The GMC protocol for making revalidation recommendations

Making a recommendation part 2

2.2 The range of information you should consider

You must use all the information available to make your recommendation. This includes:

A flowchart detailing the GMC revalidation recommendation process. Five sources of information converge into the 'Revalidation recommendation' central node: 'Outputs from appraisal/ARCP panel,' 'Information about compliance with GMC conditions or undertakings,' 'Information from clinical governance systems in all settings where the doctor works,', 'Information about compliance with any local conditions' and 'Supporting information.' The central node then leads to the 'GMC revalidation decision' at the bottom.

2.2.1 What to consider when using the information available to make a recommendation?

Supporting information

You should consider whether a doctor’s supporting information covers the whole scope of practice, for the entire period under consideration. 

You should not need to look at every piece of the supporting information. However, if you have insufficient or incomplete information on which to base a recommendation to  revalidate, you should consider whether it is appropriate to make a recommendation to defer or of non-engagement (see section 5 and section 6).

We generally expect doctor’s supporting information to be from practice in the UK1. You can use your judgement to decide whether to accept supporting information from practice that takes place outside of the UK. 

You should consider:

  • the relevance of the supporting information to the doctor’s UK practice
  • what proportion of the doctor’s supporting information it represents
  • whether it is relevant to your evaluation of their fitness to practise
  • whether you are satisfied that the supporting information meets the same standards as those expected in the UK.

If you decide the supporting information from overseas practice is not relevant, you should discuss what alternative information is needed with the doctor.

1 This also includes practice in the crown dependencies and Gibraltar.

Appraisals

A doctor’s engagement in appraisal and the processes leading to it should be active, 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. Such as, breaks in practice or where we have brought forward a doctor’s submission date. 

An appraisal should:

  • Have Good medical practice as its focus
  • Cover all of the doctor’s medical practice 
  • Should be with an appropriately appointed and trained appraiser 

Your organisation may set other appraisal requirements as part of a doctor’s employment – for example, completion of health and safety training. 

  • Completion of additional local appraisal requirements should not influence the revalidation recommendation that you make. This is a matter for employers and should be dealt with via local processes, such as disciplinary processes.
  • If, in exceptional circumstances, you consider that significant failure to meet local requirements will impact on your recommendation, you would need to be satisfied that this failure means the doctor is not engaging with revalidation and is failing to meet our requirements. You would need to specify which of our requirements have not been met.

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, meet the above appraisal requirements 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 RO of the organisation in question as soon as possible. 

Clinical and corporate governance systems

When making your revalidation recommendation, you must consider information from the clinical and corporate governance systems of all settings in which the doctor has provided services requiring a licence to practise. This includes considering whether the doctor is subject to an ongoing local process, such as:

  • investigations into incidents or concerns
  • 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.

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 section 5 for guidance on recommendations to defer.

You should keep records of how and when you were informed of the process and its outcome, and how you accounted for this when deciding which recommendation to make.

This handbook provides further information on how we define clinical governance, and what constitutes effective clinical governance for doctors, AAs and PAs.

Compliance with local restrictions

Doctors with locally agreed conditions or limitations must participate in revalidation. If a doctor is complying with any locally agreed conditions and meeting our other criteria, you should be able to make a recommendation to revalidate.

Where 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 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 threshold for a fitness to practice referral to us.

For the purpose of revalidation, locally agreed conditions do not refer to other contractual or employment arrangements. Revalidation is not a mechanism for resolving local employment or contractual disputes and does not replace mechanisms for dealing with such issues.

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 undertakings we’ve agreed or conditions we’ve put in place 
  • there are any new concerns about their fitness to practise.

Please 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 (see section 4).