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GMC to advise doctors to leave ‘factual details’ out of appraisal reflections

The GMC is set to advise doctors not to include any factual details in their reflections submitted as part of the revalidation process.

The GMC has said new guidance for doctors on submitting reflections will be released this week but listed ‘key messages’ from the guidance in its response to the Hamilton review of gross negligence manslaughter charges, which was published last week. 

Key messages in the guidance include avoiding the use of factual details about their experiences - both positive and negative - in their appraisal and learning portfolios.

This comes after it was made clear that doctors’ e-portfolios are not subject to legal privilege under UK criminal law and as a result could be requested by a court if considered relevant.

The GMC had previously recommended to the Government’s 'rapid review' of gross negligence manslaughter charges in medicine that legal protection be granted to cover doctors' reflections

However, when the review reported in Juneit said: ‘This was not considered workable or appropriate. Where any evidence is material to a case, it is right that it should be considered.’ 

The GMC will therefore advise doctors in upcoming guidance that they should discuss positive and negative experiences with their appraisers, ‘and maintain a note of these discussions’.

However, it said: ‘No factual details should be recorded in the appraisal portfolio.’

It added: ‘They [doctors] should share original, non-anonymised information with supervisors but should not record factual details in the learning portfolio.’ 

The GMC’s submission to the Hamilton review said that although reflective notes can currently be required by a court, if doctors have anonymised their reflective practice notes, ‘this should not be a cause for concern’. 

The document said: ‘It’s important to note that as reflective notes are not contemporaneous records of an incident, they are less likely to be of interest to the courts.’

Dr Chandra Kanneganti, a GP appraiser and member of the BMA's GP committee, said the guidance is a step in a 'positive direction'.

He said GPs 'used to write down everything about the complaint... putting all the factual information about [the case], a copy of the complaint letter, striking out the name of the complainant'.

Dr Kanneganti added that he was 'surprised' by the new guidance as 'the GMC are on the back foot after what happened in the [Dr Bawa-Garba] appeal court decision'.

He said: 'With this guidance at least we can have a discussion about what [incidents] have happened... I'm glad the GMC has taken the right decision to do that.'

This comes after Pulse revealed that elements of Dr Hadiza Bawa-Garba’s e-portfolio were included in materials seen by expert witnesses ahead of her criminal case.

In July an appeal court overturned a GMC-led High Court decision to strike her off the medical register following the criminal conviction.

A BMA spokesperson said: 'The focus of doctors’ reflections should be on learning, rather than blame, which is why we have consistently called for those made in education and training documents to be given legal protection…

'However, if providing written reflections, doctors should include only brief descriptions of the circumstances on which they are reflecting, and ensure full anonymity.

'Patient identifiable information and specific factual details are not needed for doctors to develop learning and improve care in the future.'

The Hamilton review, which launched in February 2018 with Dame Clare Marx at the helm, is investigating why there are fewer GNM cases involving healthcare organisations compared with individuals.

Readers' comments (27)

  • This will only make the appraisal an even more tick box exercise.. at least when I was doing personal reflection I was gaining something ....
    Well, we need to carry on working...

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  • WHEN THINGS GO WRONG YOU CAN RELECT IT TO YOURSELF AND LEARN. NO NEED TO TELL WORLD. WHAT BENEFIT DOES IT BRING BY TELLING OTHERS? BE OPEN AND HONEST TO YOURSELF AND PATIENTS. NO NEED TO INVOLVE THIRD PARTY.TRUST PATIENTS , THEY WILL FORGIVE YOU FOR GENUNINE MISTAKE BUT NOT REST OF THE WORLD . THEIR JOBS DEPEND ON TAKING ACTION.

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  • The GMC has over-stepped the reason it is there to regulate doctors and keep up Professional standards. Now it is empire building intruding into personal lives and colluding to a failed NHS by scapegoating us. The doctors have lost faith in the GMC which has lost the plot and it's sense of direction in doing too much and over regulating. We need the BMA to start a new organisation. One that we can trust and does not empire build charging exorbitant fees and over paying it's CEOs.

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  • You really couldn't make this up.
    Until there is legal privilege then SEAs and complaint discussions should be binned altogether.
    Legal privilege is not impossible and is down to our politicians to sort out. Unfortunately 100% of our politicians would appear to be not fit to practice.
    Maybe it is impossible.

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  • I bided my time, and I won out. The GMC is hoist by its own petard. The legal position on appraisal documentation was obvious.
    Perhaps I can do another appraisal, now that they are meaningless. GMC has shown its not fit for purpose, I may need to change my moniker to GoneiftheGMCisnotreconfigured.

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  • This only reinforces the well known fact that appraisal is a pointless exercise. The GMC has gone all Donald Trump on us by telling us to present “alternative” facts. Not exactly professional of them or us if we follow that advice. I think my reflections in my SOAR online template should just say, “I have reflected, therefore I am”.

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  • -'Demonstrable insight' is required to show fitness to practice.
    - Reflection is needed to demonstrate insight.
    - GMC's RO/ Appraisors need to see adequate reflection.
    - There is no impediment to use of appraisal for a wide range of purposes. Or of calling on those who see, use and contribute to your appraisal.
    - GMC speaks with forked tongue. We are used to that with Charlie at the helm of GMC

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