From: Dr Philip Dobson, Responsible Officer/ Suitable Person

From: Dr Philip Dobson, Responsible Officer/ Suitable Person

To: All doctors with a prescribed connection/Suitable Person connection

Dear Colleague

Appraisal & Revalidation Update:

I am writing to you to give you an update on the appraisal and revalidation systems which are in place for your designated body.

As you are aware, the requirement for GMC licensed medical practitioners to undergo medical appraisal became a legal requirement on 03 December 2012, although it has been considered a professional obligation for over 10 years.

The GMC regulations place the obligation on each doctor personally to ensure that we participate in the appraisal and revalidation process of the organisation with which we have our prescribed connection. If we fail to take the necessary steps to comply with the requirements then we are placing our license and registration at risk.

What are your obligations?

You must fully engage with the appraisal and revalidation process. In practice this means that you must:

1. comply with the policies and procedures which are laid down by your designated body in relation to appraisal and revalidation which are in accordance with the legal regulatory and governance framework.
2. comply with the GMC regulations and guidance for professional practise including “Good Medical Practice 2013”
3. ensure that you have an annual appraisal in accordance with the organisation’s Medical Appraisal Policy. The organisation and booking of the date of your appraisal meeting is your responsibility not that of the designated body.
4. provide, in advance of the appraisal meeting, all of the required supporting information required by your appraiser and responsible officer to enable them to make an informed and objective assessment that you are “up to date and fit to practise”.
5. adhere to the time frames set out by your organisation in terms of lead times for submission of supporting information, dates of appraisal meetings, signoff and submission of appraisal outcomes.
6. ensure that you keep your responsible officer fully informed of any matters which could potentially affect your fitness to practise (such as serious complaints, action by regulators, criminal convictions or serious physical or mental health problems).

During the initial phase of introduction of the appraisal and revalidation process there has been considerable latitude in the way in which the regulations have been enforced because of the novelty and lack of familiarity of doctors and those administering the systems with the processes and expectations of the regulators. This phase is now drawing to a close and going forward I, as well as NHS England and the GMC, will expect that all doctors are familiar with their obligations and comply with them fully or realise that they risk the loss of their license to practise.

What are the main changes ahead?

Appraisal Dates:

You have already been assigned an appraisal date (if you did not accept the automatic reminder and would like it sent you again please contact me directly). This is the nominal date for your appraisal each year and will not change from year to year. It is YOUR responsibility to arrange the appraisal meeting and ensure that it takes place ON TIME. Going forward you will be expected to have had your appraisal meeting by the last day of the month in which your appraisal date falls (for example, if your appraisal date is 16 June then your must have had your appraisal meeting with your appraiser by (at the latest) the 30 June each year). If you fail to do so and you have not requested a postponement of your appraisal then you will be classed as having a late appraisal and this will trigger the non-engagement process.

If your appraisal date is postponed by approval or is late in a particular year then your next appraisal will still be due on the original date – your original appraisal date and month does not change for subsequent years.

Provision of Information to your Responsible Officer.

It is your professional obligation to keep your Responsible Officer informed in relation to any matter which could potentially affect your fitness to practise. You must inform your Responsible Officer immediately if, at any time during the year, your circumstances change (eg, investigation, conviction, serious complaint, health problem etc). A weblink has been provided for submission of this information -

Supporting Information:

The GMC require that you provide evidence in the form of supporting information as part of the appraisal process (see GMC Link for details -

You are require to provide this information (by uploading to you appraisal portfolio eg MYL2P) at least 14 days in advance of the date of your appraisal meeting date. Some doctors have failed to comply with requirement. In future, if your appraiser is not satisfied with the quantity, quality or scope of the supporting information provided, they will be instructed not to proceed with the appraisal meeting and make a report to me to consider if non-engagement processes should be triggered. This may also result in you being charged the full fee for the cancelled appraisal meeting and having to pay for an additional meeting once the supporting information is in place.

You must undertake an independently conducted, GMC compliant multisource colleague and patient feedback at least once in each 5 year revalidation cycleand upload the full report to your appraisal portfolio. Please note that “in house” surveys are not acceptable. You are advised not to leave this until the last year of your revalidation cycle as some doctors have experienced delays in obtaining results in the past. An MSF is a mandatory requirement for revalidation and failure to provide this information could delay your revalidation and may trigger the non-engagement process.

