The GMC protocol for making revalidation recommendations

Recommendations to defer

5.1 What is a recommendation to defer?

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.

A recommendation to defer is not:

  • a way to raise concerns about a doctor’s fitness to practise with us
  • a way to request delaying your recommendation while a doctor is involved in a GMC fitness to practise investigation 

Criteria for a deferral

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 supporting information requirements
  • there are reasonable circumstances justifying 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.

Reasonable circumstances

Examples of reasonable circumstances that could account for a doctor needing more time to meet the requirements include but are not limited to:

  • parental leave
  • sickness absence
  • sabbatical or breaks in practice
  • a doctor is waiting for their supporting information to be transferred from their previous RO or suitable person.

When you are considering whether there are reasonable circumstances, you may wish to review our guidance for GMC decision makers which can be found on our website.  

Not all breaks in practice automatically require a deferral recommendation. You can make a recommendation to revalidate if the doctor engaged with clinical governance systems and provided supporting information to meet our requirements, while they were in practice.

5.2 Making a recommendation to defer

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. You can seek advice from your ELA at any point before you submit your recommendation.

You can only submit a recommendation to defer within 120 days of a doctor’s submission date. You can select a deferral period from 120 to 365 days.

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

You should also keep a record of any plans agreed and monitor progress against it during the period of the deferral. 

Where you are unable to agree an action plan 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
  • where you are recommending deferral due to insufficient evidence, select the most appropriate categories that describe your recommendation, where you are prompted to
  • specify the period of time for which you wish to defer the submission date.

We may ask you for further information about your recommendation before making our decision.

If we decide to defer the submission date, we will notify the doctor and tell them their new date. 

Deferral categories

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.

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.

5.3 Subsequent deferrals

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 exceptional circumstances and 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 any previous recommendations to defer the doctor in GMC Connect.