Health Alert: GMC Consultation "Revalidation: the way ahead"

The GMC has issued a consultation on its proposals for the new process of medical regulation; revalidation. This process will require all licensed doctors to revalidate, thereby demonstrating that they are up to date and fit to practise, on a regular basis to keep their full licence to practise. The consultation relates to the GMC's proposals on how revalidation will work in practice and closes on 4 June 2010.

Background

The GMC has been developing the revalidation process since 1998. Following support in a governmental White Paper in 2005 (Trust, Assurance and Safety – The Regulation of Health Professionals in the 21st Century), legislation has been passed to ensure that revalidation will be introduced for all doctors in the UK (Health and Social Care Act 2008).

Regulator

The UK Revalidation Programme Board (the "Board") has been established to oversee the practical delivery of revalidation across the UK. It has 16 members, meets approximately once every two months and is accountable to the GMC Council. One of the terms of reference of the Board is to provide an ongoing assessment of when local organisations will be ready to support the introduction of revalidation.

Register of Medical Practitioners and Licensing

The register of medical practitioners (the "Register") maintained by the GMC, demonstrates that a practitioner has passed certain examinations and earned the qualifications necessary to practise medicine in the UK. In addition to being on the Register, practitioners must maintain a licence to practise (the "Licence"), which again is issued by the GMC.

Many licensed doctors are also on specialist registers or the general practitioner register. These registers show the specialty in which the doctor has completed specific additional training. Going forwards, these registers will still show a historical record of the doctor's achievement, but will also show the field in which the doctor most recently demonstrated a fitness to practise through revalidation.

Overview of Revalidation

In the future, in addition to being registered and licensed with the GMC, practitioners will need to periodically (normally every 5 years) demonstrate to the GMC that they are up to date and fit to practise. Currently doctors are already under a professional duty to keep up to date, and therefore revalidation should not require "new" activities on the part of practitioners, but rather a record of such activities.

This will not involve a "point-in-time" assessment, as it is felt this will be too cumbersome and burdensome to the practitioner, but rather a continuing evaluation of a doctor's practice in the place he or she works.

It will be based upon local systems of appraisal and clinical governance, and will need to include an annual evaluation of the doctor's performance against the generic and specialty standards approved by the GMC. The generic standards will be based upon 12 attributes, drawn from the GMC guidance on Good Medical Practice, for which it is possible and reasonably practicable to produce evidence of compliance with. It is not expected that a doctor will be able to provide evidence of compliance with every generic standard as some standards are only applicable to certain groups of doctors, e.g. those working with patients or those undertaking research.

The specialty standards have been drawn together by each of the Colleges and Faculties and have been evaluated by the GMC. It is expected that all doctors will meet all of the standards for their specialty.

The annual appraisal will be undertaken by an appraiser who will usually be from the doctor's own specialty. Doctors will be required to provide a portfolio of supporting documentation to be reviewed by their appraiser. Doctors practising in both the NHS and independent sectors should collect supporting information for work in both sectors. This supporting documentation will demonstrate that the doctor meets the standards that are relevant to his or her day to day practice; examples include audit data, outcome data, evidence of participation in Continuing Professional Development and feedback from colleagues and patients through questionnaires.

Responsible Officer

The ("Responsible Officer") is a new statutory role established under the Health and Social Care Act 2008, and will usually be filled by a senior licensed practitioner in the organisation in which a practitioner works. In a healthcare organisation this is likely to be the Medical Director, and for GPs it will be the Medical Director from the PCT on whose Performer's List they are included. For doctors who are wholly independent from organisations with an appraisal system and a Responsible Officer, a number of independent organisations such as the Independent Doctors Federation, are considering providing appraisal and Responsible Officer facilities for their members.

This role was consulted upon by the Department of Health in 2008 and secondary legislation and guidance outlining the detailed role will be laid before Parliament later this year. The response to the consultation can be found at the Department of Health's website

It is the Responsible Officer who will report to the GMC once every 5 years that a doctor is up to date, fit to practise and that there are no known concerns about the doctor's practice. He or she will base this recommendation upon the outcome of the doctor's annual appraisals over the course of 5 years and the information drawn from the clinical governance systems of the organisation/s in which the doctor has worked.

In addition, the Responsible Officer will be responsible for ensuring that the system of clinical governance in place is capable of supporting the doctor in meeting the requirements of revalidation.

Role of the Colleges and Faculties

There are two potential roles for the specialist Colleges and Faculties. One is focused on quality assurance, whereby they set the specialty standards, agree the relevant supporting information for doctors in their specialty and provide advice and guidance on implementing these. The alternative is for them to have direct input into the recommendations by the Responsible Officer. The GMC prefers the quality assurance and advisory role to the direct input role.

The revalidation decision

Although based upon the recommendation from the Responsible Officer, the revalidation decision will be for the GMC. As such, the appraisal and clinical governance systems, along with the recommendations from the Responsible Officer will be subject to quality assurance.

Doctors in non-standard or training roles

The consultation envisages slightly different procedures for doctors in training, those without medical practice of any kind, those working in non-clinical practice and those working outside their registered specialty. The processes for these categories of doctors are tailored specifically to the type of evidence their practise will allow them to provide without creating additional burdens.

How revalidation will be rolled out

To enable doctors to gather the information they will need for revalidation, the systems of clinical governance and appraisals will need to be sufficiently mature. Therefore, it is intended that revalidation be rolled out on an incremental basis. Currently, revalidation is being tested in a number of pilot projects across the UK and lessons learnt from these schemes will inform the implementation process. Organisations will need to ensure that the systems necessary to support revalidation are fit for purpose.

Consultation questions

There are 20 consultation questions in total, covering the following topics:

• The process of revalidation;
• The standards against which revalidation will be regulated;
• The Responsible Officer;
• The role of Colleges, Faculties and the GMC;
• Patient and public involvement in the process;
• The mechanism for rolling out the process.

What does the consultation mean for healthcare organisations?

Revalidation is going to be the new process for medical regulation. The consultation is simply on the process by which it is going to work in practice. Healthcare organisations are going to have a pivotal role in the new revalidation process, and as such, should review the proposed process carefully and consider whether they agree with the methodology put forward by the GMC. Organisations need to be confident that the standards and information required for revalidation are realistic and achievable.

As the revalidation scheme is going to be introduced incrementally, healthcare organisations need to start taking steps to ensure that they meet the basic criteria for the Board to determine that they are ready to support the introduction of revalidation. These steps include appointing a Responsible Officer, and where appropriate a team to support that role, establishing an effective system of clinical governance, establishing a strengthened system of appraisal and reliable mechanisms to obtain feedback from patients and colleagues. To this end, the GMC has developed detailed criteria for the questionnaires which can be found in Annex 3 of the consultation. In addition, there will need to be arrangements in place to enable doctors' Continuing Professional Development.

The Department of Health is leading healthcare organisations, aiming to achieve a state of readiness within the next 12-18 months. The GMC is expecting revalidation to be extended to all doctors holding a licence to practice within 5 years of revalidation going live.

The consultation is available through the GMC website.