Making recommendations: interruption to practice and considering local versus GMC requirements
This scenario looks at:
- Considering breaks in practice when making a recommendation
- Local versus GMC requirements
Scenario: interruption to practice
After her last revalidation Dr Matthews participated in three appraisals. She then had an interruption in her practice for 18 months, because of sickness absence followed by a sabbatical agreed with the NHS Trust that employs her. She did not undertake any medical practice during these 18 months.
Both Dr Matthews' appraiser and responsible officer (RO) were satisfied that at all three appraisals, she had collected sufficient supporting information from across her whole practice, and discussed and reflected on these. At her last appraisal before being absent from practice, Dr Matthews discussed and reflected on the outcomes of her recent patient feedback exercise.
Following a return to work process, Dr Matthews resumed her previous post on a permanent part time basis, with the agreement of her employer. She completed her next appraisal 11 months after returning to work, shortly before a recommendation about her revalidation was due.
Dr Matthews' appraiser was satisfied that in her last appraisal, she had again met the requirements of revalidation, as per our guidance on supporting information and appraisal. He noted, however, that she had not completed the same amount of CPD as her full time peers - although her evidence of CPD activity was satisfactory. He also informed Dr Matthews that in line with the trust's policies, she needed to complete refresher training on basic life support as soon as possible.
Dr Matthews' RO has reviewed the summary of her appraisals. To recommend her for revalidation, they would like her to complete further CPD and provide further evidence that she currently practises in line with all trust policies that apply to her as an employee. The RO has communicated this to Dr Matthews, explaining that this further evidence is necessary given her 18 month absence from practice and her return to less than full time hours.
Key points: interruption to practice
What should the RO consider when making a recommendation?
- Dr Matthews is 'revalidation ready' as she has met the requirements for revalidation. She should not be expected to exceed them.
- GMC requirements for CPD do not require doctors to undertake a minimum number of hours or credits. A doctor should undertake CPD that is across their whole scope of practice, linked to their PDP and is sufficient for them to demonstrate they are keeping up to date and fit to practise. CPD should not be combined with mandatory training.
- Local employment requirements should not be overlaid onto revalidation requirements. This applies both to doctors' supporting information and appraisal activity.
- There are other local mechanisms that ROs and SPs should use if they require doctors to participate in further appraisals for reasons that are not related to revalidation.
- An interruption to practice is not in and of itself an acceptable reason for a deferral recommendation. The appraiser and RO should consider whether Dr Matthews engaged with clinical governance systems including appraisal and provided supporting information to meet GMC requirements, while they were in practice. If that is the case and all of the requirements have been completed, then they can make a recommendation to revalidate.
In more detail: interruption to practice
A deferral recommendation should not be justified on the basis that:
- There has been a pause in Dr Matthews' practice. She subsequently completed a satisfactory appraisal, and provided the required supporting information from across her whole practice.
- They have interpreted the fact that Dr Matthews has not had 5 annual appraisals as 'missed GMC requirements for appraisal':
- Dr Matthews does not need to complete 5 appraisals to be recommended for revalidation.
- She has completed a recent appraisal and her appraiser was satisfied that she provided a complete set of supporting information, and discussed and reflected on it appropriately.
- The fact that Dr Matthews is due to complete refresher mandatory training for employment purposes is immaterial to the revalidation recommendation.
- Dr Matthews has collected insufficient CPD, because she has collected less evidence than her full time peers:
- The appraiser was content that she has collected appropriate and acceptable CPD.
- If Dr Matthews needs to collect additional CPD she should be made aware of what is outstanding and how and when she is expected to collect it. This could be added to her PDP for her next appraisal rather than delaying her revalidation. The appraiser should qualify their comments about the amount of CPD presented, or be clear that they intend to discuss this with the RO. In other words, she should not be surprised that her level of CPD is insufficient, when a recommendation is due about her revalidation, and she should understand what expectations she needs to fulfil.