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The General Medical Council (GMC) introduced revalidation for doctors in December 2012, after many years of discussion and debate about how it was to be delivered. This was at least in part triggered by the conviction of Dr Harold Shipman and the subsequent inquiry. Recommendations sparked major concerns about patient safety, the regulation of doctors, and public confidence in the regulatory processes. The aim was to revalidate the majority of licensed doctors for the first time by March 2016 and all doctors by 2018. 80% of eligible doctors had been through the revalidation decision process and 81% of those doctors had been revalidated for the first time by the GMC report of June 2016.
Terminology: registration, licensing and revalidation
Traditionally, doctors have been registered with the GMC from qualification. The GP Register was introduced by the GMC in 2006. Since 1st April 2006 all doctors working in general practice in the NHS, including locums but excluding GP registrars, have to be on the GP Register. There is an equivalent Specialist Register, introduced in 1997, for consultants.
Licence to practise
All doctors practising medicine in the UK are now required by law to have a licence to practise and to be registered with the GMC. This requirement applies whether the doctor works full-time, part-time, as a locum, privately or in the NHS, or whether they are employed or self-employed. At the start of the revalidation process all doctors who were entitled to hold a licence were contacted by the GMC. Subsequently, doctors have been licensed at qualification. The licence is generic and does not apply to any particular specialty.
Doctors no longer in clinical practice do not need a licence but may choose to remain registered with the GMC. Such registration allows them to sign passports and retain the title of doctor but they cannot sign prescriptions or official documents. It may benefit Individuals applying for non-clinical posts to confirm that they are "in good standing with the GMC".
Successful revalidation then allows a doctor with a licence to continue to practise. Doctors with a licence to practise are legally obliged to revalidate every five years.
Revalidation is a process by which licensed doctors have to demonstrate that they are up to date and fit to practise. Its purpose is to reassure patients that doctors are regularly checked by their employer/contracted authority and the GMC.
A doctor is recommended for revalidation by their Responsible Officer (RO) if they have engaged with the appraisal process, demonstrating they are up to date and fit to practise, and if there are no outstanding investigations into their performance. Appraisals are intended to be a formative, supportive process in which the doctor reviews his/her overall work content with the appraiser. The outcome is the construction of a Personal Development Plan (PDP). Since the start of revalidation, appraisals are also an evidence-gathering process with the aim of a consequent positive recommendation from the RO. Appraisers help and advise doctors with regard to the construction of their portfolio of evidence via the annual appraisal meeting. See separate GP Appraisals article.
Whilst there are variations in implementation of the appraisal process, all the UK countries have signed up to the same revalidation principles.
The Medical Profession (Responsible Officers) Regulations 2010 required all NHS organisations ("designated bodies") to appoint ROs by 1st January 2011. Among other obligations, they are responsible for local revalidation arrangements and inform the GMC whether or not they can recommend each doctor for revalidation. The GMC has set out guidance for ROs.
Prior to each doctor's revalidation date, the RO can make one of the following recommendations:
- Recommend the doctor for revalidation unless:
- The doctor has not provided the evidence required by the GMC.
- There is an ongoing local investigation/performance issues
- There are unaddressed concerns.
- The doctor is the subject of a GMC investigation (in which case the GMC would postpone revalidation until this reaches a conclusion).
- The doctor has not engaged with the appraisal process.
- Recommend the revalidation be deferred. This may be for up to a year, if:
- Supporting information is incomplete.
- There is an ongoing local investigation or disciplinary process outstanding.
- Make a recommendation of non-engagement. In this case if all possible processes have been pursued, the GMC may withdraw the doctor's licence to practise.
Most doctors have a connection with a designated body, For doctors who do not, the GMC states that a "suitable person" (SP) can make the revalidation recommendation. Any individual wishing to make a recommendation for revalidation must apply to the GMC for approval to act as an SP. As of 31 March 2016:
- The GMC has approved 23 SPs to make recommendations for a number of different cohorts of doctors.
