When will my revalidation take place?
The GMC will start writing to all doctors from 3 December to give them their revalidation date, and by March 2013 all doctors will have received their date. The GMC has worked with responsible officers to agree these dates, which are based on when responsible officers anticipate the doctors they oversee will be ready.
The three minimum requirements the GMC has set for a GP to be ‘ready’ are:
• participation in an annual appraisal process that covers all of the doctor’s medical practice and has Good Medical Practice as its focus.
• completion of at least one appraisal, as above, which has been signed off by the doctor and their appraiser.
• demonstration through appraisal that the GP has collected and reflected on the six key pieces of evidence stipulated by the GMC.
Any doctor who becomes fully registered with a licence to practise after 3 December will be given their revalidation date at the point of registration. Their revalidation date will almost always be set five years from the point when they became fully registered with the GMC.
How much formal notice will I get?
All doctors will be given formal notice of their revalidation date at least three months before the GMC expects to receive a recommendation from their responsible officer. Doctors will also be able to check their revalidation date via ‘GMC Online’, part of the GMC website.
Is there any flexibility to reschedule the date of my revalidation if I am on a career break, such as maternity leave or a sabbatical?
Yes. A doctor’s revalidation date can be deferred if they are on sabbatical, maternity leave or otherwise on a career break. Doctors should discuss the possibility of deferral with their responsible officer in the first instance, who can defer revalidation by up to 12 months. Primary care organisations should not expect GPs to collect supporting information and participate in an appraisal when they are on a career break. A GP can be out of practice for up to two years and continue with the normal revalidation cycle – longer than that and they will be required to take part in a return-to-practice programme.
The RCGP recommends that GPs taking a break from practice contact the organisation through which they receive their appraisal. Maternity leave should be recorded as an ‘exceptional circumstance’ on a doctor’s portfolio so that her responsible officer can take this into account when making their recommendation.
I haven’t been told who my responsible officer or my designated body are. How do I find out?
For GPs on a performers list, the designated body is the primary care organisation that manages that list. You will have one named responsible officer from that organisation. The GMC has a tool to help find your designated body on its website, which you can access via tinyurl.com/DesignatedBody.
What information will I have to supply during my next appraisal?
Annual appraisals organised by your designated body will play a crucial role in revalidation. GPs will be expected to prepare a portfolio of supporting information from every area of their practice, including any work they do for organisations other than their designated body. The GMC has stipulated six types of supporting evidence that doctors will be expected to provide at least once in each five-year revalidation cycle:
• quality improvement activity (such as clinical audits)
• feedback from patients (at least 34, if using the GMC questionnaire, once every five years)
• feedback from colleagues (at least 15, if using the GMC questionnaire, once every five years)
• continuing professional development (CPD)
• significant event audits
• a review of complaints and compliments.
Dr Caroline Fryar, medico-legal adviser at the Medical Defence Uniont (MDU), says: ‘Your ability to revalidate largely depends on the success of the yearly appraisals. Failure to engage with the process could mean your responsible officer notifies the GMC and you will not be able to revalidate.
‘During your appraisal discussion, you will be expected to demonstrate, with reference to the supporting information, that you are up to date and fit to practise, and that you have reflected on your practice and identified any area for improvement.
You may find it useful to review the GMC’s appraisal framework, which sets out 12 professional attributes against which doctors’ practice should be considered during appraisals.
‘Following your appraisal, you should have a new personal development plan setting out your objectives for the following year, such as further training. It will then be up to you to meet these objectives and update your portfolio before your next appraisal.’
What are the possible outcomes of revalidation?
A responsible officer can make one of three recommendations about a GP. They can:
• make a positive recommendation that the GP is up to date and fit to practise, and should be revalidated
• request a deferral because more information is required to make a recommendation (for example, in the event of a career break)
• notify the GMC that the GP has failed to engage with any of the local systems or processes (such as appraisal) that support revalidation.
However the recommendation, deferral, or notice of failure to engage is not the final decision on a GP’s revalidation. The responsible officer can only submit their decision to the GMC; the GMC makes the ultimate decision.
What will happen to my licence to practise if a decision about me is deferred, or my responsible officer says I have not participated in revalidation?
If a responsible officer requests a deferral of a doctor’s revalidation date, the GMC will consider their request and decide if it is appropriate to defer. A deferral of a doctor’s revalidation date is an administrative process and has no impact on a doctor’s licence to practise.
All licensed doctors must participate in revalidation to maintain a licence to practise. This is a legal requirement. Doctors must also participate in local processes that underpin any revalidation recommendation. Doctors will put their licence at risk if they fail to engage, despite being given ample opportunity to do so. All local efforts to deal with the problem should be exhausted before the doctor’s non-engagement is reported to the GMC.
If I feel I’ve been unfairly treated. Can I appeal?
