The GMC should be accountable to Parliament, the Health Select Committee has concluded in its inquiry into the regulator’s proposals for revalidation.
The GMC is formally accountable to the Privy Council but “in the absence of a mechanism which makes this accountability effective we intend to exercise this function ourselves on behalf of Parliament”, the committee says.
The development of revalidation - over 10 years - has taken too long, the cross-party group of MPs, chaired by Stephen Dorrell, also says.
“Now that late 2012 has been set as the date of implementation, we look to the GMC to ensure that there are no further delays and that the current target date is achieved,” it says.
On the current proposals, the committee warns that too little attention has be given to dealing with doctors whose practice gives cause for concern.
“We regard this as an important weakness in the current proposals which the GMC needs to address if the introduction of revalidation is to help sustain public confidence in the medical profession,” it says.
Remediation
The committee is also concerned about the ‘instinctive’ use of the word ‘remediation’.
The MPs are recommending that the GMC must publish clear guidance to Responsible Officers about how they should deal with the cases of doctors whose performance gives rise to concern.
Otherwise it fears “instinctive use of the word remediation in cases where a doctor’s performance gives cause for concern may have the effect of pre-judging the appropriate response to a particular set of circumstances”.
“While it is important to ensure that the rights and legitimate interests of doctors are safeguarded, the primary purpose of revalidation is to protect the interests of patients,” the committee says.
Appraisal system
Looking at the systems proposed, the Health Select Committee broadly supports the GMC’s proposal that revalidation should be based on the conclusions of employers’ appraisal systems.
However, it confirms that it received evidence showing that the record of employers on appraisal is patchy. “The GMC needs to satisfy itself that all organisations which employ doctors have robust and consistent systems of appraisal in place on a timescale which makes possible its objective of introducing revalidation in late 2012,” it says.
The committee particularly emphasises the importance which it attaches to patient and colleague involvement in the appraisal process - and therefore in the revalidation process. It recommends that the GMC should “undertake a review of best practice in gathering the views of patients and colleagues and develop its proposals in the light of that review”.
Responsible Officers
MPs were also concerned that there should be clear guidance about how Responsible Officers (usually local medical directors) should act when a conflict of interest arises between their responsibility to their employer and their responsibility to the GMC for professional regulation (for example, in cases of whistleblowers).
The committee says: “The GMC should consider further what safeguards may be desirable to protect the interests of individual doctors in circumstances where they believe a conflict of interest may have influenced the decision of a Responsible Officer”.
Language
The health select committee considered the issue of doctors for whom English is a second language.
It says: “We regard the ability of a doctor to communicate effectively with his or her patient as fundamental to good medicine. As the body responsible for revalidation and with a commitment to introducing it by late 2012, we expect the GMC to satisfy itself that it has the necessary powers to fulfil this role; if it is not satisfied (whether as a result of EU legislation or for any other reason) we expect it to say so publicly and report to Parliament what changes are necessary to allow it to fulfil its function effectively.”
Views from the profession
Professor Peter Furness, Academy of Medical Royal Colleges Revalidation Lead, says: “We support the committee’s call for a clear commitment to a firm implementation date.
“The Academy agrees with the committee’s emphasis on patient safety and public protection and agrees with the need to identify doctors who are not performing adequately. However, we must remember that the overwhelming majority of doctors are practising to good standards, and for this reason revalidation must not seem like a punishment for that majority but an opportunity to develop and improve their practice further.
“Revalidation will not succeed unless doctors have the access to the data about their performance and the time to prepare the information for revalidation. It is rightly noted that good doctors working in good institutions are able to do this, in which case the cost of implementing revalidation should be reasonable. But it remains true that there are parts of the health service where this is not the case, and there is a risk that revalidation will fail if this is not corrected.
“The Academy is concerned that in the current challenging financial climate there are likely to be pressures on time made available to doctors. Doctors need time to keep themselves up to date and to demonstrate that they are doing so. We would recommend that this is addressed as a priority.”
