Considering information about a doctor's fitness to practise
This page is in Section 2: Considering your recommendation about a doctor's revalidation - part of the GMC's guide for responsible officers on making revalidation recommendations.
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Your responsibility to consider information
This section clarifies some important points about what information you should consider when you formulate a recommendation.
The scope of your statutory responsibility to make revalidation recommendations is defined in the Responsible Officer regulations 2010 and the General Medical Council (Licence to Practise and Revalidation) Regulations 2012.
To fulfil your statutory function of making revalidation recommendations to the GMC, you will need to consider a range of information, as described in this section.
You will need to consider the information available to you about a doctor’s fitness to practise in order to inform your judgement about their revalidation. Your consideration of the available information will have one of three outcomes:
- your recommendation that the doctor’s licence to practise should be continued, based on your informed judgement that they are fit to practise
- your request for the GMC to defer the date on which you are required to make a recommendation about the doctor’s revalidation
- your notification to the GMC, that a doctor has not engaged in systems and processes that support revalidation, and consequently, that you are unable to make a positive recommendation about their revalidation.
The range of information you should consider
An RO will need to consider the following sources and types of information for every doctor about whom they make a recommendation:
- a doctor’s participation in annual appraisals, where the doctor is not in a training programme
- the supporting information collected by the doctor
- the assessments and other curriculum requirements of a doctor’s training programme, where the doctor is in a training programme
- the systems of clinical and corporate governance that are in place within the doctor’s workplaces
- information from all organisations in which the doctor has undertaken medical practice
- the doctor’s compliance with GMC conditions or undertakings that have been placed on their registration during the current revalidation cycle
- the doctor’s compliance with any locally agreed conditions on the doctor’s practice
- any unaddressed concerns about the doctor’s practice.
When submitting your recommendation, the GMC expects that you agree with the totality of the statement that accompanies the recommendation that you are making. Section 3 and Section 4 describe the statements and criteria that apply to each type of recommendation.
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Information from a doctor’s participation in systems of annual appraisal
All three recommendation categories require an RO to agree to statements relating to the doctor’s participation in annual appraisal during the current revalidation cycle.
You must be satisfied that, within the designated bodies for which you are the responsible officer (RO), arrangements for doctors’ appraisals provide you with reliable outputs.
The GMC does not require you, as an RO, to look at each individual piece of supporting information that a doctor collects for their revalidation. It is for you to judge the level of detailed information that you need to review when considering your recommendation.
Reflecting the requirements of the GMC’s Good Medical Practice Framework for appraisal and revalidation
You will need to consider whether the annual appraisals that the doctor has participated in reflect the principles set out in the GMC’s Good Medical Practice (GMP) Framework for appraisal and revalidation (pdf).
To recommend a doctor for revalidation your judgement must be that the doctor's annual appraisals do reflect the requirements of the GMP Framework.
You have an obligation to ensure that, within the designated bodies for which you are the RO, systems of medical appraisal comply with the principles set out in the GMP Framework.
Appraisal systems outside your designated body
In some cases you will not have responsibility for the system of appraisal in which a doctor participates, but will remain the doctor’s RO. In making a decision about a doctor’s revalidation you must consider whether the doctor’s appraisals meet the GMC’s requirements as set out in the Good Medical Practice (GMP) Framework.
Regardless of whether you have responsibility for the appraisal system in which a doctor participates, you must take reasonable steps to ensure that a doctor’s appraisals meet the GMC’s requirements. This includes:
- ensuring that local systems record information about all areas of a doctor’s practice, and
- working with appraisers and others who summarise and collate information about a doctor’s appraisals.
You are not responsible for developing appraisal systems in organisations for which you are not the RO but you will need to consider whether the system is robust in making your recommendation about the doctor’s revalidation.
Where you believe that a doctor’s appraisal system does not meet the principles in the GMP Framework, you should raise your concerns with the organisation in question as soon as possible.
Appraisal for the purposes of revalidation
Appraisal can serve a number of purposes; doctors may be required to participate in systems of appraisal for reasons other than revalidation. As such, local or organisational requirements may be incorporated into a doctor’s appraisals.
