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Q&A: Non-engagement with revalidation

At this stage, we are all familiar with revalidation – the process by which doctors in the UK are obliged to demonstrate to the General Medical Council (GMC) that they remain up-to-date and fit to practise.

There are only three recommendations that a doctor’s Responsible Officer (or Suitable Person) can make to the GMC about them in relation to revalidation:  

  • a positive recommendation that the doctor is up-to-date and fit to practise,
  • a request to defer the date of making a recommendation about the doctor,
  • a notification of the doctor’s non-engagement with revalidation.

It’s important to bear in mind that, since revalidation was introduced in December 2012, more than 16,500 doctors have been successfully revalidated and just five have received non-engagement recommendations from their Responsible Officers.  

The purpose of this piece is to look more closely at the concept of non-engagement with revalidation.  

What is non-engagement?

A doctor is deemed to not be engaging in revalidation where, in the absence of reasonable circumstances to justify it, they:

  • do not participate in the local processes and systems that support revalidation
  • do not participate in the formal revalidation process.

In practice non-engagement is likely to mean that a doctor has failed to complete annual appraisals, has not responded to communications from their Responsible Officer, and that this has remained the case despite being given sufficient opportunity and support to engage.  

What is the consequence of non-engagement?

The GMC can administratively remove a doctor’s licence to practise if they fail to participate in revalidation. Only those doctors holding a licence to practise may undertake clinical practise in the UK, so non-engagement is potentially career ending.  

Does a doctor immediately lose their licence to practise if they don’t engage?

No. There are several steps in the process.

Firstly, the Responsible Officer submits notification of non-engagement as their revalidation recommendation about the doctor. The GMC then begins the process of administratively removing the doctor’s licence to practise. The doctor is informed that the GMC is minded to withdraw their licence to practise and has 28 days in which to make representations to the GMC. Even at this stage, it is not too late to begin to engage with revalidation.

Ultimately, if a doctor continues to not engage, the GMC will remove their licence to practise. The doctor can then pursue a legal appeal of this decision, but there is a strict time limit of 28 days from the date of the GMC’s decision letter in which to do so.  

I am a GP partner. What should I do if I become aware that someone in my practice is not engaging?

Support and encourage them - collating all the evidence required for appraisal and revalidation can be daunting. At the same time, make sure they understand the serious consequences of non-engagement, and that doing nothing is not an option.

From the perspective of protecting your own position, you cannot employ a GP who does not have a licence to practise.

There are helpful resources for partners in this position available from the Faculty of Medical Leadership & Management and Fair Route to Revalidation websites.  

Andrea James is head of professional discipline and healthcare regulatory sectors at Shoosmiths Solicitors, was formerly an in-house solicitor to the General Medical Council and specialises in advising doctors.