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  6. Recommendations of non-engagement

Making a recommendation about a doctor’s revalidation

Recommendations of non-engagement

Making a recommendation of non-engagement

All licensed doctors must take reasonable steps to arrange a recommendation about their revalidation. If a doctor fails to engage with revalidation in line with our guidance, without reasonable excuse, we may withdraw their licence to practise.

If a doctor is not engaging with revalidation you must inform us, even if the doctor is not in their notice period. However, making a recommendation of non-engagement must only be used after all reasonable local processes have been exhausted in attempts to get the doctor to sufficiently engage.

Non-engagement in revalidation is where all of the following criteria have been met:

  • the doctor has been given sufficient opportunity and support to engage in appraisal or other activities designed to support a revalidation recommendation, but has failed to do so, or the level of engagement is insufficient to support a recommendation to revalidate
  • you do not have, and do not anticipate having, sufficient information on which to base a recommendation about the doctor’s revalidation
  • you have assured yourself that the doctor does not meet the criteria for a recommendation to defer their submission date and there are no reasonable grounds that account for the doctor’s failure to sufficiently engage with revalidation and meet all the requirements
  • all reasonable local processes have been exhausted in attempts to rectify the doctor’s failure to engage
  • where applicable, you have notified us of any unaddressed concerns about the fitness to practise of the doctor
  • where applicable, you have discussed any public interest concerns raised by the doctor with your employer liaison adviser
  • as a consequence of their non-engagement, you cannot envisage being able to make a recommendation by the doctor’s submission date.
  • A non-engagement recommendation must not be used as a way of raising concerns about a doctor's fitness to practise. You must refer fitness to practise concerns that meet our threshold through our existing processes, as soon as those concerns arise.

    Making a formal recommendation of non-engagement

    During a doctor’s notice period (usually four months before their submission date), we would normally expect you tell us about a doctor’s non-engagement by making a formal recommendation of non-engagement.

    A recommendation of non-engagement is you telling us that a doctor has not engaged in the systems and processes that support the revalidation process, or the level of engagement is insufficient to support a recommendation to revalidate.

    Before making your recommendation of non-engagement, you must consider whether the doctor could meet the requirements by their submission date.

    If so, you should contact us to discuss. It might not be appropriate to make the recommendation early in the doctor’s notice period. However, your recommendation of non-engagement must reach us by the doctor’s submission date.

    If you are considering a recommendation of non-engagement, you must discuss this with your ELA or our revalidation team. In addition to making a recommendation of non-engagement, you should consider whether you have other governance levers, including disciplinary processes, when managing concerns about a failure to engage.

    Informing us of non-engagement before notice is issued

    You must inform us if a doctor is not participating in the local processes that underpin revalidation outside the doctor’s four month notice period. We will write to the doctor to remind them that they must participate in these processes to maintain their licence to practise.

    If the doctor continues to fail to sufficiently engage with revalidation, and all local processes have been exhausted, you can ask us to bring forward their submission date and issue the doctor with notice. You can then make a formal recommendation of non-engagement.

    If the doctor begins to engage with revalidation before you make your recommendation of non-engagement, you must decide whether it’s now appropriate to make a recommendation to defer or a recommendation to revalidate, depending on the information available to you.

    Contact your ELA if you need advice about this process.

    How do we respond to recommendations of non-engagement

    A recommendation of non-engagement begins a regulatory process that can result in a doctor’s licence to practise being withdrawn.

    • We tell the doctor their licence is at risk for failing to meet the requirements of revalidation and that they have 28 days to tell us why we should not remove their licence. We may share any response from them with you and ask you for further information, before we make our decision.
    • In a small number of cases, where we become aware that a doctor has raised public interest concerns we may ask you to provide additional information as part of our standard procedure. We may ask you to demonstrate that the recommendation you made to us is fair, and that the public interest concerns raised by the doctor have not had a bearing on the recommendation that has been submitted. This is to safeguard against your role as a responsible officer, or our role as a regulator, being used inappropriately in response to a doctor raising concerns. For more information about public interest concerns, please see Appendix 1 of The GMC protocol for making revalidation recommendations: Guidance for responsible officers and suitable persons
    • If we subsequently decide to remove the doctor’s licence, we will give them notice and explain their right to appeal within 28 days of the notice. We’ll also tell you the date we will be removing the doctor’s licence, if they do not appeal. If the doctor does not appeal, we’ll email you again on the day we remove their licence.
    • If the doctor appeals, we will not remove their licence until the outcome of the appeal is known. Appeals are handled by an independent GMC team and can be lengthy. During this time, you must continue with any local processes.
    • The doctor remains connected to you during the appeals process unless the connection breaks for another reason. The doctor’s name will continue to appear in your list of ‘Submitted Recommendations’ on GMC Connect, and in your ‘All Doctors list’. While the doctor remains connected to you they must have access to appraisal systems and supporting information.
    • You may be asked to provide a witness statement or to attend a hearing as a witness.
    • If the doctor’s appeal is unsuccessful, we will remove their licence and let you know. If the appeal is successful, the doctor will keep their licence and get a new revalidation submission date. We will inform you both of the new date.
    • If you need further advice or information during this process you should contact your ELA.

    Recommendation: non-engagement statements

    Made pursuant to The Medical Profession (Responsible Officer) Regulations and The General Medical Council (Licence to Practise and Revalidation) Regulations

    I am the appointed or nominated responsible officer, or recognised suitable person, for the medical practitioner to whom this recommendation of non-engagement applies.

    I have read the criteria for non-engagement and I confirm that:

    • The medical practitioner has not engaged in appraisal or other activities required to support a recommendation to revalidate, or the level of engagement is insufficient to support a recommendation to revalidate.
    • I do not have and do not anticipate having sufficient information on which to base a recommendation about the medical practitioner’s fitness to practise. I have assured myself that the named medical practitioner does not meet the criteria for a deferral of a recommendation about their fitness to practise.
    • The medical practitioner has been provided with sufficient opportunity and support to engage with revalidation, but has failed to do so. Based on the information available to me, there are no extenuating circumstances which account for their failure to engage.
    • All reasonable local processes have been exhausted in attempts to rectify the medical practitioner’s failure to engage in revalidation.
    • Where applicable I have notified the GMC of any outstanding concerns about the fitness to practise of the named medical practitioner. I have notified the GMC in accordance with GMC guidance on raising concerns about doctors.
    • Where applicable, to the best of my knowledge I have discussed any public interest concerns raised by the doctor with my employer liaison adviser and can confirm that these have had no bearing on the recommendation being submitted.

    Consequently I cannot recommend that the named medical practitioner is fit to practise.