- I am changing jobs next year. Do I keep my original RO for this revalidation cycle?
Your responsible officer (RO) will normally be the one linked to the designated body where you are currently working. If you change organisations, your RO will also change.
Your new RO will, however, consider information relating to the whole five-year cycle, so will liaise with your former RO to ensure they have all the required information.
- I no longer see patients. Do I need to revalidate?
All doctors carrying out clinical duties must have a licence to practise and will need to revalidate to maintain it.
The GMC does not require doctors all doctors to hold a licence to practise. For example, if they are do purely medico-legal work (unless they are examining patients). However, some insurers and solicitors do ask that their experts to hold a licence to practise so you may wish to confirm with each instructing firm.
If you relinquish your licence to practise you should remember that you cannot carry out functions requiring a licence, for example, prescribing medications.
- What information do I need to collect?
You will be expected to prepare a portfolio of supporting information from every area of your practice including any work you do for organisations other than your designated body. The GMC has detailed guidance on the supporting information required.
Your evidence will fall into four main categories:
- General information - what you do in all aspects of your work
- Keeping up to date - maintaining and enhancing the quality of your professional work
- Review of your practice - evaluating the quality of your professional work
- Feedback on your practice - how others perceive the quality of your professional work
During your appraisal discussion, you will be asked to demonstrate, with reference to this supporting information, that you are up-to-date and fit to practise, that you have reflected on your practice, and identified any areas for improvement.
You may find it useful to review the GMC's appraisal framework which sets out 12 professional attributes against which a doctor's' practice should be considered during appraisals, grouped into the following four domains:
- Knowledge, skills and performance (how you're keeping up-to-date and applying that knowledge)
- Safety and quality (complying with systems to protect patients)
- Communication, partnership and teamwork (listening to patients, respecting their views and providing them with the information they need to make decisions about treatment; and treating colleagues fairly and with respect)
- Maintaining trust (showing respect for patients, being non-discriminatory and acting with honesty and integrity)
You are required to provide evidence of multi-source feedback for colleagues and patients (if applicable), and engagement with a quality improvement activity once in every five-year revalidation cycle.
Following your appraisal, you should have a new personal development plan setting out your objectives for the following year, such as further training. It will then be up to you to meet these objectives and update your portfolio accordingly before your next appraisal.
- I do work for more than one organisation – will I need a responsible officer for each role?
You will only have one responsible officer (RO), but you will be required to present supporting evidence covering every area of your practice. This means your supporting information must cover all your roles as a doctor, including locum work, private practice and NHS practice.
You're expected to tell your responsible officer and appraiser about all the places you have worked since your last appraisal. You are also expected to share the following information at any of the places you have worked:
- if you're involved in a significant event
- if a complaint is made about you
- if there is a concern about your fitness to practise
- if you are suspended or have restrictions placed on your practice (by an employer or the GMC). You must also tell any patients you see independently.
Your RO will consider information from the whole of your practice when making a recommendation to the GMC.
You can find out more about revalidation and working in multiple settings from the GMC website.
- I am a responsible officer. Will the MDU cover me?
It is possible that litigation could arise as a result of an appraisal and/or a decision on revalidation. For example, a claim could be brought by a patient who has been harmed by a doctor in circumstances where his/her appraisal was found to be satisfactory and responsible officer (RO) made a recommendation for revalidation which the GMC accepted.
The patient may allege the doctor was deficient and that deficiency, which should have been picked up, caused them harm. We do not expect that this would happen very often. If such a circumstance arose for an NHS patient, the claim would be brought against the NHS employing organisation and would fall under NHS indemnity.
It is also possible the appraiser or the RO could be sued by a doctor on the grounds they had not been recommended for revalidation and that it has harmed their employment prospects.
Each case is judged on a case-by-case basis. If you are a responsible officer or appraiser and an MDU member, you can contact the advice line for more information.
- I've had health problems and am behind with my CPD. How will this affect revalidation?
Provided you are engaging with the appraisal process, your responsible officer (RO) can ask the GMC for a deferral in a decision about your revalidation. The RO can request a deferral for up to 12 months which simply postpones your revalidation.
You should then work with your organisation to obtain any outstanding supporting information as soon as possible.
Appraisals have been affected by the COVID-19 pandemic as doctors may have become ill and unable to collect evidence of CPD or attend an appraisal meeting. The GMC does not require that a doctor literally has an appraisal every year if there's a legitimate reason for the appraisal being missed, such as the pandemic. The GMC postponed the revalidation dates for doctors due to revalidate between March 2020 and March 2021 for up to a year. While it acknowledges the disruption, it advises doctors to follow the advice of their responsible officers.
- My clinical performance is under investigation. Will this prevent me from revalidating?
If the matter is still being investigated by your employer when your revalidation is scheduled, it is likely your responsible officer (RO) will request that the date is deferred. For GPs, this will usually be a performance review by the organisation that manages the Performers List on which your name is included.
In its protocol for ROs, the GMC says that deferral requests can be made for doctors who "are participating in an ongoing local governance process, the outcome of which is material to your evaluation of the doctor's fitness to practice and your ability to make an informed recommendation." Your RO will be asked to specify the length of the deferral which can be up to a year.
Once the investigation is completed, you will still be able to revalidate provided the findings do not cast doubt on your fitness to practise. It will be important to demonstrate that you have reflected on what happened, any lessons you have learned, and be prepared to discuss this during your next appraisal.
If your clinical performance is under investigation by the GMC, then your revalidation will have been put on hold by the GMC pending the outcome of their investigation(s).