Making a recommendation about a doctor’s revalidation

Recommendations to defer

What is a recommendation to defer

A recommendation to defer is a request for more time to make your revalidation recommendation. To make a deferral recommendation you must be satisfied that the following criteria apply:

  • the doctor is engaging, and will continue to engage with, the local processes that underpin revalidation
  • an informed recommendation is not possible on the basis of the information currently available to you, when compared to the requirements of the Guidance on supporting information for appraisal and revalidation
  • there is a legitimate reason why the doctor needs additional time to provide the outstanding information or outcome
  • you have identified the additional information or outcomes that you need in order to make an informed recommendation, and you have identified where and when this information will be obtained
  • you are confident that the recommended period of deferral will allow you to consider the outstanding information and make a revalidation recommendation for the doctor.

Recommendations to defer can be made when a doctor is engaged in the systems and processes that support revalidation but:

  • there is incomplete information on which to base a recommendation to revalidate
  • they are participating in an ongoing local governance process, the outcome of which is material to your evaluation of the doctor’s fitness to practise and your ability to make an informed recommendation.

Examples of reasonable circumstances that could account for a doctor having incomplete supporting information and needing more time to meet the requirements might include:

  • parental leave
  • sickness absence
  • sabbatical or breaks in practice
  • a doctor recently gained a connection to you, and is waiting for their supporting information to be transferred from their previous responsible officer.

This list is not exhaustive. You must exercise your judgement in determining whether a doctor has engaged in the processes that support revalidation, and whether it’s appropriate to recommend a deferral.

A recommendation to defer is not:

  • A way to raise concerns about a doctor’s fitness to practise with us: concerns must be raised through existing processes as soon as they arise.
  • A way to request delaying your recommendation while a doctor is subject to a GMC fitness to practise investigation (in these cases we will postpone a doctor’s revalidation pending the outcome of the investigation).

Making a recommendation to defer

You must exercise your judgement in determining whether a doctor has engaged in the local processes that support revalidation, and whether it is appropriate to make a recommendation to defer. You can seek advice from your ELA at any point before you submit your recommendation.

You must discuss the reasons for your deferral recommendation with the doctor and agree an action plan for how the doctor will meet the outstanding requirements by their new submission date.

Keep a record of any plans agreed with the doctor and monitor progress against it during the period of the deferral. Where you are unable to agree an action plan with the doctor because, for example, the doctor is absent from work, you should inform the doctor of the deferral recommendation and what they need to do by their next submission date.

To submit a recommendation to defer you must:

  • confirm that all criteria for a recommendation to defer apply
  • select the appropriate reason for your recommendation from the drop down menu in GMC Connect
  • specify the period of time for which you wish to defer the doctor’s submission date.

We may ask you for further information about your recommendation before making our decision. For example, if you have previously recommended a deferral of the doctor’s submission date.

If we make a decision to defer the doctor’s submission date, we will notify the doctor and tell them their new date. You will be able to see this date on GMC Connect.

Additional Categories of information about deferrals

From March 2019, you will be asked to provide some additional high-level information about deferral recommendations due to insufficient evidence. GMC Connect will prompt you to select the top category or categories that best describe your reason for recommending a deferral.

These categories (which will appear slightly abbreviated on GMC Connect) are:

  • Appraisal activity – missed GMC requirements
  • Colleague feedback – missed GMC requirements
  • Compliments and Complaints – missed GMC requirements
  • CPD – missed GMC requirements
  • Interruption to practice
  • Patient feedback – missed GMC requirements
  • QIA – missed GMC requirements
  • Significant events – missed GMC requirements

'Missed GMC requirements' means that a doctor has not collected, discussed or reflected on that specific category of information. Our requirements are set out in our guidance on supporting information for appraisal and revalidation.

You can choose more than one category where necessary, but you should take care to only select the factors that were most important in your decision making.

For more information see our supporting case studies which explain how you should consider the most appropriate category to select:

  • Making recommendations: Interruption to practice and considering local versus GMC requirements
  • Making recommendations: Appraisal activity and sufficient supporting information

Subsequent deferrals

We do not expect you to submit a further recommendation to defer for a doctor unless there are exceptional circumstances.

Where a doctor’s date has been deferred and they fail to provide the outstanding information in the timeframe you agreed, this is usually considered non-engagement. We only expect to receive another recommendation to defer if there were clear reasons why the doctor needed additional time.

You must agree with the doctor by when this outstanding information will be provided. If a date cannot be agreed it may be appropriate for the doctor to consider giving up their licence, or risk having it withdrawn for non-engagement.

If you think you might need to make a further recommendation to defer, you must discuss this with your ELA as soon as you become aware of it.

You can view previous recommendations to defer the doctor in GMC Connect.

Recommendation: defer 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 deferral recommendation applies.

I have read the criteria for a deferral and I am satisfied that:

  • the medical practitioner has engaged with the systems and processes that support revalidation
  • there are no unaddressed concerns about the fitness to practise of the medical practitioner to whom this deferral request applies.

Where there is insufficient evidence to support a recommendation about the medical practitioner’s fitness to practise:

  • I have identified the outstanding evidence required for me to make an informed decision about the medical practitioner’s fitness to practise
  • I anticipate being able to make an informed recommendation about the medical practitioner’s fitness to practise once the outstanding evidence has been collected.

Where the medical practitioner is participating in an ongoing process:

  • I will consider the outcome of this process when making a recommendation about their fitness to practise.
  • I anticipate being able to make an informed recommendation about the medical practitioner’s fitness to practise once the process is concluded.

Please enter your requested submission date in dd/mm/yyyy format.

Your date must fall within 12 months.

Please select the option which best describes the reason for your deferral request:

  • The doctor is subject to an ongoing process
  • Insufficient evidence for a recommendation to revalidate