Making a recommendation about a doctor’s revalidation
The range of information you should consider
You must use all of the information available to make your recommendation.
- outputs from the doctor's annual appraisals, including their reflections on supporting information (if the doctor is in training the assessments and other curriculum requirements of their training programme)
- intelligence from other sources, such as clinical and corporate governance systems from all settings where the doctor works
- information about the doctor's compliance with any GMC conditions or undertakings that have applied to their registration during the current revalidation period
- information about the doctor's compliance with any locally agreed restrictions on their practice.
The information must, as far as possible, cover all aspects of the doctor's practice, in all settings and the entire time period under consideration.
You should be assured that a doctor is fit to practise and that there are no unaddressed concerns about them.
If you have insufficient or incomplete information on which to base a recommendation to revalidate, you must decide whether it is appropriate to recommend a deferral, or to recommend that the doctor has not sufficiently engaged in revalidation (see recommendations to defer and recommendations of non-engagement).
Considering the whole of a doctor’s practice
Doctors must identify their whole scope of practice and declare all places they have worked and all roles they have undertaken since their last appraisal. Their supporting information must cover all aspects of their work, for the entire period under consideration, including any work they’ve done in:
- clinical (including voluntary work) and non-clinical (including academic) roles
- NHS, independent sector and private work.
A doctor’s appraiser can offer them advice on how they can meet the supporting information requirements and signpost appropriate resources. However, it is you who makes the decision as to whether the doctor has met all the requirements.
You should not need to look at every piece of the doctors supporting information, but you must be sure that:
- your recommendation is consistent and fair
- the doctor has met all GMC criteria for your recommendation.
If a doctor’s supporting information does not reflect their whole practice, or meet the requirements in our supporting information guidance, you should consider whether it is appropriate to make a recommendation to defer (to allow them to collect any outstanding information), or a recommendation of non-engagement.
Information from overseas practice or practice that does not require a licence
Revalidation assures patients and the public that doctors remain up to date and fit to practise, in line with the standards of practice required in the UK.
We expect doctors to collect their supporting information from the practice that they undertake in the UK, unless there are exceptional circumstances. For example a doctor in the military who is stationed overseas.
Only in exceptional circumstances would a doctor with supporting information drawn wholly or substantively overseas from practice be able to maintain their UK licence to practise.
If a doctor is working overseas only sporadically, as well as undertaking UK practice, there is no reason why they can’t collect and reflect on some evidence from that practice as part of their appraisal.
You can use your judgement to decide whether or not to accept supporting information from practice that does not require a UK licence.
You may wish to consider:
- the relevance of the supporting information to the doctor’s licensed UK practice
- what proportion of the doctor’s supporting information it represents
- whether it is material to your evaluation of their fitness to practise.
If you decide the supporting information from overseas practice is not relevant, you should discuss with the doctor what alternative information they need to provide.
If a doctor is not undertaking any practice in the UK (or crown dependencies or Gibraltar) they do not need to hold or maintain a UK licence to practise. You should discuss with them whether they need to continue to hold their licence.
If you need further advice, you can discuss this with your ELA.
Outputs from appraisal
The timing of appraisals
For the purposes of revalidation doctors must participate in an annual appraisal based on Good medical practice. A doctor’s engagement in appraisal and the processes leading to it should be active and ongoing, and demonstrate that the doctor is meeting the criteria to revalidate.
A doctor does not need to have completed five appraisals to revalidate successfully. There may be legitimate reasons for a doctor to miss an appraisal including; breaks in practice, such as for parental leave, working or training overseas, ill-health, or caring responsibilities.
In addition, you may need to make a recommendation about a doctor less than five years since they last revalidated: for example, if the doctor’s submission date has been brought forward, or we have given them an earlier date.
Local appraisal requirements
Your organisation may set other appraisal requirements as part of a doctor’s employment – for example, completion of health and safety training. This is a matter for employers and should be dealt with via local processes, such as disciplinary processes. Completion of additional local appraisal requirements should not influence the revalidation recommendation that you make.
If, in exceptional circumstances, you consider that significant failure to meet local requirements will impact on the recommendation you make, you would need to be satisfied (and satisfy us) that failure to meet local requirements means the doctor is not engaging with revalidation and is therefore failing to meet our requirements. You would need to specify which GMC requirements have not been met.
Appraisal carried out by other organisations
If you make a recommendation based on appraisals carried out by other organisations, you must take reasonable steps to assure yourself that the appraisals are robust and provide you with the information you need.
If you have any concerns about a doctor’s appraisal, you should raise your concerns with the responsible officer of the organisation in question as soon as possible.
Appraisals can serve a number of purposes and may include local or organisational requirements. You only need to consider whether the doctor’s appraisal meets the requirements for revalidation when making your recommendation.
Information from clinical and corporate governance systems
You must consider information from clinical and corporate governance systems where your doctors work when making your recommendations.
Boards and governing bodies of healthcare providers are responsible for monitoring the effectiveness of organisational systems. The handbook Effective governance to support medical revalidation includes a checklist to support sound governance.
Revalidation is not a mechanism for resolving local employment or contractual disputes and does not replace mechanisms for dealing with such issues. However, when making your revalidation recommendation, you must consider whether the doctor is subject to an ongoing local process, such as:
- investigations into serious incidents
- disciplinary or other human resources processes
- processes that address a doctor’s non-engagement with revalidation
- remediation programmes in which a doctor is participating
- occupational health or return to work programmes.
In such cases you may need to wait for the outcome of that process to be known before you can make a recommendation to revalidate for the doctor. See recommendations to defer.
Information about the doctor’s compliance with GMC conditions or undertakings
Doctors practising with conditions or undertakings must participate in revalidation.
For doctors connected to you, you must make sure that systems are in place to monitor whether:
- they are complying with conditions or undertakings imposed by the GMC
- there are any fresh concerns about their fitness to practise.
Please contact your contact your ELA to discuss any new or ongoing fitness to practise concerns.
If a doctor is complying with conditions or undertakings and you agree with all relevant criteria you should make a recommendation to revalidate.
Information about the doctor’s compliance with locally agreed restrictions on their practice
Organisations may enforce locally agreed conditions or restrictions on a doctor’s practice. For example, where a concern about their practice is raised, or where reasonable adjustments need to be made on health grounds. Organisations may agree local conditions whether or not GMC conditions or undertakings are in place.
For the purpose of making revalidation recommendations, locally agreed conditions do not refer to other contractual or employment arrangements between an organisation and a doctor.
Doctors with locally agreed conditions or limitations must participate in revalidation.
If a doctor is complying with any locally agreed conditions and meeting the our other criteria, you should be able to make a recommendation to revalidate.
If a doctor is not complying with locally agreed conditions on their practice, you should:
- report the doctor’s failure to comply to the local organisation(s) in question
- consult the our recommendation criteria in this guidance to decide whether it is appropriate to make a recommendation to defer or a recommendation of non-engagement
- contact your ELA for advice about whether the doctor’s failure to comply with locally agreed conditions meets the .