Dr Greenock is a junior partner at a GP practice and is working under locally agreed restrictions on her practice. These were adopted after a clinical incident which, after consulting the GMC Employer Liaison Adviser for your area, you judged did not meet the threshold for referral to the GMC’s fitness to practise processes.
Dr Greenock is participating in mentoring and remediation processes willingly. She has cooperated with the appraisal system and has been gathering her supporting information.
You are aware that four years ago, a concern about Dr Greenock’s fitness to practise was investigated, and concluded with conditions being placed on her registration, by the GMC. The information you have from her previous employer indicates that she complied fully with her conditions until they expired, and showed sufficient insight into the incident, the findings against her, her conduct and the need for measures to address her development needs which were put in place at that time.
You are concerned at the implications of recommending that a doctor is revalidated while that doctor is still working under locally-imposed conditions, especially in light of her history, and are seeking advice on whether to defer your recommendation about Dr Greenock.
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In making a recommendation about a doctor’s revalidation, you will be asked to confirm that there are no unaddressed concerns about the doctor’s fitness to practise.
We recognise that some licensed doctors will be practising with restrictions placed on their registration as a result of a GMC fitness to practise (FTP) investigation.
Where a doctor complies, this is not a barrier to revalidation – we need your assurance that, to the best of your knowledge, there are no concerns that are not being investigated, referred, or managed as appropriate. As soon as you become aware of a concern you should raise it in the appropriate way.
What you must agree to when you make the revalidation recommendation statement is that there are no unaddressed concerns about the doctor’s fitness to practise. Fitness to practise procedures will deal with issues of patient safety and enable independent decisions to be made about a doctor’s fitness to practise, measured against professional standards.
Nevertheless, new FTP concerns can still arise. You should not hesitate to raise an FTP concern about the doctor with the GMC if in your judgement it is beyond the threshold for referral, or discuss with our ELAs if you are unsure – even if you have just recommended that the doctor be revalidated. Remember that as an RO you have a professional duty as a licensed doctor to report anything that risks patient safety, either to the GMC or another body as appropriate in the circumstances.
The Licence to Practise and Revalidation regulations (pdf) give the GMC the power to suspend a doctor’s revalidation cycle, where this is necessary because of an ongoing FTP investigation. We will not take a decision about a doctor’s revalidation while FTP proceedings are underway.
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