In this regard you need only consider whether the doctor’s appraisals meet the GMC’s requirements for revalidation, as outlined in the Good Medical Practice (GMP) Framework and the GMC’s Supporting information for appraisal and revalidation (pdf).
Considering the whole of a doctor’s practice
In making your recommendation you will need to make a judgement about whether the doctor’s system of annual appraisal has enabled them to present and discuss information from across the whole of their practice.
Some doctors will undertake medical practice in more than one organisation. You will need to consider information from all organisations in which a doctor practices when making your recommendation.
To make a positive recommendation about a doctor’s revalidation, your judgement must be that the whole of a doctor’s practice has been considered at annual appraisal, in line with the principles of the Good Medical Practice (GMP) Framework.
This section provides more information about the transfer of information about a doctor’s revalidation between organisations. Information about information sharing and other relevant issues is also included in the GMC’s guidance on Confidentiality and Leadership and Management for all doctors.
A doctor’s responsibility to participate in appraisal
Licensed doctors must participate in systems of appraisal that are robust for revalidation.
If you cannot state that the doctor’s appraisal system reflects the principles of the Good Medical Practice (GMP) Framework or considers the whole of the doctor’s practice, you will need to consider whether this is due to the doctor’s failure to engage with appraisal.
In this circumstance, you should refer to the GMC’s criteria for deferral requests and criteria for notifications of non-engagement in revalidation to consider which recommendation category is appropriate.
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A doctor’s presentation and discussion of appropriate supporting information
To make a positive recommendation about a doctor’s revalidation you will need to be satisfied that the information the doctor has presented and discussed at annual appraisals meets the requirements of the GMC’s guidance Supporting information for appraisal and revalidation. You should therefore consider whether:
- the doctor has collected all six types of supporting information
- this information has been drawn from the whole of the doctor’s practice
- the doctor has collected this information as frequently as specified in the GMC’s guidance Supporting information for appraisal and revalidation (pdf).
The GMC does not require you, as an RO, to analyse each piece of a doctor’s supporting information in order to make a judgement about their revalidation.
Depending on the scale and complexity of the designated bodies for which you are the RO, you will need to make arrangements for receiving information about a doctor’s presentation and discussion of supporting information at appraisal.
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Information about doctors in training
The arrangements for the revalidation of doctors in training are principally the same as for all other doctors. Nevertheless, revalidation takes account of the existing systems and requirements of training programmes in which doctors participate.
The majority of supporting information required for revalidation is already collected by doctors as part of their training programmes. Where doctors do not routinely collect items of supporting information, they are not expected to go beyond the requirements of their training programme to collect it.
As part of their training programmes, doctors in training will work in more than one organisation. In making your recommendations, you should consider all relevant information from the local education providers in which doctors undertake training placements.
As an RO, your recommendation about a doctor’s revalidation represents your evaluation of their fitness to practise. You should ensure that you consider information about a doctor’s fitness to practise that is available to you from outside the formal assessments and curriculum requirements of their training programme.
You will need to consider the following three factors. These take the place of the factors described elsewhere in Section 2 for licensed doctors who are not in training. These factors are reflected in the wording of the positive recommendation statement.
Participation in the assessments and curriculum requirements of a doctor’s training programme
Doctors in training are required to reflect on their practice by undertaking assessments and through regular meetings with their educational supervisor.
These assessments and meetings reflect the requirement for all licensed doctors to collect and reflect on information drawn from the whole of their practice, as outlined in the GMP Framework for appraisal and revalidation (pdf).
Statement One of the positive recommendation statements:
- acknowledges that doctors in training already work within systems that should enable them to meet the requirements to support their revalidation
- clarifies that doctors in training are not required to participate in an annual appraisal process above and beyond the activities currently required as part of their training programme.
Undertaking and discussing the assessments and curriculum requirements of a doctor’s training programme
As an RO, you will need to make a judgement about whether a doctor in training has undertaken and discussed the assessments and curriculum requirements of their training programme in accordance with the requirements of the GMC’s Supporting information for appraisal and revalidation (pdf).
