The GMC has launched a consultation on revalidation and is seeking the profession’s feedback to help them shape the final process.
The consultation asks 20 questions covering:
1. How revalidation will work, including the roles of responsible officers (RO) and doctors in non-mainstream roles?
2. How it will affect doctors and employers in terms of assessment, education and training?
3. The inclusion of feedback from patients as part of doctors’ assessments.
4. How and when revalidation will be introduced?
Revalidation will be based on local systems of clinical governance and annual appraisal over a five year period. It will be based on a continuing evaluation of a doctor’s practice in the context of their everyday working environment.
For most doctors it will not mean having to do new things or change the way they work. It is not designed to create unnecessary burdens and the vast majority of doctors will have no difficulty in meeting the standards for revalidation, says the GMC.
Doctors will be required to provide information to support their revalidation such as audit data, outcome data and evidence of participation in CPD. The RO, who will most likely be the trust’s medical director, will then make a recommendation to the GMC as to whether the doctor should be revalidated and it will be for the GMC to make the final decision.
Where there are concerns about a doctor’s practice the RO will not be able to make a positive recommendation to the GMC. Where possible these concerns will be addressed through a process of remediation involving appraisal and clincial governance processes.
Also revalidation may be deferred if there are any gaps in the supporting information provided by the doctor.
GMC chair Prof Peter Rubin, says: “What is being proposed is no more than what should be happening in every doctor’s practice - it is based on local systems of annual appraisal over five years and affirms what has already been demonstrated through that appraisal process.”
Revalidation will be phased in over a period of five years following extensive piloting. It will be introduced only when individual trusts have a robust system of appraisal and clinical governance in place. The first ‘early adopter’ trusts are likely to go live with revalidation at some point during 2011.
The GMC says it is important that doctors respond to the consultation as further work is required to develop the detail of some of the proposals. “We want frontline doctors, patients and all those involved or affect to help shape the final product,” it says.
The consultation runs until 4 June 2010.
The questions the profession has for the GMC
The BMA has a range of concerns relating to revalidation:
1. Workload: reports from some of the pilots suggest that appraisals are taking too long. The proposed appraisal framework is too rigid and will be too time consuming unless greater flexibility is introduced.
2. Remediation: the Department of Health expects there will be a 75% increase in the number of cases involving remediation. But it is not yet clear who will carry out remediation, how it will be resourced and at what point GMC fitness to practise procedures will come into play.
3. Costs: the cost of setting up and then yearly funding of the new roles of ROs and GMC affiliates will be costly. GMC affiliates are a proposed new layer of regulation - they will be medical or lay individuals working at regional level who will help ROs and managers resolve concerns about doctors. The introduction of 1,000 ROs is estimated to be £6.7m in start up costs and £4.5m a year thereafter. The GMC affiliates model is estimated to cost between £4.1m-£7.4m to set up and then up to £4.5m a year to run. Who will pay for this? Is it affordable in the current climate?
4. Responsible officers: medical directors are likely to take on the role of ROs. But there could be conflicts of interest between the medical director’s role of supporting doctors and being accountable to the GMC and/or employer. Also, will medical directors be able to handle the additional workload?
5. IT system: will trust IT systems be able to cope with the need to generate accurate data in areas such as clinical audit, clinical monitoring and activity data, complaints and patients safety systems?
6. Equality: will the royal colleges be able to produce equivalent standards across each specialty and sector? Will locums and doctors from smaller specialties be able to produced sufficient evidence for revalidation?
Concerns raised by medical defence organisations:
1. New disciplinary sanction: the MDU and the MPS is concerned about a new disciplinary sanction against doctors called an “agreed statement of concern” (originally called a “recorded concern” when first mooted by the Chief Medical Officer in 2006). This will be a voluntarily accepted sanction offered by a RO. It will be used for concerns not serious enough to call into question a doctor’s fitness to practise but it will be made available to the public. This could impact on a doctor’s reputation and future career prospects.
Commenting on revalidation Hamish Meldrum, chairman of BMA council, says: “Despite some useful lessons being learned from the early analyses of the various pilot projects, there is still a long way to go before we have a realistic idea of what revalidation will really mean for doctors.
“The uncertainties over how revalidation will work in practice are a barrier to gaining the confidence of the profession - a confidence that is crucial for the success of any system.”
Tags: Revalidation
Yet another time-wasting box-ticking exercise introduced by the most lowly regarded group in society (MPs) in a vain hope of persuading the public that the most highly regarded profession is performing to standard. It will cost a huge amount, take up time that could be better spent in clinical or supporting work, and achieve nothing other than providing employment for the otherwise unemployable.
The GMC should be cut back to the size it was forty years ago and charge a similar annual subscription. PMETB should be abolished, rather than merge with the GMC, and its function repatriated to the Royal Colleges. I would also abolish MMC, the Deaneries, NHS Direct and PCT’s. The whole system of health care has become an end in itself, rather than a means to an end.
Of course this would mean that the politicians would no longer have control over us, and that we might be allowed the privilege of individual thought, responsibility and accountablity, but we couldn’t be allowed that now, could we?
In other European countries and the USA there is no appraisal for freely practicing practitioners ( gps or office based consultants)just a regional or federal licensing which is approved by the regional medical board( and no there are no lay members) which applies regularly reasonable scrutiny-if the public has a complaint they are free to consult their solicitor and take it from there. The public can also choose to go to a different practitioner if they dislike the first one.( so much for 360 appraisal)
The hospital system overseas is tightly regulated by a hierarchy ( professor on top/head of service) and underperformance by practitioners usually leads to dismissal as it does in private industry.
The UK as in many other aspects does things differently- however to ensure this process is done properly and robustly it will require an enormous amount of money and time . So my questions are:
who is training the trainers(ROs) to a satisfactory level?
And who monitors their judgement.( i.e. enhanced appraisal)?
will there be an appeal process in cases of conflicting arguments( i.e. personality clashes with medical director or RO)?
Who is going to pay for all this?
What does it really achieve apart from stopping people doing their job-is anyone going to be a better doctor after undergoing this paper exercise?
I just think all this could be achieved with a lot less hassle by just looking across the pond and get real about a free health service . There is no free health service. Its you and I that will pay for all this .The end.