Revalidation

The meaning of the term Revalidation, as defined by an amendment to the Medical Act 1983, is ‘the evaluation of a medical practitioner’s fitness to practise’.

The process of revalidation that now faces GPs is the end result of a long process of debate and discussion within the profession and within society at large. The GMC historically faced criticism that it was more concerned with the welfare of the doctors than with the public and has undergone considerable reform over the last 10 years.

Whilst the concept of periodically checking if doctors are still fit to practice has been around for a long time, it was the Shipman enquiry and the challenges of its author, Dame Janet Smith that gave some urgency to putting a system in place, not least to assure the public and re-establish public confidence in the General Medical Council.

The process of revalidation is therefore one in which doctors need to positively affirm to the General Medical Council (GMC) that they are up to date and fit to practice based on the principles and values of Good Medical Practice. This is required every five years.

To administer the process of revalidation each doctor is associated with a “Responsible Officer” who makes recommendations to the GMC about their fitness to practice. For the vast majority of GPs the Responsible Officer is the Medical Director of NHS England for the area in which they practice. For our area these are:

  • Dr K Murphy (Medical Director and Responsible Officer at NHS England Lancashire and Cheshire & Merseyside)
  • Dr C Melrose (Medical Director and Responsible Officer at NHS England Cumbria & North East)

The key point for all doctors is to ensure they know who their responsible officer is.

The revalidation process started in 2012, with Responsible officers and clinical leaders in the first tranche. All doctors should by now have been allocated a “Revalidation Year” to ensure that all are revalidated within the 5 year cycle.

There are 5 things each GP should have in place before they go through the revalidation process.

  • 1. Ensure that you have a responsible officer – if not, inform the GMC.
  • 2. Ensure that your annual appraisals are properly conducted.
  • 3. Register with and use a revalidation e-portfolio or equivalent for your appraisals.
  • 4. If you haven’t done a patient or colleague feedback survey in the past three years, plan to do them.
  • 5. If you haven’t done a full cycle clinical audit in the past three years, plan to do one.

The responsible officer, at the time that a revalidation is due, will make a recommendation to the GMC. The RO can make one of three recommendations:

  • A positive recommendation where the doctor has participated in the systems and processes to support revalidation, collected the required support information and there are no outstanding concerns about the doctor’s fitness to practice.
  • Deferral Request where the RO is requesting more time to make a recommendation, either because there is incomplete information or on-going local processes because of concerns over a doctors performance.
  • Notification of non-engagement where the doctor has not engaged in the process and systems to support revalidation. This can potentially result in the removal of the doctor’s licence to practice.

It is important to note that the revalidation timetable is not an opportunity to first raise concerns about a doctor’s performance. These should be addressed on an on-going basis and not “saved up” for revalidation. In addition the RO has a responsibility to feed into the Appraisal Process any issues that have arisen locally that are considered to warrant some attention. In considering a recommendation about revalidation, an RO needs to be satisfied that these issues have been addressed in the appraisal process.

The Responsible Officer has a duty to consider other sources of information before making a recommendation to the GMC. These will include information generated by the clinical and corporate governance systems in which the doctor works. These may include, but are not limited to:

  • disciplinary or other human resources processes
  • processes that address a doctor’s non-engagement with revalidation
  • remediation programmes in which a doctor has participated.

There is a common misconception that the process of revalidation for a doctor requires them to take part in a separate process or involve meetings / interviews. This is not the case and the process by which the RO makes a recommendation for the GMC to consider is an “invisible” process to the doctor. The first the doctor will know is when a letter drops through the letterbox confirming that they have been revalidated.

There are a number of sources of guidance on revalidation, sometimes closely linked to the subject of appraisal. These are all available below or in the Advice and Guidance section of our web site which is searchable for the exact query that you have.