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Making recommendations: deferrals

There may be times that you’ll make a recommendation to defer a doctor’s revalidation date. This scenario looks at:

  •  the relationship between breaks in practice and recommendations to defer
  • your discretion in deciding whether to make a recommendation to defer
  • discussing issues with us in confidence, separately from making your recommendation.

Scenario: deferring a doctors revalidation date

Dr Bolton has returned from nine months of maternity leave. Her revalidation is due within three months and she has been issued notice by the GMC that a recommendation is due.

Before Dr Bolton’s return to work, you intended to make a recommendation to defer her submission date, but are not sure this is necessary.

At her return interview, she indicated she is ready to revalidate as she had collected all six types of supporting information before she left.

However, she has not practised in the preceding 12 months and has had only four appraisals in the last five years.

Dr Preston has been on sick leave for seven months. Her health concerns have been kept confidential from her colleagues. She has collected five types of supporting information, with one outstanding.

She needs two months to recover from an operation and you have agreed a return to work date.

She was issued notice two months ago, but the date by which the GMC expects to receive a recommendation is shortly before she gets back to work. She has missed one appraisal.

You are considering what decision to make about Dr Preston.

Key points: deferring a doctors revalidation date

Key issues are:

  • You should make recommendations about doctors on a case by case basis
  • the only basis for a recommendation to defer is that you agree with the criteria outlined in the recommendation statements, not the length of a break in practice
  • you can discuss revalidation with us in confidence before making a decision about what to do
  • deferral does not imply anything negative and the doctor will continue to hold a licence to practise
  • there is often no definitive answer as to whether recommendations to defer are appropriate, but you can make that judgement as you see fit.

In more detail: deferring a doctors revalidation date

You should assess separately whether each doctor has met the requirements for revalidation, and make your recommendation accordingly: you should not make your judgement in either case based on the other.

For Dr Bolton, maternity leave does not necessarily require deferral. She says she has all of her supporting information.

You should be able to verify this, and to check it is current and follows our supporting information guidance.

If Dr Bolton’s engagement in her four appraisals was active and positive, you don’t need to worry about the appraisal she missed – especially as she has engaged with the return to work process.

If you can confirm she has fulfilled all of the criteria in the recommendation statement, then you can make a recommendation to revalidate.

If you have any concerns that mean you cannot make the statements, you should handle them accordingly.

Dr Preston has not managed to collect and reflect upon all of her supporting information, so you would not be able to make her recommendation to revalidate statement.

A recommendation to defer may be suitable, but you should agree how long she needs to collect the outstanding supporting information – the deferral will not automatically be for the seven months she missed. Once she meets the missing requirements, she too can be recommended for revalidation.

If you are content with the management of Dr Preston’s health concerns, including respect for her confidentiality and her ability to work, you don’t need to tell us anything about her circumstances: we only need a recommendation to defer statement and the confirmation you’ve agreed a period to meet requirement.

You can discuss this or any other case confidentially with our employer liaison advisers. We will not act without receiving a recommendation from you.

You could also make sure your organisation’s return to work policy refers to revalidation so it is clear what is likely to happen.