Responsibilities for sharing information

Responsibilities of doctors

All licensed doctors must inform their responsible officer of all the organisations or settings in which they provide medical services, including any locum or self-employed practice and any work for online providers. As a minimum, this must be done annually as part of the appraisal process. Keeping this information up to date is a matter of probity, essential to whole scope of practice appraisal and the sharing of information under these principles.

Doctors working in UK training programmes must declare all work undertaken outside training – including locum roles – on their Form R or electronic equivalent.

In line with Good medical practice, if a doctor is suspended from a medical post or has restrictions placed on their practice by any organisation, they must immediately inform the responsible officer or senior medical officer at every location in which they work and any patients they see independently.

Appraisal documentation is confidential. It is routinely accessed by the doctor, their appraiser(s) and their responsible officer or suitable person. In some circumstances doctors may have a contractual or other requirement to share appraisal information with employers or contracting bodies. Any such agreement is outside the requirements for revalidation. 

Responsibilities of responsible officers and approved suitable persons

Responsible officers must take appropriate action in response to any information of note they receive about the practice of a doctor who is connected to them, bearing in mind the needs of patients and of the doctor concerned. This includes information received from outside the doctor’s designated body.

Where a responsible officer becomes aware of information about a doctor that could affect the safety or confidence of patients, they should share that information with all places where the doctor is known to be working in a medical capacity.

If a responsible officer has concerns about a doctor who is no longer connected to them, they should share these with the doctor’s new responsible officer. In situations where the doctor’s new employment has yet to be confirmed, it may be appropriate to delay: responsible officers should have reference to the GMC’s ethical guidance on writing references and relevant local advice about pre-employment checks.

Where the doctor concerned no longer has a connection for the purposes of revalidation, the previous responsible officer should take appropriate steps to protect patients. They should remind the doctor of their responsibility to bring the matter to the attention of their next responsible officer and to practise only within their competence. Responsible officers should also retain information for transfer to the doctor’s future responsible officer. Information about previous connections can be viewed by the doctor’s current responsible officer or suitable person via GMC Connect.

In line with the GMC’s recommendation protocol, at the point of making a revalidation recommendation about a doctor, responsible officers should consider clinical governance information from each of the organisations where the doctor works. This may be obtained via the appraisal process or directly from the organisations concerned.

Responsibilities of organisations who use the services of licensed doctors (but do not act as their designated body for revalidation)

Any organisation using the services of a licensed doctor must inform that doctor’s responsible officer of any concerns that could impact on patient safety or public confidence as soon as they arise. In addition, it may be appropriate to directly contact other organisations where the doctor is known to be working, or liaise with doctor’s responsible officer about doing this. The priority line of communication must be with the doctor’s responsible officer because they have a statutory responsibility in relation to fitness to practise.

Organisations that use the services of locum doctors should provide appropriate feedback in the exit report to the locum agency.

All organisations or individuals who employ, contract with, or award practising privileges to licensed doctors should place those doctors under a continuing duty to immediately inform them if they become subject to investigation or have restrictions imposed on their practice.

Further guidance and sources of advice

These principles are designed to be high-level and universal in their application. More detailed guidance for on information sharing is provided by the national health departments, specifically:

• In England, Information flows to support medical governance and responsible officer statutory function.
• In Northern Ireland, Maintaining High Professional Standards in the Modern HPSS: A framework for the handling of concerns about doctors and dentists in the HPSS, 2005 (Applies to employed doctors only)

Further advice on when and how to apply these principles is available from the GMC’s employer liaison advisers.

 

^{* Good medical practice (paragraph 43) states ‘You must support colleagues who have problems with their performance or health. But you must put patient safety first at all times’.}