The General Medical Council has announced that later this year it will ask all doctors for information about where they work in preparation for the rollout of the new system of revalidation for their licence to practise. Martin Hodgson looks at revalidation, the current status of its implementation and what GPs have to do to comply with the requirements.
At the end of 2012 it is expected that the first doctors will be told when they will revalidate and, over the next few years, every licensed doctor will be revalidated for the first time.
It is important that all doctors are aware of this timescale and are already collecting the necessary supporting information that they will require to successfully revalidate when the time comes. It is also important that they remember that the processes for revalidation are still being developed and they need to keep themselves updated with changes to the system and the revalidation arrangements as they are agreed.
What is revalidation?
In November 2009 all practising GPs in the UK received a license to practise from the General Medical Council (GMC), the body responsible for regulating the registration and work of doctors. This licence to practise includes a requirement for doctors to periodically “relicense” if they wish to continue to practise.
Revalidation is a the new system being introduced in the UK by which doctors will be able to achieve this relicencing. It will involve them demonstrating to the GMC that they are up to date, fit to practise medicine and are complying with all relevant professional standards, including the generic standards of practice outlined in the Good Medical Practice and elaborated on in Good Medical Practice for General Practitioners.
Further information about revalidation can be found in the Guide to the Revalidation of General Practitioners published by the Royal College of General Practitioners (RCGP).
All doctors holding registration with a licence to practise will have to participate in revalidation. Prior to the development of the revalidation model the RCGP staged a series of consultations on the processes and the information required for revalidation and sought feedback from a wide range of key stakeholder groups and organisations. The results of this feedback are contained in the Revalidation Criteria, Standards and Evidence Consultation Report, published in February 2009.
Why is revalidation being introduced?
The GMC states that the purpose of revalidation is to assure patients, employers and other healthcare professionals that licensed doctors are up to date and are practising to the appropriate professional standards.
The RCGP believes that revalidation will provide a focus for doctors' efforts to maintain and improve their practice, will facilitate the organisations in which doctors work to support them in keeping their practice up to date, and will encourage patients and the public to provide feedback about the medical care they receive from doctors. In these ways, it states, revalidation will contribute to the ongoing improvement in the quality of medical care delivered to patients throughout the UK.
It is also believed that revalidation will serve as a way of identifying GPs, as far as is practicable, for whom there are significant concerns about their fitness to practise and to detect early signs of deteriorating performance. The RCGP is working to ensure that GPs will be supported at every stage during the revalidation cycle, particularly if they are experiencing difficulties.
How will revalidation work?
Revalidation will be based on each doctor submitting “supporting information” to a senior, licensed doctor in the healthcare organisation where the doctor works. This person will be known as the Responsible Officer. The supporting information will be material that most doctors are familiar with — such as annual appraisals and audits — and the collection of the material will be reviewed annually at appraisal and submitted to the local Responsible Officer as a portfolio of supporting information.
For GPs, the Responsible Officer is likely to be in the primary care organisation on whose performers list they are included.
In this respect the Responsible Officer has a significant role in the revalidation process. It is they that will provide the GMC with assurance that any particular doctor is meeting the standards required of them and that there are no known concerns about their practice. The GMC, however, will have the final say on revalidation and it will be for it to agree or disagree with the recommendation of the Responsible Officer.
More detailed information on the RCGP proposals and plans about how revalidation will work in practice is available in the latest version of the RCGP Guide to Revalidation for General Practitioners.
The RCGP states that opportunities for revalidation must be equal for all GPs and that the process must be “proportionate and achievable” for all, regardless of their working pattern. The RCGP points to the fact that it has conducted a number of pilots to determine how revalidation will affect different groups of GPs, such as peripatetic locums, remote rural GPs and those who work in secure environments. The pilots have identified a range of alternative approaches and these have been adopted.
What supporting information will be required?
The key information all GPs will need to collect over a five-year cycle for revalidation includes:
annual personal development plans (PDPs)
250 learning credits demonstrating continuing professional development (CPD)
one “colleague survey” or multi-source feedback (MSF)
one patient survey
a record of all formal complaints
10 significant event analysis records
one audit — complete cycle.