Governance and Quality Assurance:

Doctors must provide evidence of participation in governance and quality assurance processes including provision of CQC or other regulatory reports for the organisation in which they work as part of their supporting information. Where a designated body has in place a centralised quarterly or annual audit system, participation by the doctor will be considered a mandatory component of the supporting information for appraisal.

Scope of Work:

Where a doctor works in more than one organisation the doctor must provide as part of the appraisal supporting information, a letter from the manager, director or chief executive of each organisation confirming: governance compliance, any practicing restrictions and any concerns relating to the doctor.

Mandatory training and policies:

All doctors must confirm and evidence as part of their appraisal that they have completed mandatory training (eg BLS/ILS, infection control and prevention, anaphylaxis) and that they have in place the mandatory policies required by the Responsible Officer (complaints, public interest disclosure, organisation clinical governance and insurance/indemnity for the full scope of practice)

English Language Competence:

The regulations now place an obligation on the Responsible Officer to ensure that all doctors with a prescribed connection are competent in the use of English. From 28 June 2014 all non UK graduating doctors from the European Economic Area, when joining the designated body will have to either provide satisfactory evidence of language competence as detailed in the Guidance On Language Requirements or an IELTS certificate with an overall score of 7.5 or above before they will be accepted into the designated body. All non-UK graduate doctors from outside the EEA must produce a PLAB certificate before they will be accepted into the designated body unless exempted from this requirement.

No doctor may be employed by, contracted with or admitted by the designated body until this evidence has been provided to the Responsible Officer.

For non-UK graduates who already have a prescribed connection with the designated body, appraisers will make a statement in the annual appraisal that there are no language proficiency concerns in relation to the doctor. If the appraiser is unable to make the required statement a doctor may be required to undertake a IELTS test and must then achieve a score of 7.5 or greater otherwise the doctor will be referred to the GMC for consideration of further action.

Evidence of Qualifications and Experience:

Before any doctor can be accepted into the designated body, the doctor must provide satisfactory evidence to the Responsible Officer that their qualifications and experience make them appropriate to the work to be performed.

No doctor may be employed by, contracted with or admitted by the designated body until this evidence has been provided to the Responsible Officer.

Human Resources Checklist and Disclosure Statement:

All doctors with a prescribed connection to the designated body must submit a fully completed HR checklist and signed Disclosure Statement as part of the supporting information for their annual appraisal. This will be provided as part of the materials for preparation for appraisal.

If these documents are not provided the appraisal will be classed as unsatisfactory and will be referred back.

Disclosure and Barring Service Check:

Before any doctor can be accepted into the designated body, the doctor must provide to the Responsible Officer, a satisfactory enhanced vulnerable adult (and also where appropriate child) DBS check, which is no more than 3 months old at the time of submission which confirm that the doctor is suitable for the proposed position.

There is an ongoing obligation on doctors to inform the Responsible Officer of any subsequent convictions either in the UK of abroad. Failure to notify will be dealt with as a fitness to practise issue.

No doctor may be employed by, contracted with or admitted by the designated body until this evidence has been provided and the references have been checked.

Professional References:

Before any doctor can be accepted into the designated body, the doctor must provide two professional references which are acceptable to the Responsible Officer, which confirm that the doctor is suitable for the proposed position.

No doctor may be employed by, contracted with or admitted by the designated body until this evidence has been provided and the references have been checked.

RO Management of Stream 2 Complaints:

From September 2014 the GMC no longer handles stream 2 complaints about doctors (these are low level complaints which do not meet the criteria for full GMC investigation). Instead the GMC will refer the matter to the doctor’s Responsible Officer and it will be for the Responsible Officer to decide if the complaint requires further handling (eg local investigation and what, if any sanctions are appropriate). The full details of this new process are not yet finalised but I will keep you informed as the proposal progresses.

Please accept my apologies for the length of this letter but I am sure you can see that there are a significant number of changes and updates which are becoming necessary to ensure that we continue to comply with the requirements of the GMC and NHS England to ensure that our appraisal systems is robust, fit for purpose and that revalidation recommendations are accepted without question. Please also be assured that I will continue to work to keep the level of bureaucracy and extra work involved for you to the absolute minimum!

Yours Sincerely

Philip Dobson
Responsible Officer