Home > GMC Scotland > Consultation responses > Health committee calls for written evidence for inquiry into workforce planning in Scotland NHSSafer for Patients, Supportive for Professionals: A Framework for Managing Poor Performance of Health Professionals and Teams in NHS Scotland – A Consultation
GMC Scotland Response
Safer for Patients Consultation Response
GMC Scotland is the Scottish policy office of the General Medical Council and has been established as part of the comprehensive reform of the General Medical Council, shaping a GMC that is fit for purpose in today’s conditions. The General Medical Council functions to ensure the application of commonly held standards across the whole of the UK and is committed to contributing actively to the delivery of excellence in medical practice in Scotland, working with Scottish health organisations, patients and public.
We welcome the opportunity to contribute to this consultation.
Question 1 Do you agree with this analysis of the current situation?
We agree with this analysis of the current situation. It is essential that the public have trust in healthcare professionals and this can only be reinforced by the improvement of Scottish poor performance management systems.
We welcome any developments that encourage greater communication between health professionals’ employers and which increases patient protection.
Question 2 In what way might this analysis of the current situation in Scotland be improved?
A clearer understanding of the number of potential cases involved would be beneficial. It is easier to find a solution when the scale of the problem is understood. From our own experience the GMC is fully aware of the difficulties in providing robust statistics in relation to the number of fitness to practice cases in Scotland. We would be happy to share the information, which we have been able to gather on Scottish cases, with the Scottish Executive and NHS Scotland.
We acknowledge the good work of the colleges, which has been undertaken in recent years in setting up and running the External Clinical Assessment Teams (ECATs). The best practice within colleges can be built upon and should be used within the new framework.
Question 3 Do you agree with these principles on which to build a new framework for action?
We believe that section 8 gives a clear understanding of the key principles, which must underpin the framework. Any system that is adopted must be inclusive and equitable.
Question 4 Are there any other principles which such a framework should embody?
Healthcare regulatory bodies must also have confidence that the proposed framework for action is robust and fit for purpose.
The measures or procedures that will be developed must fit effectively with the healthcare regulatory bodies’ complaints handling procedures. These must be flexible so that they are able to adapt to changes in the regulatory bodies’ procedures.
Question 5 Do you agree with the list of tasks in the framework for action?
Yes, this list is a sound basis for progress.
Question 6 Are there any other tasks which should be included within this framework?
We believe that liaison with regulatory bodies at appropriate points in the operation of model is crucial to the successful implementation of it.
Question 7 Which of the options for taking this framework forward do you favour?
We believe that giving the role to a lead health board or involving a management consultancy, would not be effective. The option of creating a new organisation to undertake this activity would add to the plethora of bodies and has the potential to confuse public and professionals.
Although the NCAA may be able to offer a service level agreement similar to those in Wales and Northern Ireland, this would not allow for the multi-disciplinary approach that is favoured by the Scottish Executive. However the GMC recognises that any structure put in place in Scotland can learn from the work of the NCAA.
NES would be an attractive option if there is a priority placed upon education within this model. We recognise that there may be difficulties with this option, as education may be only one of the aspects within the model.
The NHSQIS role in driving quality improvement in Scotland makes it the natural home for this framework. If NHSQIS was the chosen delivery mechanism this could create problems with the quality assurance mechanism. This would also have significant resource implications, which must be addressed by the Scottish Executive.
It is important that if possible a consensus is achieved within the healthcare community in Scotland over the structure and implementation of a framework.
Question 8 Are there any other options which you would propose?
We support the notion of an over-arching supervisory committee. An inter-agency or virtual network model could be used. This concept could draw on the expertise and good practice that resides within NHSQIS, NES, the Royal Colleges and elsewhere. Such a model could also benefit from the expertise of the NCAA. This would have the advantage of placing the knowledge gained from ECATs in an effective management structure, which is more transparent and accountable and would increase trust. Such a model would capitalise on the Scottish short lines of communication and the commitment of the broad Scottish healthcare community to manage poor performance as effectively as possible.
The management locus could reside within NHSQIS and in practical terms resources might be eased by looking at a level of secondment from e.g. NHSQIS and NES. The scale of resource application will be dependent upon the size of the problem (see answer to question 2). It could be envisaged that the virtual network could comprise a range of individuals with significant expertise from throughout the healthcare professions and could comfortably accommodate substantial lay input. We believe that it is important that there is meaningful patient involvement in any model, which is adopted.
The details of such a model would require to be looked at and the model should be kept under review. The auditing and quality assurance of whatever model is devised is very important. The Scottish Executive may wish to consider purchasing an external audit and quality assurance of this delivery model when it is up and running.