Regulating doctors, ensuring good medical practice

Criteria for deferral requests

These criteria describe the circumstances in which you, as a responsible officer (RO), can request that the GMC defers the date by which you must submit a recommendation about a doctor’s revalidation (the ‘submission date’).

These criteria apply only to the licensed doctors for whom you are the RO. You cannot make a recommendation about a doctor if you are not their RO.

The ways in which doctors will have a prescribed connection to a designated body are set out in the Responsible Officer regulations 2010.

Deferring a doctor’s revalidation submission date

The process of deferring a doctor’s revalidation submission date begins with an RO’s deferral request. Successful deferral requests conclude with a revised submission date being placed on the doctor’s record.

The criteria for responsible officer deferral requests

As an RO you should be satisfied that the following criteria apply when you request the deferral of your recommendation. These criteria reflect the statements that you must agree when you submit a deferral request to the GMC:

  • the doctor is engaging in local processes that support revalidation

  • you cannot make an informed recommendation about the doctor’s revalidation on the basis of the information that is currently available to you, when compared to the requirements of the GMC’s guidance Supporting information for appraisal and revalidation (pdf)

  • you have identified the additional information or process outcomes that you require in order to make an informed recommendation

  • you have identified where and when this information will be obtained

  • you are confident that the requested deferral period will enable you to consider the outstanding information and make a revalidation recommendation

  • you are confident that the doctor is engaging, and will continue to engage with, the local processes that underpin revalidation.

At any point before you submit your recommendation you can seek advice from the GMC Employer Liaison Adviser (ELA) for your area.

When is a deferral request appropriate?

Incomplete supporting information

Licensed doctors must collect the information outlined in the GMC’s guidance Supporting information for appraisal and revalidation (pdf).

This information must be drawn from across the whole of their practice. Doctors will need to present and discuss this information at their annual appraisals.

Some doctors may not have been able to collect and reflect on all of the required supporting information by the time that their revalidation falls due.

Examples of the reasonable circumstances that could account for a doctor having incomplete supporting information might include:

  • maternity leave

  • sabbatical or break from practice

  • periods of practice outside the UK

  • sick leave

  • where a doctor has recently gained a prescribed connection to your designated body, and is waiting for their supporting information to be transferred.

This list is not exhaustive. You must exercise your judgement in determining whether a doctor has engaged in the local processes that support revalidation, and whether it is appropriate to request a deferral. In these cases you may find it helpful to contact the GMC ELA in your area, for further discussion.

Ongoing local investigation or disciplinary process

In some circumstances, as an RO you may need to request the deferral of your recommendation in order to consider the outcome of ongoing or recently concluded local disciplinary processes or investigation. These processes are likely to relate to a doctor’s conduct or performance.

When you request a deferral on this basis, you should be satisfied that the following criteria apply:

  • you will not be in a position to consider the outcome of that local process by the date on which the revalidation recommendation is due

  • you expect that the outcome of that local process will enable you to make an informed recommendation about the doctor’s revalidation

  • where appropriate, you are confident that any concerns about the doctor’s fitness to practise do not meet the threshold for referral to the GMC’s fitness to practise procedures (you should also consider discussing any such concerns with your GMC ELA).

Deferral period

In your deferral request, you must specify the additional length of time that you need in order to make your recommendation about a doctor’s revalidation.

If you submit your recommendation through GMC Connect you will be asked to specify a new date by which you expect to be able to submit your recommendation. This date must fall within the subsequent twelve months.

You should choose a submission date that reflects the length of time you think you need to receive and consider any outstanding information that may be relevant to the doctor’s revalidation.

The GMC may ask you for further information about the deferral requests that you submit. This may be because, for example, you have already requested a deferral in respect of the same doctor.

At any point before you submit your recommendation, you can seek advice from the GMC ELA for your area.