Professor Antony Narula, Royal College of Surgeons’ council member for revalidation, says: “We welcome the recognition that appraisal, as the key mechanism in the process, must be improved and made consistent. Ideally, we would like the GMC to specify minimum expectations for how appraisal is managed instead of leaving this to the four departments of health in the UK to design.
“We also support the committee’s call for greater clarity on how doctors who do not receive a positive recommendation of revalidation will be dealt with. We have previously called for the GMC to produce detail on appeals and how the revalidation process interfaces with their existing ‘fitness to practice’ processes.
“We welcome the recommendation that the GMC continues its efforts to resolve problems of doctors from elsewhere in the European Union. The committee’s report does not discuss how the revalidation process applies to ‘fly in-fly out’ doctors who work in the UK on temporary registration and we would welcome a clear statement from the GMC on this.
“However, the college has repeatedly called for a risk based approach to revalidation with the focus on doctors with non-standard careers, particularly locums, instead of doctors working full time in an NHS trust with existing appraisal and clinical governance systems. Unlike the committee, we do not agree that the Responsible Officers Regulations have provided sufficient clarification. We also remain concerned that monitoring of the whole of a doctors practice is not embedded in the system and there is currently no imperative for organisations to share information about clinicians who work in more than one place.”
MDU head of advisory services, Dr Michael Devlin, says: “The MDU does not believe that the proposed role for Responsible Officers in overseeing revalidation includes the necessary safeguards to protect the interests of doctors when there is a disagreement between the doctor and their Responsible Officer or if there is a possible conflict of interest.
“We also told the committee that the current system of appraisal for doctors is patchy. There are quite a few healthcare organisations that do not undertake regular appraisal yet it will be the cornerstone of the revalidation proposals. We made the same point when responding to the GMC consultation in 2010 and we know it has got this on board.
“In the interests of fairness to all doctors, the GMC needs to outline the minimum requirements for revalidation as early as it can so that doctors have plenty of warning. The prospects for doctors who fail to revalidate are bleak and they must all be on an equal footing when it is introduced. Early notice of what is required of them will give them all an equal opportunity to collect the evidence they need before revalidation starts in 2012.”
Dr Hamish Meldrum, BMA chairman of council, says: “I am pleased that the Health Select Committee agrees that the revalidation process needs to be streamlined and more realistic in what it is trying to achieve. It is also reassuring to note that the committee concurs that more guidance and detail is required for Responsible Officers to deal with concerns about a doctor’s performance.
“The process to revalidate doctors has been in discussion for over ten years and this demonstrates that the original proposals were too bureaucratic and unrealistic. It would be better to build on what we have and standardise doctors’ appraisals throughout the UK. The appraisal process could then be regularly improved and used as a tool to give doctors better feedback about their performance so that patient care can be improved even further.
“Unfortunately it is not always the case that sufficient information exists from the appraisal system about a doctor’s performance. Appraisal systems around the country remain patchy, a fact that has been highlighted by the inquiry. The BMA has received reports that some doctors are not being appraised and some do not even have access to data from their trust to enable them to be appraised effectively.
“I urge the GMC to take note of this inquiry and work with doctors to ensure that revalidation is delivered on time and benefits patients and doctors.”
The GMC response
Niall Dickson, chief executive of the GMC, responds: “We welcome the Health Committee’s report and its strong support for revalidation - it is good that MPs are clear that there must now be no delay in its introduction.
“This report makes clear that the committee shares the joint commitment of the GMC and the four UK health departments to introduce revalidation by the end of 2012. It remains our number one priority.
“The report rightly highlights areas where more work is needed - for example, on remediation we remain committed to supporting the four health departments who are taking the lead on this important issue. We are also working on a number of other fronts to make sure revalidation is fit for purpose and we will be supporting the newly appointed Responsible Officers to achieve this.
“The committee also raises two other major issues. First, we would welcome the opportunity to report directly to the Health Select Committee on all areas of our work, including revalidation; we have been calling for this for some time.
“Secondly, the committee highlights the current problem that the GMC cannot check whether doctors from the EU are able to speak English so they can practise safely. We are determined to find a solution and are currently working with ministers and officials at the Department of Health to ensure patients are fully protected.”
Read the full report.
Tags: GMC, Revalidation
