FAQs - The Responsible Officer and making the recommendation to the GMC

Last updated: 1 March 2010

Questions on this page

1. 1. How will the Responsible Officer make a recommendation to revalidate?
2. 2. What if the Responsible Officer cannot make a positive recommendation?
   

More information can be found on our revalidation page.

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1. How will the Responsible Officer make a recommendation to revalidate?

The full details of how the Responsible Officer role will work are still being developed. Further information is expected later this year from the Departments of Health following completion of their current rounds of pilots. However, in broad terms we expect the process will work as set out below once the whole system is up and running.

In the vast majority of cases, a recommendation from the Responsible Officer to the GMC to revalidate a doctor will be based on the positive demonstration of practice against satisfactory standards through a cycle of five annual appraisals and the absence of unresolved concerns about performance.

During that time, the doctor concerned will have accumulated supporting information about his or her practice to show that they are working to the standards set by the GMC and the relevant Royal College or Faculty. This information will be presented at appraisal.

The Responsible Officer will be familiar with the appraisal and local clinical governance processes and will have knowledge of whether there are any unresolved concerns about the doctor.

If the required information about the doctor's practice is present, the Responsible Officer will be able to make a positive recommendation to the GMC that the doctor should be revalidated.

2. What if the Responsible Officer cannot make a positive recommendation?

There are likely to be three main scenarios where this might happen, although the particular circumstances will undoubtedly differ from case to case:

• There may be exceptional cases in which a doctor has not been in active practice and has clearly not engaged with any appraisal process or with his or her Responsible Officer. In these circumstances, there will be little or no evidence on which a Responsible Officer could make a positive recommendation that a doctor is up to date and fit to practise. In these circumstances the doctor will need to take an alternative route for revalidation or can expect to have his or her licence to practise withdrawn. Any decision to withdraw a licence will be subject to an appeal process.
• If there are gaps in the supporting information provided by the doctor, the GMC, based on the recommendation of the Responsible Officer, may decide to defer revalidation to enable the doctor to collect the necessary information. In the absence of negative information indicating that the doctor's fitness to practise is impaired, there would be insufficient grounds for referring the case to the GMC's fitness to practise procedures, but, equally, it would not be appropriate to renew the doctor's licence where there were significant gaps in the supporting information required to show that the doctor was competent and fit to practise.
• Where there are concerns about a doctor's practice these should be identified as early as possible and, where possible, addressed through appraisal and the relevant local clinical governance processes. Action on concerns should not wait until a doctor is due to be revalidated by the GMC. Of course, if there are serious concerns about a doctor's practice, then the Responsible Officer would want to engage with the National Clinical Assessment Service or refer the doctor to the GMC, where there are concerns about patient safety. It is unlikely that these issues would simply come to light at the point in the process when the Responsible Officer is due to make a recommendation to the GMC.  If any concerns are ongoing at the time of revalidation, the recommendation could be deferred until such time as local, National Clinical Assessment Service or GMC processes have been concluded.