The Secretary of State for Health has announced that doctors will be given annual assessments and full five yearly checks to ensure they are still competent and fit to practise starting from December 2012. The General Medical Council (GMC) will be responsible for revalidation, which will be on the basis of a dossier of evidence of a doctor's competence compiled over five years. This will include annual assessments and patient questionnaires.
 

This article considers why these changes been proposed, what they mean for doctors, how will they be implemented and what are the concerns?

Why do we need revalidation?

Revalidation is a way of regulating licensed doctors. It is akin to relicensing doctors to ensure quality in healthcare and patient confidence is maintained and increased.

The medical profession has been wrestling with the concept of revalidation for many years and the process to be implemented later this year builds on layers of recommendations previously contemplated and changed.

The position remains that once a doctor has qualified, it is assumed that he will remain competent - up to and unless professional conduct proceedings decide otherwise.

However, going forward, doctors will be required to demonstrate they are practising in accordance with the GMCs guidance on "Good Medical Practice" - which sets out the principles and values on which good practice is founded i.e. that which is expected of all doctors registered with the GMC.

What does this mean for doctors?

Revalidation applies to all doctors who hold a UK licence to practice, regardless of their medical specialism (save for those registered for short term temporary periods).

The new regulations will require the GMC Registrar to withdraw a doctor’s licence for reasons of necessity, following on from the doctor’s participation (or non-participation) in revalidation. The Registrar will have discretion to withdraw a licence in certain circumstances, for example, if the doctor fails to provide requested information relevant to their revalidation, or where inaccurate or unverifiable information has been provided.

How will doctors comply with revalidation requirements?

Licensed doctors will have to revalidate every five years, by having annual appraisals based on the Good Medical Practice guidance. At the end of the five year period, the doctor’s Responsible Officer will make a submission to the GMC about the doctor’s suitability to be revalidated. (The Responsible Officer being the medical director of the designated body that is supporting the doctor in his appraisal.)

During the appraisal process the doctor will discuss his practice and performance with his appraiser and use supporting information to demonstrate he is continuing to meet the Good Medical Practice principles. Doctors will be required to maintain a portfolio of supporting information to demonstrate they are continuing to meet the attributes set out in the guidance.

The six types of supporting information doctors are expected to provide and discuss are:

  1. Continuing professional development
  2. Quality improvement activity - i.e. demonstrating regular participation in activities that review/evaluate their quality of work
  3. Significant events: - i.e. demonstration of lessons learnt/action taken following untoward/critical incidents
  4. Feedback from colleagues - feedback is to be collected using standard questionnaires that comply with GMC guidance
  5. Feedback from patients - as above
  6. Review of complaints/compliments - including discussing any changes in practise following a complaint

In order to have a revalidation recommendation made, at least one appraisal (within the five year period) must specifically cover the Good Medical Practice guidance and be signed off by the doctor and the appraiser as having been met.

Implementation

Revalidation will commence in early December 2012 when the GMC (Licence to Practice and Revalidation) Regulations are introduced to replace the existing GMC (Licence to Practice) Regulations 2009. After introduction, the GMC expects to revalidate:

  • Responsible officers and other medical leaders - by March 2013
  • A fifth of licensed doctors - between April 2013 and March 2014
  • The majority of licensed doctors - by the end of March 2016
  • All remaining licensed doctors - by the end of March 2018

What are the concerns?

Concerns have been expressed that the revalidation process may be overly bureaucratic, setting unrealistic expectations on doctors who are already under pressure from busy workloads, and diverting them away from patient care. One of the greatest concerns is with regard to ensuring consistency in the appraisal process and the requests for information in support.

In particular, the British Medical Association (BMA) consider that further work is required to ensure the process is fit for purpose. However, the BMA accepts that the principles it established during the consultation process have been sufficiently addressed to enable the GMC to proceed with its timetable. These principles include transparency around reporting requirements and resolving disputes, as well as ensuring a cost effective process.

If properly implemented and realised, the benefits of revalidation will be significant. However, the process must be sufficiently flexible to apply to all licensed doctors across all medical specialisms. Indeed, it is expected that there will be additional guidance provided by the individual Royal Colleges about the requirements to provide supporting information for specific medical specialisms. Going forward, it is hoped that the first cycle of revalidation will dispel any ongoing concerns. We will therefore be keeping a close eye on developments following implementation.