Responses to Concerns FAQs
This section sets out processes for raising concerns and reporting locally managed concerns about medical education and training, ways in which we may initiate investigation of concerns and outlines how we may respond to concerns. Concerns may relate to any aspect of medical education and training where there is evidence that the GMC’s standards and requirements are not being met.
We are working to ensure that we have a national picture of quality management and that we are proportionate in all of our quality assurance activities. Therefore we need to be assured that concerns are being shared with us, whether:
- they are being managed successfully at a local level;
- assistance is needed in order to manage concerns locally;
- concerns require regulatory intervention.
The Responses to Concerns process deals mainly with the latter two items listed above.
Concerns about any aspect of medical education and training may arise from a number of sources, including the following:
- evidence arising from scheduled GMC quality assurance activity (such as visits to medical schools or deaneries, national trainee and trainer surveys, information from annual reports and scheduled updates from medical schools and deaneries)
- information reported directly from deaneries or medical schools as a result of their quality management activities
- information reported from other bodies and stakeholders, such as employers, Medical Royal Colleges and Faculties, the Quality Assurance Agency and other healthcare regulators such as the Care Quality Commission, NHS Quality Improvement Scotland, Healthcare Inspectorate Wales, or the Regulation and Quality Improvement Authority of Northern Ireland.
- concerns raised with us by medical students, trainees, trainers or others in the training community
- concerns raised with us by patients and the public.
How do I raise a concern?
Any concerns may be reported to the GMC via quality@gmc-uk.org
An individual or organisation reporting a concern must have and be able to share relevant evidence, if we are to investigate further. Reported concerns which are not substantiated by evidence may not be taken forward. Concerns reported anonymously may be followed up if accompanied by appropriate evidence.
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What can I raise a concern about?
A concern may be raised when there is evidence that a medical school, deanery, trainer or local education provider is not meeting our standards. However, we can not interfere with any locally-taken decisions in relation to individuals, such as examination results or assessment outcomes.
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Should some concerns be reported and managed locally?
We will not normally interfere with local processes already in place to deal with issues. For example, if a trainee contacts us with a concern or issue regarding a specific aspect of their training programme, we might refer them to their local deanery which will have processes in place to deal with such situations.
For medical students, we will not intervene to resolve concerns that an individual has raised or should raise with their medical school. However we will take issues into consideration where they affect patient or medical student safety or if we consider that the issues mean that the standards that we set for medical schools are not being met.
If there are serious training concerns, Postgraduate Deans can, with Medical Royal College and Faculty involvement and awareness, remove one or more groups of trainees from a training setting or organisation. Such action must be reported to us immediately, with relevant action plans and timeframes included within the next Deanery Report. Medical schools may also remove medical students from an inappropriate training environment until it can be assured that it is safe and suitable for the training of medical students. This kind of action should also be reported to us immediately, with relevant action plans and timeframes included within the next medical school Return.
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What will the GMC do when a concern is raised?
When a concern is reported to us, we will take initial steps to examine the available evidence to determine whether or not the issue relates to our undergraduate or postgraduate standards and requirements.
Once a concern has been verified, we may ask the deanery or medical school for a formal account of the issue and a summary of actions taken so far. If the deanery or medical school’s approach to the concern is appropriate and effective, further regulatory action will not be taken but monitoring updates may be required.
If the concern requires further action from us, responses may include one or more of the following:
- action planning and monitoring of improvement - this will involve direct correspondence between the GMC and medical school or deanery to investigate the concern, and action plans may be requested within given timelines.
- a meeting where we discuss the concern with medical schools, deaneries, or other relevant stakeholders - for example those from LEPs – this option offers an immediate assessment by GMC representatives and associates and may be undertaken in a situation where either:
- a more rapid response than a full, triggered visit is required or
- a triggered visit may not be necessary to resolve the issues, but detailed discussion with stakeholders is required.
- a triggered visit to further examine the issue and prompt an effective response.
If the deanery or medical school responses to any of the above are unsatisfactory, we may consider further action.
Where appropriate, information about concerns will be shared with the SHA or governing body and other healthcare regulators.
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What are triggered visits?
A triggered visit is undertaken where there is evidence to suggest serious educational failure that requires direct engagement with trainees and the training environment. It is the first stage of withdrawing of approval for a training programme, site, unit, or any other training cohort.
