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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.