiring remediation of practice] in the
first place. It is very important, as a doctor, that I say that.
Where, for whatever reason, a doctor is found to
need remediation, there have always been, over all my years in
practice in the NHS, ways of achieving that. There is a difference
[ . . . ] between organisations that have a written policy and
those that do not yet have one. But we have no reason to think
that revalidation should be further delayed while waiting for
organisations to have their written policy. We need to get moving
and others can then be encouraged to catch up.
He was not overly concerned that 42% of doctors were
affiliated with designated bodies which had no formal policy for
reskilling, rehabilitation and remediation:
Remediation has been a feature of the NHS for all
the years that I have been in practice. It is not new. What is
new is that one of the successes of revalidation before it even
begins is that it has stimulated organisations that do not have
effective evaluation and appraisal systems to develop them. That
will inevitably start to uncover doctors who are not practising
to the high standards that we would all wish to see. So it is
bringing a sharp focus on remediation, but it would be wrong to
regard remediation or revalidation as inextricably linked because
they are not. Remediation is a long-term issue that has been around
for a long time. You are quite right that not all organisations
have a policy, but I would be astonished if all organisations
had not at some stage had to remediate doctors. It has often been
done in a very ad hoc way in the past. Organisations are playing
catch-up to formalise things that have been done very informally
over the years. Our view is very clear. The public would not understand
it if there were any further delays. We need to start revalidation
and those organisations that do not have a formal policy of remediation
will need to play catch-up quite quickly.
[ . . . ] From all my years of practice I would be
astonished if these organisations did not haveinformal
arrangements for remediation. They might not have a written policy,
but they would have an informal one.
41. Una Lane and Niall Dickson indicated the arrangements
being made to institute formal reskilling, rehabilitation and
remediation policies in all designated organisations:
The revalidation support team [ . . . ] funded by
the Department of Health, is working with those organisations
to make sure that they have action plans to put those policies
in place and to formalise what they may very well currently be
doing informally. The responsible officer regulations now place
clear responsibilities and duties on organisations to have such
policies in place for remediation, rehabilitation and retraining.
All organisations must meet those statutory duties and the revalidation
support team will be working with those organisations to make
sure they put the processes in place very swiftly.
Most of these thingsnot only the responsible
officer regulations which Una has referred to, but the obligation
to give doctors appraisalshave been in their contracts
for many years. It is interesting that revalidation is acting
as a catalyst to put in place basically what we would term clinical
governance arrangements that should have been in place some time
ago. It is very encouraging. In every inquiry where things have
gone wrong you see weaknesses in this kind of clinical governance,
and the fact is that the [revalidation] system is strengthening
42. An important feature of the new system of revalidation
is its focus on establishing and assuring consistency of standards
of practice for all doctors licensed by the GMC. We consider it
vital that this system is properly supported by clear policies
in each designated organisation responsible for doctors which
establish what steps are to be taken if a doctor's practice is
found to be deficient as a result of the revalidation process,
and how the doctor is to be reskilled or remediated if such courses
of action are considered appropriate.
43. We note that a proportion of the designated organisations
which did not have a stated policy for reskilling, rehabilitation
and remediation in place in March 2012 may well have had some
formal or informal procedure for the remediation of practice.
We also accept the argument that the lack of formal procedures
in a number of organisations is no reason to delay the implementation
of revalidation yet further. The GMC must nevertheless realise
the substantial risk to the integrity of the revalidation programme
that a lack of clear and consistent remediation programmes poses.
Although we recognise the danger of focussing on form rather
than substance, we believe that it is an essential element of
good practice for all organisations which employ doctors to have
clear and effective procedures for reskilling, rehabilitation
and remediation of medical staff when that is necessary. We expect
the GMC to ensure that this condition is satisfied as part of
its continuing programme for the development of revalidation and
we shall seek assurances about the progress made in this area
at our accountability session with the GMC next year.
Consistency in revalidation
44. We were concerned to examine the arrangements
for appraisal and revalidation of doctors in 'hard to reach' areas
of practice, such as locum GPs and other doctors working in non-mainstream
45. Una Lane told us that "locum doctors should
be able to revalidate in the same way as every other licensed
doctor [ . . . ] the responsible officer regulations have what
they call designated organisationsa whole range of organisationsand
have given them statutory duties to support doctors. Over 50 locum
agencies in England are designated bodies under the regulations
and must support their doctors with appraisal and revalidation."
She stressed that the information which doctors needed to provide
for their appraisals and revalidation would be consistent and
focused on the GMC's manual Good Medical Practice, whatever
the nature of their own practice: the Department of Health was
undertaking a re-procurement exercise to insert into the contracts
of all locum agencies who are preferred suppliers to the NHS the
requirement that they have systems in place to support revalidation.