The PDP is the plan that each doctor should complete and update at their annual appraisal detailing their areas for development and how they will be achieved. All doctors should record details of their PDP and appraisal and keep them. The RCGP recommends that doctors try to make sure the areas picked for development are manageable ones and will have an impact on patient care.
CPD is demonstrated by collecting credits from educational activities. Each credit relates to an hour spent on CPD and the 250 learning credits should be collected as 50 credits per year. Credits can be doubled if a doctor can demonstrate they have had an impact on patient care or education of others. This includes such activities as developing practice protocols and sharing information at practice meetings, for example.
The RCGP recommends that doctors keep a log of all of their learning (including practice-based work) which they can use to calculate credits for their appraisal. The credits collected should include a mixture of different types of CPD such as reading, e-learning, educational events, practice-based education and learning which involves recorded impact.
Tools for recording the colleague survey or MSF and the patient feedback survey and review are still to be agreed by the RCGP and GMC. In the meantime the RCGP recommends GPs to use surveys conducted in the practice and lists a number of tools that can be used.
Details can be found on the RCGP website.
A record of all formal complaints received by the practice should also be recorded along with details of actions taken.
The 10 significant event analysis records should be spread out over the five years and the audit should be an audit of care that the doctor concerned was personally involved in. The supporting information should include reflection on the audit outcomes and a re-audit to monitor changes and actions taken.
What is the latest timescale for revalidation?
The licence to practise issued to doctors does not have a set expiry date. However, it requires doctors to participate in revalidation once the new system is implemented. How soon each doctor will be called for revalidation will depend upon the way in which the GMC implements the rollout of the new system.
Originally the GMC considered deciding revalidation dates according to GMC reference numbers. However, this was determined to be infeasible and the GMC has now announced a phased approach to introducing revalidation depending upon local readiness. This will mean that revalidation will only start in an area where the local systems needed to support revalidation are shown to be ready and fit for purpose.
The health departments in England, Scotland, Wales and Northern Ireland have the responsibility for ensuring that local processes are ready to support revalidation and are leading on testing and piloting the various elements involved.
It is expected that the first areas will be ready to begin revalidation in late 2012 with the first recommendations for revalidation being made in 2013.
The GMC has stated that in Spring 2012 they will ask all doctors for information about where they work. This is because, for the purposes of revalidation, doctors will link to the GMC through one organisation and they need to know which organisation this is.
At the end of 2012 the first doctors will be told when they will revalidate, and over the next few years, it is expected that every licensed doctor will be revalidated for the first time.
What should GPs be doing now?
GPs should ensure that they have their annual appraisals and record their supporting information, including their PDPs. They should also record their significant event audits or clinical audits, as well as conducting patient and colleague surveys, and they should deal with any complaints properly, recording their reflections.
They should keep a log of their learning and record all their education, including the hours spent and impact, using the RCGP’s credit system. The RCGP wants to ensure that the quality of appraisal and revalidation is consistent for everyone, and has developed a range of guidance and tools to support both processes. Guidance includes:
Principles of GP Appraisal, which sets out a policy and principles to underpin the appraisal process for GPs
Personal Development Plan Guidance for Appraisers, which provides guidance to appraisers on how to advise their appraisees on PDP construction
Core Information for Quality Assurance of GP Appraisal, which sets out the consensus view from across the UK on the development of common quality assurance standards of appraisal.
A Revalidation ePortfolio has been developed by the RCGP, working closely with GPs, to ensure that it will support the needs of GPs, GP appraisers and primary care organisations as a comprehensive appraisal and revalidation toolkit. It is free of charge for RCGP members. The RCGP states that it should be considered a “transitional tool” as it will be developed in line with national requirements relating to appraisal and revalidation as they evolve over time.
The RCGP states that every doctor will receive ample notice from their Responsible Officer that their revalidation is due. However, they remind all doctors that it is important for them to remember that revalidation is a five-year process, not a fifth-year process. They must be collecting supporting information about their practice and participating in appraisal throughout the five years.
Where can I find more information?
The revalidation section of the RCGP website is updated regularly and it is recommended GPs check this site to stay up to date with developments. All GPs should read the RCGP Guide to the Revalidation of General Practitioners, which is now in its third edition, and will be regularly updated as arrangements evolve.
The GMC’s website is also a very useful source of information on revalidation.
Last reviewed 12 March 2012