The GMC says that it has put in place a number of safeguards to ensure revalidation is delivered in a way that is fair for all doctors, including clear guidance for responsible officers on assessing evidence, flexibility for doctors who are absent from work for long periods and guarantees that doctors will not be penalised for any failures by their employers or responsible officers.
GPs will have a right of appeal in respect of any decision that affects their registration or licence to practise. If the GMC becomes aware that a doctor has failed to engage with revalidation, it will contact the doctor directly and give them an opportunity to engage. If a doctor’s licence is withdrawn by the GMC because of a failure to engage, the doctor can appeal to a GMC registration appeals panel.
The GMC is also conducting a programme of evaluation, supported by independent research, to assess the impact of revalidation, including the impact on different groups of doctors. Alongside this, a separate quality assurance programme will collect and analyse data about responsible officers’ recommendations to ensure they are consistent and fair.
If I’m remediated, does that process defer the revalidation cycle?
Not necessarily. Local remediation may be appropriate to support a doctor if problems with their practice are identified. A responsible officer may request that a doctor’s revalidation date be deferred until a period of remediation has concluded.
In some cases, a deferral may not be necessary, if the concern is a low-level one and the responsible officer is satisfied that the doctor is fit to practise and that there are no risks to patients.
How will remediation, or cover for GPs undergoing remediation, be funded?
The BMA says that this has yet to be fully determined – there is now an agreement that funding will be provided but the details are being looked at by an NHS Commissioning Board working group.
Is collecting 50 CPD credits a year mandatory?
No, it is not. RCGP revalidation lead Professor Nigel Sparrow says: ‘The GMC simply states that a doctor needs to keep up to date. All the royal colleges are using a credit system for measuring CPD with 50 credits a year required. All the other colleges use a time-based credit system, where one hour of learning plus a reflective record equals one credit.
‘However, the RCGP recognises the value of implementation of learning in practice and so the time-based credit can be doubled if the GP can demonstrate how the learning has been used in practice.
‘If the credit system is not used, the GP has to decide how they will show their appraiser that they are keeping up to date.’
Dr John Holden, senior medical adviser at the Medical and Dental Defence Union of Scotland (MDDUS), adds: ‘Revalidation should not simply be seen as a test you either pass or fail. It is designed to help doctors meet the required standards and is a continuous process.
‘You will have the opportunity to discuss any exceptional circumstances with the appraiser and then make plans to address the shortfall in CPD. The doctor and appraiser should agree how the appraisal is summarised and what steps the doctor will take to address any issues.’
What is the minimum number of sessions I need to document to meet the supporting information criteria?
If you do not work full time in general practice, you will still need to provide the same amount of supporting information as your full-time peers in order to demonstrate that you are up to date and fit to practise.
Professor Sparrow says: ‘The RCGP recommends that responsible officers should be willing to consider a standard portfolio so long as it meets the requirement to document 200 half-day clinical sessions, of which 100 are from the two years prior to revalidation.
‘A half-day is defined as four hours, of which 2.5 hours are face-to-face clinical contact. If a GP believes they cannot meet the minimum criteria for supporting information, they should discuss this with their responsible officer who will consider their individual circumstances.’
I work in a remote practice and it is difficult and costly for me to access CPD activities and to get feedback from colleagues. Are my circumstances likely to be taken into account?
Dr Holden says: ‘There is likely to be consideration given to a GP’s circumstances and if you don’t have many colleagues, you may have to agree with your appraiser another way of demonstrating the attributes required by exploring alternative forms of evidence. GPs in remote areas might, where appropriate, consider using alternative evidence-based methods which may better satisfy the requirements. For example, it may be more valid for GPs who have fewer contacts to opt for a smaller, detailed sample of contacts than a larger sample of people who have limited knowledge of the GP.’
Will revalidation affect where I am registered as a patient?
It is likely to, yes. The GMC’s Good Medical Practice Framework for Appraisal and Revalidation states that doctors should make arrangements for accessing independent medical advice when necessary. It says ‘Ensure that you have access to independent and objective medical care’.
How do revalidation and fitness-to-practise procedures fit together?
Revalidation is not a new way of raising concerns about a doctor’s fitness to practise. Any concerns about a doctor’s fitness to practise will be raised through the GMC’s existing processes as soon as they arise.
If a GP is subject to a GMC fitness-to-practise investigation at the point when they are due to be revalidated, their revalidation date will be postponed.
Why is revalidation being introduced?
According to the Department of Health, revalidation is a new approach to the regulation of licensed doctors that will give doctors a clear framework to reflect upon and improve their quality of care as well as ensuring that a doctor’s practice is systematically reviewed. The DH says revalidation will provide assurance to patients and the public that their doctor remains up to date and fit to practise medicine.
How much is revalidation costing the NHS?
The cost of revalidation for the majority of doctors who are already doing appraisals is expected to be relatively small, according to the DH. However, it has so far refused to publish detailed cost estimates. Its official impact assessment, which will include a detailed analysis of the costs and benefits of revalidation, will be published later this month.