WELSH NHS CONFEDERATION
GENERAL MEDICAL COUNCIL REVALIDATION: THE WAY AHEAD
DRAFT RESPONSE TO CONSULTATION
MAY 2010
- Introduction
The following is a composite response on behalf of NHS organisations in Wales, prepared by the Welsh NHS Confederation, to the General Medical Council’s consultation on how revalidation will work in practice.
- Response
General
The Welsh NHS Confederation welcomes the opportunity to provide a composite response on behalf of NHS organisations in Wales. We understand that the All Wales medical executive will be providing a response from the medical profession within Wales.
In general, we support a process that will assure patients, the public, employers and other healthcare professionals that licensed doctors are up to date and are practising to the appropriate medical standards. We also support the principle of revalidation being based on existing local systems of appraisal and clinical governance. We also welcome the acknowledgement in the consultation document that the introduction of revalidation needs to acknowledge the complexity of modern healthcare, including the different systems and structures in four countries and the full range of healthcare providers.
We fully support the need for organisations to support doctors in meeting the requirements of revalidation and recognise that organisations will need to have robust and resourced clinical governance and appraisal systems in place to do this.
The response will be laid out under the headings of the 4 sections of the consultation document and each question raised in the document will be answered in turn.
Section 1 – How revalidation will work
Q1 Do you agree that revalidation should be based on a single set of processes for evaluating doctors’ performance in practice, rather than split into the separate elements of relicensing and recertification?
Yes, given that the Royal Colleges and Faculties’ specialist standards are not separate from the GMC generic standards but built upon them. It will also provide simplicity and ensure that doctors, patients and employers/contractors will be able understand the process.
Q2 Do you agree that revalidation should be based on a continuing evaluation of doctors’ performance in the workplace?
Yes, the GP appraisal system in Wales has been well received and successful in recent years and a similar system should be developed for all doctors. Doctors should be annually appraised and their performance linked to national agreed standards and any areas for action identified. This will allow any issues to be addressed well in advance of any revalidation date.
Q3 Do you agree with the proposals for dealing with the most common situations where a Responsible Officer may not be in a position to make a positive recommendation?
We support the proposal that the responsible officer should be a senior licensed officer and should be the Medical Director or a delegated deputy in the case of NHS organisations in Wales. We understand the types of scenario outlined whereby a responsible officer may not be able to make a positive recommendation. We fully support the notion that where there are concerns about a doctor’s practice that these should be identified and addressed as early as possible through internal processes, e.g. the local appraisal and clinical governance processes.
Q4 Do you agree that the Colleges and Faculties should not be directly involved in the recommendations made by the Responsible Officer to the GMC?
We note that all Colleges and Faculties feel that their role should focus on setting standards and agreeing the relevant supporting information for doctors in their specialty, as well providing guidance and advice to appraisers on these issues. We support this role and agree that the Responsible Officer should make the individual recommendations to the GMC, seeking advice from the Colleges and Faculties as appropriate.
Q5 If so, what do you think their role should involve? a) Setting standards and defining specialty information b) Advice and guidance for appraisers c) Advice and guidance for responsible officers d) Audit and quality assurance of the recommendation process
We feel that the Colleges and Faculties could add value to all the above.
Q6 Do you agree that for trainees, successful progression through training should be the means of securing revalidation?
We fully agree that revalidation should not create additional burdens for trainees, particularly given the recruitment problems in Wales. The proposal that the Annual Review of Competence Progression (ARCP) should be suitably enhanced to ensure its robustness for revalidation is a sound one. Completion of this process along with the view of local clinical governance leads and local medical director leads that there are no issues of concern should allow trainees to revalidate.
Q7 Do you agree with our proposals for the revalidation of doctors with no medical practice of any kind?
Yes.
Q8 Do you agree that the list of registered and licensed medical practitioners should indicate the field of practice on the basis of which a doctor has secured revalidation?
This proposal can only be beneficial to employer organisations, particularly if a doctor’s recent practice for the purposes of revalidation has been in a non clinical discipline. However, the fact that many doctors practise across more than one discipline needs to be borne in mind.
Section 2 – What doctors, employers, and contractors of doctors’ services will need to do
Q9 Do you agree that, for the purposes of revalidation, the Good Medical Practice Framework is an appropriate basis for appraisal and assessment?
As stated earlier, we agree that existing local systems of appraisal and clinical governance should form the basis of revalidation. We also support the need for generic professional standards by which to measure doctor’s performance. Given that the GMP framework’s key principles are broadly relevant to the whole medical profession, it seems appropriate that it provides a foundation for the development of local systems.
Q10 Do you have any further comments on the proposed use of the Good Medical Practice Framework?
See above Q9.
Q11 Is the overall approach to the development of standards and supporting information for revalidation reasonable? If not, what else is necessary?
We note the wide range of submissions received from the Colleges and Faculties. We are pleased that the Academy of Medical Royal Colleges has worked with the individual colleges to ensure a degree of consistency, and support the criteria by which the specialty standards for each College and Faculty were evaluated against by the GMC. We also support the notion that the standards and supporting information should be relevant and applicable to all doctors in clinical practice.
Q12 Is the supporting information proposed by the Colleges and Faculties meaningful, practicable and proportionate for the majority of doctors in clinical practice?
Information not considered.
Q13 Do you agree that these are the appropriate principles to guide doctors’ CPD activity in relation to revalidation? If not, what alternative approach is required?
We agree that CPD is one of the ways in which doctors will be able to demonstrate that they are meeting the required standards. The core principles that are proposed to guide CPD activity are sound, i.e. it should focus on personal development, should cover the full scope of their practice, should promote self reflection, should be outcome focussed, should be needs based, should be influenced by clinical governance and appraisal process and should reflect quality and diversity.
Section 3 – Patient and public involvement in revalidation
Q14 Do you agree with our approach to patient and public involvement in revalidation? If not, what other arrangements would you suggest?
We agree that patient and lay involvement should be in an advisory and quality assurance capacity rather than in individual recommendations made by the Responsible Officer. NHS organisations may wish to use the experience of their non officer members to add value to their process, through their appropriate sub committees.
Q15 Do you agree that the GMC Principles, Criteria and Key Indicators for Colleague and Patient Questionnaires in Revalidation are appropriate for evaluating these types of questionnaires for revalidation?
Yes, these appear sound.
Q16 Do you agree that doctors should be required to participate in colleague and patient (where applicable) feedback at least once in each five year cycle?
We agree with the principle of colleague/patient feedback and feel that it should happen on a more frequent basis.
Q17 Do you think that there should be a mechanism for making sure that colleague and patient questionnaires comply with our criteria for evaluation?
We recognise the need to ensure quality and consistency in relation to these questionnaires. We do not have a strong view on whether the GMC should be involved in reviewing and accrediting these questionnaires or whether individual NHS organisations should be tasked with ensuring that the questionnaires comply with the criteria.
Section 4 – How and when revalidation will be introduced
Q18 Do you agree that revalidation should be introduced initially in areas and organisations where local systems are developed and sufficiently robust to support the revalidation of their doctors?
We fully support the phased incremental approach to the roll out and understand the advantages of beginning in areas with well developed local appraisal and clinical governance systems. We are aware of certain pilot sites in Wales in relation to doctor appraisal and recognise that other areas will indeed be able to learn the lessons from these pilot sites.
Q19 Do you agree with the proposed approach for the initial roll out of revalidation? If not, what alternatives do you suggest?
See above Q18.
Q20 Do you agree that a deadline should be set for organisational readiness for revalidation?
We accept the need for a reasonable and realistic deadline to work towards.