The responsible officer regulations that were introduced
at the start of last year absolutely changed the role of locum
agencies. They are no longer simply providing a service to the
NHS in whatever way they see fit. In future, they must correspond
to the statutory duties placed upon them in the same way as every
other organisation and must make sure that they meet the requirements
set out in their contracts.
46. Niall Dickson confirmed to us that it is the
Department of Health, rather than the GMC, which is responsible
for this reprocurement. He regarded this as a means of driving
up the performance and accountability of locum agencies and their
responsibility for the practice of the doctors they employ:
[ . . . ] This is a transformation in what locum
agencies have been to what we want them to be. It is not only
what we want them to be but what the service wants them to be
and what the Government expect them to be, hence the reprocurement
of approved locum agencies that the Department of Health is going
through now. We will have to see how it works in practice.
47. Niall Dickson emphasised that the responsible
officers in locum agencies would all be GMC licensed doctors who
would, as responsible officers, have to base their recommendations
for revalidation of doctors on "proper evidence". Employers
of locum agencies, in the NHS or elsewhere, would also be expected
to provide feedback to agencies on their performance to enable
them to build on their practice, though it is not clear how this
will be achieved. Una Lane told us that "the process should
look the same for all doctors. The kinds of supporting information
that individual doctors might bring [to support their revalidation]
will vary depending on the nature of their practice or the specialty
in which they work."
48. Professor Sir Peter Rubin thought that employers
also had a responsibility to judge on the fitness of a doctor
for the purpose required:
[ . . . ] It is probably appropriate to draw a distinction
between fit to practise and fit for purpose. A doctor may well
be fit to practise, having kept up with their continuing medical
education, etc., but they may not be fit for purpose for a particular
role at a particular time. It may be because they have not had
any sleep for 24 hours or it may be because their experience in
another EU country is not relevant to primary care in this country,
which is a recurring issue. We are the gatekeeper with regard
to being on the register, having a licence and being fit to practise
in a chosen specialty or primary care, but employers have a big
responsibility to say, "Does this individual doctor meet
our purposes for this role at this time?"
49. We suggested, and Niall Dickson confirmed, that
there is an important role for the GMC to monitor and, where appropriate,
raise concerns about the performance of locum agencies in the
discharge of their statutory duties in connection with revalidation.
50. Revalidation must ensure a consistency of approach
to standards of medical practice in all sectors. It is especially
important for public confidence and standards of practice that
all designated organisations apply the same high standards to
the evidence to be presented to the GMC. This is especially necessary
in those sectors particularly at risk from commercial pressures
in the engagement and tasking of doctors, where there have been
recurrent concerns over the competence of doctors recruited for
short-term and peripatetic engagements.
51. It is crucial to the integrity of the system
of revalidation that the responsible officer is in all cases a
doctor registered with and licensed by the GMC. As Sir Peter set
out, with commendable frankness:
The clue is in the name, "responsible".
We want somebody that we can nail, quite frankly. We want somebody
who is going to be on our register that we can hold accountable
for doing it right.
52. Our previous reports have underlined the importance
we attach to the role of the GMC as the "owner" and
"leader" of the revalidation process. As revalidation
is implemented, we look to the GMC to maintain this leadership
role. This will involve actively monitoring and upgrading the
operation of the new system to ensure that it fulfils its objective
of providing greater assurance to patients about the quality and
professionalism of doctors who provide care.
Language competence of licensed
53. In our 2011 report on the GMC, we indicated our
dissatisfaction with the present legislative bar on the routine
testing by the GMC of the language competence of doctors from
the European Economic Area and Switzerland who wish to practise
medicine in the UK. We took the view that the current legal framework
was at odds with good clinical practice, a situation which was
clearly unacceptable. Public confidence in the medical profession
required the issue to be addressed authoritatively.
54. Niall Dickson updated us on progress towards
a language testing regime for EEA and Swiss doctors. This is progressing
in three areas:
a) The Government proposes to bring forward for
enactment by the end of 2013 an order under section 60 of the
Medical Act 1983 which removes the prohibition in UK law on testing
EEA and Swiss doctors for language competence.
b) Even if the Medical Act is amended, the GMC
will still be subject to the requirements of the relevant European
directiveDirective 2005/36/EC on the recognition of professional
qualificationswhich prohibits universal language testing.
The GMC and several of its European counterparts are pressing
for amendments to the directive to give competent authorities
in member States more authority to undertake language testing.
c) Regulations governing the duties of responsible
officers are to be amended to require them to assure themselves
of the language competence of a doctor, by testing if necessary.
These amendments are expected to be made in the course of 2013.
55. In the report of our 2011 hearing with the GMC
we accepted the proposed amendment to the regulations governing
responsible officer duties as a strictly short-term measure pending
amendment of the Directive.
