The GMC has committed to increasing awareness of bias and improving equality, diversity, and inclusion (ED&I) training as part of an internal review of its decision-making processes.
The recommendations cover five main areas, including:
- The GMC’s approach to auditing the fairness of its work, which will be more consistent and
will involve seeking more external feedback.
- Introducing a single set of decision-making principles to increase consistency across the
- Tailoring equality, diversity and inclusion (ED&I) training for GMC staff across different roles.
Publishing more detailed data about GMC fitness-to-practise processes.
- Making sure fairness and ED&I are embedded into the way the GMC operates in future,
when the Department of Health and Social Care introduces a new regulatory framework for
The recommendations are based on the direct participation of 40 members of staff, with 900 more members forming the evidence base, and include increasing transparency, particularly on fitness-to-practise (FtP) data, and seeking external feedback in its audit processes.
Part of the work of the regulatory fairness review centred on having open conversations about bias since it was clear that staff ‘felt uncomfortable discussing how bias might impact their work’.
An external review published in October 2022, carried out by consultancy firm Howlett Brown, recommended the GMC seek more external audits of its decision-making processes.
These recommendations were incorporated into the internal review, which stated an aim to ‘develop a more structured and transparent approach to commissioning external audits’.
The review also identified 220 members of staff who last completed ED&I training before the Equality Act 2010, and addressing this training gap was flagged as ‘an immediate priority’.
While the review was organisation-wide, implementation of the recommendations focus on high-stakes decisions as they are more likely to directly impact on registrants, patients and the public.
Laura Harding, the report’s author, said: ‘All of us in an organisation such as the GMC make decisions, and no matter how big or small they are they each have an impact. Managing the risk of bias in those decisions is vital, and will result in fairer decisions for everyone who interacts with the GMC.’
In November 2022, a separate independent review found that the accusations against Dr Manjula Arora around the ‘promise’ of a laptop should never have reached the GMC.
Ms Harding’s internal review report acknowledged the importance of this case as it raised ‘the profile internally of the nuances of bias and how it impacts decision making’.
Some of the 23 recommendations are already being implemented and many have deadlines for completion this year.
GMC chief executive Charlie Massey said: ‘A degree of bias is inherent in human nature, and so a fundamental principle of our approach is to look for the risk of bias and to assess the controls we have in place to manage it. The recommendations in this report are key to that.’