A triggered visit is a short and focused visit carried out by a small team of GMC visitors to investigate a particular concern and may consider a single LEP, training unit, programme or medical school. The visitors will be medical and lay and will be selected from our pool of Associates. We may arrange triggered visits in partnership with a medical school or deanery and, if the issue is specialty-specific, with the relevant Medical Royal College or Faculty.
The outcome of a triggered visit is a report, which will normally be published on our website, although we reserve the right not to publish the report. All stakeholders involved with the visit will have the opportunity to check factual accuracy prior to publication and to respond in the form of an action plan setting out how they are addressing the requirements set in the visit report. The stakeholders will be given appropriate notice of publication.
Any organisation which is subject to a triggered visit may request a formal review by the GMC Postgraduate Board of any decisions included within a triggered visit report.
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What if I have a concern about an individual doctor?
Where concerns relate to the conduct of provisionally or fully registered doctors with a licence to practice, individual doctors may be referred to the GMC. Further information about complaints regarding the fitness to practise of doctors.
If at any point during our investigation of a medical training or education concern a doctor’s fitness to practise is called into question, we may refer the doctor for further investigation.
Further guidance for doctors regarding raising concerns about patient safety.
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Can concerns be identified during a scheduled quality assurance visit?
Scheduled visits to deaneries and medical schools are part of the GMC’s overarching Quality Improvement Framework. These visits are tools to quality assure a deanery or medical school’s quality management processes to ensure that all standards are being met. However, a visit team may need to take action on specific concerns raised during a visit in order to ensure patient and trainee or student safety, or to raise serious educational concerns.
The visit report will note where a concern has been raised, but these concerns may be dealt with separately from the visit reporting process depending on the urgency of the concern.
There are generally two types of concerns which may be identified during a scheduled visit:
- perceived risk to patient, trainee or student safety. This is defined as a 'level one concern'. For example:
- trainees are working without appropriate access to clinical supervision, for example out-of-hours
- trainees are performing procedures or taking consent outside their competence or without appropriate clinical supervision
- failure of the employer to tackle behaviour by trainers or colleagues that is undermining trainees.
- a serious educational concern. This is defined as a 'level two concern'. For example:
- local service pressures mean that no education or formal teaching is being delivered
- cohorts of trainees are not progressing, for example trainees are failing Annual Review of Competence Progression assessments (ARCPsor RITAs) because their training is not appropriate.
Both types of concerns will be discussed and confirmed with the undergraduate or postgraduate dean during the visit and immediate action may be required.
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How are concerns monitored?
Deanery Reports and action plan updates are our key tools for ongoing monitoring of requirements set as part of our quality assurance activity, and for monitoring any concerns until they are resolved. We generally expect any open concerns to be included within the report and integrated into action planning.
We may also ask for additional information or updates regarding concerns when we are aware of additional activity, for example, we may ask for a deanery to share a report from a local visit to a unit where there is an open concern. We reserve the right to ask for relevant additional or supplementary information regarding a concern.
Once a concern has been dealt with and is in the monitoring stages, we may initiate a targeted check to assure ourselves of improvement.
All concerns will be monitored until they are considered to be fully resolved, with sound evidence of improvement and sustainable solutions in place. Concerns may be re-opened if issues re-occur or are found to be persistent.
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What should I do if I have a concern about the quality of my education?
In the first instance, every effort should be made to resolve the issue locally, through the medical school or university. Every school should have a student complaints mechanism in place, and processes to deal with issues that arise. If you are not satisfied with your medical school's response to your complaint, you may wish to escalate to your university, or inform the Office of the Independent Adjudicator for Higher Education. Further information about the Office is available on the OIA website.
The GMC can not become involved in or intervene in any individual cases or complaints, nor can we contest any decisions made by the medical school or university. However, we may consider concerns when they are directly related to securing our standards relating to education and training. Our standards are set out in our publication Tomorrow's Doctors. If you have evidence that your school is not meeting our standards, please contact us at quality@gmc-uk.org. We can provide advice if needed.
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What should I do if I have a concern about the quality of my clinical attachment or student assistantship?
You should report any issues or concerns about the quality of your clinical attachment or student assistantship to your medical school.
Remember that the duties of a doctor registered with the GMC state that you should act without delay if you have good reason to believe that you or a colleague may be putting patients at risk. If you are exposed to situations during your clinical attachment or student assistantship where patients are being put at risk, you should report this to your medical school immediately.
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