Statement Two of the positive recommendation statement acknowledges that doctors in training already collect the majority of the supporting information required for revalidation as part of their training programme.
Information collected during the implementation of revalidation
During the implementation phase of revalidation, doctors in training are not required to collect all six types of supporting information as laid out in the GMC’s Supporting Information for appraisal and revalidation if this is not currently a requirement of their training programme or curriculum.
Arrangements for the revalidation of trainees will be linked to the existing Annual Review of Competence Progression (ARCP) processes or equivalent.
Regardless of whether you are part of the ARCP panel for a doctor in training about whom you make a recommendation, as an RO you will use the outputs of the ARCP panel to inform your judgement.
ARCP panels will be required to consider additional clinical governance information and to make a judgement on the revalidation recommendation as well as on progression through training.
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Information available to the responsible officer from relevant clinical and corporate governance systems
A doctor’s collection of supporting information and participation in appraisal or assessment is an important source of information for your recommendation. You also need to take account of other relevant information generated by the clinical and corporate governance systems in which the doctor works.
As an RO, you should have regard for information generated by any local processes that inform your recommendation about a doctor’s revalidation. These may include, but are not limited to:
- disciplinary or other human resources processes
- processes that address a doctor’s non-engagement with revalidation
- remediation programmes in which a doctor has participated.
To make an informed recommendation, you may need to consider the outcome of an ongoing or recently concluded process. In this instance you should consult the GMC’s criteria for deferral requests.
Information for the purposes of revalidation
You must ensure that the information you take into account from clinical and corporate governance systems is relevant to your recommendation about whether a doctor remains fit to practise, and whether their licence to practise should be continued.
Revalidation is not a mechanism for resolving local employment or contractual disputes. It does not replace existing mechanisms for dealing with such issues.
You must not base your recommendation on information that does not inform your judgement about the doctor’s fitness to practise and whether their licence to practise should be continued.
Information sharing between organisations
As an RO you are responsible for ensuring that robust systems of clinical governance exist within your designated body or bodies. You will have access to a range of information from clinical and corporate governance systems including:
- serious incidents
- fitness to practise issues
- time out of practice
- remediation processes.
You should ensure that arrangements for the transfer of relevant information about a doctor’s revalidation exist between all organisations in which a doctor works.
The importance of information transfer
As revalidation is based on an evaluation of the whole of a doctor’s practice, designated bodies and ROs may need to gather governance information from a range of sources. These include but are not limited to:
- voluntary work
- private practice
- NHS organisations
- locum work.
Facilitating the transfer of information from separate systems of clinical and corporate governance will allow doctors to collect and reflect on information drawn from the whole of their practice.
Effective systems of information transfer will enable organisations to:
- collate information about a doctor’s revalidation
- transfer information to a doctor’s designated body, and
- help ROs to ensure that they can consider all available information when making a recommendation.
Designated bodies and ROs will need to ensure that information is exchanged appropriately between organisations. Particular consideration should be given to data protection and freedom of information legislation and relevant GMC guidance, including Leadership and management for all doctors and Confidentiality.
Collating information about doctors in training
If you are the RO for doctors in training, you will need to consider clinical governance information that assures you about their fitness to practise, in order to make a recommendation to the GMC. This includes information from all organisations in which they have undertaken clinical placements.
ROs are not, however, responsible for collecting supporting information on behalf of a doctor in training. The GMC’s guidance Supporting information for appraisal and revalidation (pdf), clarifies that licensed doctors remain responsible for collecting information from across their whole practice and for discussing this information at appraisal.
Doctors in training programmes will collect information in support of their revalidation, by participating in the assessments and curriculum requirements of their training programme.
Other relevant information
The majority of information that informs your recommendation will be generated by appraisal, supporting information, and corporate and clinical governance systems.
Nevertheless, you should take account of any other relevant information that you become aware of. This section refers to further sources of advice and information you may wish to consult in making your recommendations.