We were disappointed to learn from Niall Dickson that the GMC
aspires only to have the relevant changes to domestic legislationthe
Medical Act 1983 and the Medical Profession (Responsible Officers)
Regulations 2010in force by the end of 2013.
We consider that the proposed legislative changes to require
responsible officers to assure themselves of the language competence
of the doctors for whom they are responsible should be made as
soon as possible, pending satisfactory amendment of the European
Professional Qualifications Directive. In any event, we expect
that should any issue about a doctor's language skills be identified,
the responsible officer should be alerted immediately and should
take appropriate action at once. The GMC and the Government should
both confirm that this is their intention.
56. It is welcome that the GMC and the Government
propose to amend existing legislation in order to require responsible
officers to assure themselves of the language competence of any
doctor licensed to practise in the UK. Nevertheless, the European
directive which has the effect of prohibiting universal language
testing by the GMC remains in effect. Although the European Commission
adopted a proposal for amendment of the Professional Qualifications
Directive in December 2011,
we see no clear timetable for the effective revision of this legislation,
and while the Department has told us that its officials are working
closely with the department for Business, Innovation and Skills
(the lead Department), the GMC and UK negotiators with the EU,
we have seen no clear statement of the Government's negotiating
57. In our 2011 report we accepted the de facto work-around
of local testing of language competence by responsible officers
as a strictly interim measure. We are disappointed that no
substantive progress seems to have been made at European level
in addressing the underlying issue of language testing of doctors
with primary qualifications from elsewhere in the EEA and in Switzerland.
We continue to look to the Government, the GMC and the relevant
EU institutions to produce a long-term solution to this problem
within a timescale which reflects the potential risks to patients
across Europe which are inherent in the present unsatisfactory
situation. We ask the Government to set out in its response to
this report the steps it is taking to seek amendment of the relevant
Directive and the expected timetable.
Revalidation and patients
58. In our 2011 report on revalidation we found it
unsatisfactory that little attention had been given to the issue
of how to deal in the revalidation process with doctors whose
practice gives cause for concern, particularly since it appeared
that remediation of practice was the instinctive response to any
indication of inadequacy. We concluded then that "while it
is important to ensure that the rights and legitimate interests
of individual doctors are safeguarded, the primary purpose of
revalidation is to protect the interests of patients".
In its response to that report, the GMC indicated that should
any deficiencies be identified in the revalidation process which
gave rise to concerns about a doctor's fitness to practise, they
should be raised with the GMC immediately through its existing
59. We asked what rights patients had to be informed
about the outcome of appraisal processes and revalidation processes.
Una Lane told us that all the information held by the GMC on doctors'
revalidation was "open and transparent":
Where we take action in relation to a doctor's registration
through our fitness-to-practise procedure, all those decisions
are published on our website and linked to the individual doctor's
entry on our register online. Similarly, where we withdraw the
doctor's licence through the revalidation process, that information
will be publicly available. Where doctors decide to relinquish
their licence, again that information is publicly available online
via our website. As far as appraisal is concerned, local healthcare
organisations run an appraisal process. For most of us who have
an appraisal, the output looks like a professional development
plan for the following 12 months.
Professor Sir Peter Rubin added that
[ . . . ] the GMC is the most transparent medical
regulator in the world. Where we find a doctor's practice is impaired,
that information and the reasons why we came to that conclusion
are in the public domain. You can go on to our website and see
this information. [ . . . ] The information is there and is well
known to be there.
60. Revalidation will introduce a more comprehensive
framework for doctor appraisal and assessment, and public knowledge
and understanding of the process and the degree of assurance which
revalidation is intended to give will doubtless increase as more
systematic appraisals take place and responsible officers make
their submissions to the GMC as to whether practitioners are fit
to practice. The information provided to the public on the GMC
Most doctors already have a regular appraisal, but
the focus and content can vary from one place to the next. The
introduction of revalidation will mean that every licensed doctor
will have their practice regularly evaluated against the standards
that we set them as their regulator. We believe this will give
you greater confidence in the doctors who treat you.
As part of their regular appraisal, doctors will
be expected to think about their practice and consider the areas
in which they could improve their practice in the future. Over
time we believe this focus on doctors' development will help to
improve both the care that patients receive and the safety of
We'll revalidate a doctor based on a recommendation
that we receive from their 'responsible officer'. This person
will usually be the doctor's medical director. They will make
their recommendation based on a doctor's appraisals over a five
year period. They will only make such a recommendation if there
are no outstanding concerns about that doctor's practice.
