Revalidation is the process by which doctors holding registration with a licence to practise will have to demonstrate to the GMC that they are up-to-date and fit to practise and complying with the relevant professional standards.
It is a single process with two potential outcomes – re-licensing and re-certification. All doctors will have to be re-licensed, while those on the GP register or the specialist register will have to be re-licensed and undergo specialist re-certification.
Re-licensing will be largely undertaken through local clinical governance processes with the final responsibility for re-licensing resting with the GMC. Re-certification will be led by the medical royal colleges who will in turn have to provide a positive statement of assurance to the GMC.
Background to revalidation
Harold Shipman, a GP working in the north west, became one of England’s most notorious serial killers when he murdered approximately 250 of his patients between 1972 and 1998.
The ensuing Shipman Inquiry was highly critical the GMC’s approach to managing dangerous and incompetent doctors, and called for reform. Dame Janet Smith, chair of the Shipman Inquiry, went on to challenge the GMC’s initial plans for revalidation.
The GMC postponed the introduction of revalidation and the Chief Medical Officer reviewed revalidation afresh. It culminated in the current plans, which include re-certification.
The GMC insist that revalidation is as much about improving quality of care as catching a potential Shipman.
Licence to practise
From autumn 2009, licensing will be introduced for any doctor wanting to pracitse medicine in the UK. They will, by law, need to be both registered and hold a licence to practise. This will apply whether they practise full-time, part-time, as a locum, privately or in the NHS, or whether they are employed or self-employed. Retired doctors who want to continue prescribing, and those with a private practice, will need a licence. There is no need for a doctor to have a licence if they are working abroad.
Timing of revalidation
The GMC is not introducing revalidation at the same time as licensing. Only when we are sure that the necessary systems and arrangements to support doctors are in place, will we begin to implement revalidation. The first revalidations will not happen before 2011. Once revalidation is introduced, licences will be subject to periodic renewal, probably every five years.
The process of revalidation for doctors
Revalidation is the umbrella term that covers both relicensing and recertification. In practice, revalidation will be a single set of processes covering both elements. If a doctor is meeting the requirements for the recertification of their entry in the specialist register, this will also cover relicensing. Nothing extra will need to be done.
Revalidation will be based on elements that most doctors are already familiar with, such as annual appraisal and audit. Work is ongoing to ensure that these local mechanisms are sufficiently robust. By building on arrangements that are already in place, the GMC aims to minimise additional burdens.
Doctors will need to show they’re continuing to practise in accordance with the standards that the relevant royal college or faculty has prescribed for the specialty. They are in the process of developing and agreeing with the GMC the applicable standards and the information that you will need to collect to show that you are meeting those standards.
Specialty specific standards will be linked to the generic standards of practice that the GMC has set for all doctors.
Revalidation will be based upon a process of annual appraisal in the workplace organised by the employer. The information a doctor collects about their practice contributes to the annual appraisal and shows they are meeting the relevant standards.
The outputs from a doctor’s appraisal will be considered by a Responsible Officer – a new role created under the Health and Social Care Act 2008. They will recommend to the GMC whether or not a doctor should be revalidated.
The GMC says that as long as there are no significant unresolved concerns about a doctor’s practisce, and they have continued to demonstrate through appraisal that they’re adhering to the standards for revalidation, a recommendation will be made by the Responsible Officer to the GMC confirming their continuing fitness to practise and suitability to be revalidated.
This role is of concern to some representative organisations, which fear prejudicial decisions.
Costs of a licence to practise
The annual fee for maintaining registration with a licence will be the same as the current annual retention fee (£410). The annual fee for holding registration without a licence will be £145. Holding registration without a licence will allow doctors to show employers, overseas regulators and others that they remain in good standing with the GMC. A doctor cannot practice in the UK without a licence.
Doctor’s preparation for revalidation
Actions doctors should take include:
1. Doctors have until 14 August to let the GMC know whether they would like a licence to practise. If so, they must hold one - in addition to being registered with the GMC - by 16 November.
2. Reviewing their appraisal documentation from the last few years.
3. Checking the evidence that they have claimed in their files, such as courses attended and CPD certificates.
4. Checking what aspects of the PDP have been achieved and what has not. If doctors have uncompleted elements, they should identify reasons for this and record them.
5. Reviewing any changes to job plans or specialist practice, and confirming there is active CPD in those areas.
6. Collecting a list of any accolades or letters of appreciation that have been received.
7. Collecting evidence of any other clinical activity undertaken, such as clinical audits.
8. Collecting evidence of any non clinical activity undertaken, such as multi-source feedback, patient surveys, teaching and research.
9. Making sure that all of the documentation is in place for any complaints or incidents.
10. Ensuring that the clinical or medical director within the trust has copies of the doctor’s appraisals and a record that they have taken place.
Will it involve an exam? The GMC says some specialties are proposing to use on-line open book knowledge assessments as part of CPD and this would contribute to the evidence for revalidation, but no one is proposing a formal examination for practising doctors.
What happens if the GMC takes sanctions against a doctor’s practise? Doctors being investigated under the fitness to practise procedures when the licence to practise is introduced, or have been in the past, will still be entitled to hold a licence provided that their registration has not been suspended or erased.
If a doctor’s name is suspended from the register, they will not be entitled to a licence during the period of suspension. If a doctor’s suspension is lifted and their registration is restored after the introduction of licensing, they will automatically be granted a licence to practise at that point.
What is multi-source feedback? Multi-source feedback from patients and colleagues will be one element of revalidation. It will be organised through the workplace.
The GMC is developing some generic questionnaires to capture patient and colleague feedback. They claim the questionnaires are undergoing extensive research to confirm their validity. If successful, they will be made available to anyone who wishes to make use of them.
Will doctors in training be affected by revalidation? Yes. Doctors in training will participate in revalidation. The GMC intends for doctors in training to be able to use the record of their progress through training for the purposes of their revalidation. There won’t be a separate set of requirements.
Do locum consultants and specialty doctors need to revalidate? Yes. They will still be required to demonstrate that they are practising to the appropriate standards for the specialty in which they are working and the level at which they are practising. Whether they are on the specialist register or not, the specialty standards that need to be met will be the same.
More common questions.
Further support from the DH’s revalidation support team.
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November launch for licences to practise