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Compliance with GMC conditions and undertakings
A number of doctors will be practising with GMC conditions or undertakings placed on their registration, at the time you are due to make a recommendation about their revalidation.
The existence of GMC conditions or undertakings on a doctor’s registration does not preclude them from revalidating. Rather, you must monitor a doctor’s compliance with any conditions imposed by or undertakings agreed with the GMC in accordance with the Responsible Officer regulations 2010.
You are responsible for ensuring that, within the organisations for which you are the RO:
- systems are in place to monitor doctors’ compliance with existing conditions and undertakings
- systems are in place to ensure that there are no fresh concerns about the fitness to practise of these doctors.
This should include maintaining regular contact with the GMC to discuss new and existing fitness to practise concerns about the doctors for whom you are responsible.
You should recommend a doctor for revalidation where they are complying with conditions imposed by, or undertakings agreed with the GMC, and you agree with all relevant GMC criteria for positive recommendations.
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Compliance with conditions agreed locally
Concerns about a doctor’s fitness to practise should be referred to the GMC in line with our guidance on the threshold for referring concerns (pdf).
Nevertheless, organisations may feel it appropriate to agree conditions on a doctor’s practice where a concern about their practice is raised, regardless of whether it meets the threshold for referral to the GMC, or whether the doctor is found to be impaired as the result of a GMC investigation.
What are locally agreed conditions?
For the purposes of revalidation, locally agreed conditions refer only to conditions on a doctor’s practice that are agreed in response to a concern about a doctor’s fitness to practise locally. They do not refer to other contractual or employment arrangements between an organisation and a doctor.
The agreement of local conditions remains a matter for individual organisations. Organisations may agree conditions:
- in addition to GMC conditions or undertakings
- where there are no GMC conditions or undertakings on a doctor’s registration
Taking account of local conditions in your recommendation
While the creation and management of locally agreed conditions remains a matter for organisations that contract or employ a doctor’s services, as an RO you should consider a doctor’s compliance with any locally agreed conditions when making your recommendation.
Compliance with locally agreed conditions is referred to in Statement Four of the positive recommendation statements.
If, in your judgement, a doctor is complying with conditions on their practice that have been agreed locally, you are able to recommend the doctor for revalidation, providing that you satisfy the GMC’s other criteria for positive recommendations.
If, in your judgement, a doctor is not complying with locally agreed conditions on their practice, you should consult the GMC’s recommendation criteria in Section Four to determine whether it is appropriate to:
- report the doctor’s failure to comply, to the local organisation(s) in question
- request the deferral of your recommendation or
- notify the GMC of the doctor’s non-engagement in revalidation.
You should also consider whether the doctor’s failure to comply with locally agreed conditions meets the threshold for referral to the GMC.
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Unaddressed concerns about a doctor’s fitness to practise
As an RO, you cannot make a positive recommendation about a doctor’s revalidation, if you identify concerns about their fitness to practise that are not being addressed through local or national mechanisms.
To satisfy yourself that there are no unaddressed concerns about a doctor’s fitness to practise you should consider the following sources of information:
You should not raise concerns about a doctor’s fitness to practise via your recommendation. As soon as you identify a potential concern about a doctor’s fitness to practise, you should consider the thresholds for referring concerns (pdf) to the GMC’s fitness to practise procedures or consider what action you need to take locally.
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Insufficient information about a doctor’s revalidation
You will need to consider whether you have sufficient information on which to base a positive recommendation about a doctor’s revalidation.
If you have insufficient or incomplete information on which to base a positive recommendation, you must determine whether it is appropriate to request the deferral of your recommendation, or notify the GMC that the doctor has not engaged in revalidation.
You will have sufficient information about a doctor’s revalidation if the doctor meets the GMC’s minimum requirements for collecting and reflecting on supporting information, and participating in appraisal or training programme assessment. The GMC’s requirements are outlined in:
In making a recommendation about a doctor’s revalidation, you are not benchmarking a doctor’s engagement in revalidation against that of their peers. You are confirming that an individual doctor has met the minimum requirements for their revalidation as set out by the GMC.
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