61. The GMC is clear on its policy on publishing
information about cases under its fitness to practice procedure
where the practice of doctors has been found to be impaired. Information
to the public about the revalidation process is also important
in demonstrating how the system is functioning and helping to
sustain confidence in the medical profession: but national policy
on publishing information for patients and the public about the
revalidation process is less than clear.
62. Una Lane suggested that the outcome of an annual
appraisal undertaken at local level would normally resemble a
'personal development plan'. It seems to us unlikely that such
a plan would be published as a matter of routine, especially where
it might be interpreted to give rise to concerns about a doctor's
practice, and we do not advocate routine publication of such appraisals.
63. Nevertheless, circumstances are bound to arise
where appraisals identify the need for improvement in a doctor's
practice in order to meet the standard required for a positive
revalidation recommendation. If a doctor is under an obligation
from a responsible officer to take steps to improve standards
of practice, the rights of that doctor's patients to be informed
of the obligation must be considered in proportion to the potential
risk. We continue to believe that the arrangements for informing
patients of circumstances where a doctor has been required to
undertake remediation measures are not sufficiently clear. In
view of the imminent implementation of the revalidation process
we recommend that the GMC take steps to clarify these procedures
as a matter of urgency, and certainly before our accountability
session next year.
64. We raised with the GMC the adequacy of the requirement
under revalidation for doctors to gather formal patient feedback
once every five years. Una Lane saw this requirement as part of
a process to ensure that all doctors sought patient feedback on
their practice as a matter of course: "we know that it does
happen in many GP practices currently, and in fact in many good
hospitals, but it absolutely does not happen universally and it
is not something that every licensed doctor is currently engaged
in. We think it is [ . . . ] a big step forward and that revalidation
will drive doctors to ensure that they seek such feedback from
nevertheless did not want to introduce a system that was overly
65. The GMC says that patients will play 'an important
role' in revalidation, and that each doctor will have been expected
to have collected 'formal patient feedback' at least once in every
five-year revalidation cycle.
Patient and colleague feedback questionnaires have been prepared
by the GMC for employers and doctors to use: the GMC says they
have been subject to in-depth research and testing with numerous
doctors, patients and medical colleagues.
66. The GMC reports strong support from patient groups
for revalidation, and cites a 'patient Statement of Support' for
revalidation which states that "patients and the public need
to be sure that the doctor they consult or the doctor who is treating
them is up to date and fit to practise". The King's Fund,
reporting to us the findings of a study of public opinion on attitudes
to revalidation which it had undertaken with MORI, indicated that
the proposed inclusion of patient feedback within revalidation
had met with "particular approval".
67. There is clearly a balance to be struck in ensuring
that doctors seek patient feedback on their practice at regular
intervals: the feedback must be sought regularly enough to be
worthwhile and to ensure that patients have a genuine opportunity
to give their views, but the procedure should not be burdensome.
We consider that the minimum frequency of feedback stipulated
by revalidation once only in the five-year revalidation
cycle risks sending the wrong message to patients about
the importance of their feedback to the process. We
consider that the requirement to seek feedback from patients at
least once every five years does not sufficiently reflect the
aspiration of the GMC, which we share, to ensure that every doctor
seeks periodic feedback from patients. The GMC should consider
setting a more challenging target which will provide greater assurance
to patients that their views are regularly sought and reflected
upon by their doctors.
14 Under the General Medical Council (Licence to Practise
and Revalidation) Regulations Order of Council 2012 (SI 2012/2685) Back
The state of medical education and practice in the UK 2011,
General Medical Council 2012, p. 16 Back
HC (2010-12) 1699, para 4 Back
Ev 21, para 2 Back
Ev 33, para 8 Back
Ev 33, para 12 Back
Ev 34, para 15 Back
Ev 34, para 14 Back
Ev 21, para 9 Back
Ev 33, paras 9-10 Back
Health Committee, Fourth Report of Session 2010-11, Revalidation
of Doctors, HC 557, para 32. Back
Ev 21, para 5 Back
Report of the Steering Group on Remediation, Department
of Health, December 2011, p 9 Back
Ev 38 Back
Ev 30-31 Back
Q22 (Una Lane) Back
Ibid. (Niall Dickson) Back
Health Committee, Annual accountability hearing with the General
Medical Council, Eighth Report of Session 2010-12, paras 19-23 Back
COM(2011) 883 final, Proposal for a Directive of the European
Parliament and of the Council amending Directive 2005/36/EC on
the recognition of professional qualifications and Regulation
on administrative cooperation through the Internal Market Information
Ev 22 Back
Fourth Report of the Health Committee, Session 2010-11, Revalidation
of Doctors, HC 557, para 31 Back
http://www.gmc-uk.org/doctors/revalidation/12398.asp , last accessed
on 28 November 2012 Back
Ev 34, para 18 Back
Ev 34, para 19 Back
Ev 24 Back