- 995 doctors have an approved SP.
- There were 9,691 doctors on GMC records without a prescribed connection to a designated body or a GMC-approved SP.
The revalidation process
In order to be revalidated, each doctor must engage in an annual appraisal. The appraisal is based on GMC core guidance "Good Medical Practice" (GMP). This is organised into four domains which demonstrate essential professional values:
- Knowledge, skills and performance.
- Safety and quality.
- Communication, partnership and teamwork.
- Maintaining trust.
In order to demonstrate they are complying with this guidance, each doctor must build a portfolio of evidence to show they are meeting the requirements. There are six types of information each doctor must collect:
- Continuing professional development (CPD). The GMC does not specify any particular number of hours or credits required, or the way in which a doctor should keep up to date. Courses, meetings, journals, web-based learning and the Patient's Unmet Needs (PUNs)/Doctor's Educational Needs (DENs) system are all possible methods. Evidence should be presented in a way which can be related to the domains of GMP. It is expected there will be a variety of learning methods demonstrated.
- Quality improvement activity. This includes activities such as audit, case reviews, evaluation of policies or review of clinical outcomes.
- Significant events. These are reviews of unintended or unexpected events, which could or did lead to harm of one or more patients.
- Feedback from colleagues. (This must be by the use of a standard GMC-approved questionnaire.)
- Feedback from patients. (As for colleague feedback.)
- Review of complaints and compliments.
Each type of speciality or role receives further guidance on the type of supporting information they must collect from their specialist organisation, such as the medical Royal colleges. For GPs, this is laid out in the Royal College of General Practitioners (RCGP) guide to supporting information for appraisal and revalidation. This is an evolving guide, most recently updated in March 2016. See separate GP Appraisals article for more information. There is also separate guidance for foundation and specialty doctors in training. Doctors of all specialities must show evidence that they reflect on their learning and the impact of their learning on their practice, rather than purely collecting evidence of attending courses, etc.
In addition to this, each doctor must describe the scope of his/her roles and practice and must complete declarations with regard to probity and health. There must also be an annual PDP produced during each appraisal, and the last PDP must be reviewed. After each annual appraisal, the appraiser signs a number of statements which indicate whether satisfactory appraisal has taken place, demonstrating the doctor is keeping up to date, engaging with the process and providing evidence of reflective practice and that there have been no concerns elicited regarding fitness to practise.
Doctors are not in attendance when they revalidate. Providing all the appraisal statements have been agreed and there are no other outstanding performance issues, the RO will simply recommend revalidation. The doctor then receives notification of revalidation from the GMC. Appraisals are annual and revalidation occurs every five years, based on the previous five years of appraisal documentation.
Further reading and references
Revalidation; BMA, 2013
Shaping the future of medical revalidation – interim report (January 2016); UMbRELLA (UK Medical Revalidation Evaluation coLLAboration) appointed by the GMC
Effective governance to support medical revalidation; General Medical Council, 2013
NHS medical revalidation; NHS England
Medical Revalidation; The Scottish Government
Appraisal and Revalidation; Public Health Wales
Revalidation; HSC Public Health Agency
Fifth Report; The Shipman Inquiry
GMC Progress Report; Revalidation Advisory Board meeting, 9 June 2016
Revalidation; The General Medical Council (GMC)
Information on the General Practitioner (GP) Register; General Medical Council (GMC)
Information on the specialist register; General Medical Council (GMC)
Implementation principles; General Medical Council (GMC)
Suitable Persons; General Medical Council (GMC)
The Good medical practice framework for appraisal and revalidation; General Medical Council (GMC), 2013
Supporting information for appraisal and revalidation; General Medical Council (GMC), March 2012
RCGP guide to supporting information for appraisal and revalidation (2016); Royal College of General Practitioners, March 2016
Information for doctors in training; General Medical Council (GMC)