GPs not backed for revalidation may face fitness-to-practise hearing

Responsible officers (ROs) who identify concerns about a GP's fitness to practise during revalidation should refer them straight to GMC fitness-to-practise procedures or consider other local measures, a GMC guidance document says.

GMC: advice for responsible officers
GMC: advice for responsible officers

GPs deemed to have failed fully to engage with revalidation also could be stripped of their licence to practise, according to a GMC guide for ROs, the local officers who will make recommendations to the GMC on doctors' fitness to be revalidated.

The RO protocol explains the three possible outcomes following a GP's assessment for revalidation. ROs can only make a revalidation recommendation once the GP receives notice from the GMC of their revalidation date.

Having assessed the information presented at the time of revalidation, the RO will make one of the following three recommendations:

- a positive recommendation that the doctor is up to date and fit to practise.

- a request to defer the date of your recommendation.

- a notification of the doctor’s non-engagement in revalidation.

If a GP has participated in annual appraisals and collected the required information for revalidation, including multi-source feedback, the RO can make a positive recommendation to the GMC.

Once this recommendation is made it is up to the GMC to make the final decision on whether a GP should be revalidated.

However, if there is not enough information available to the RO to make a revalidation recommendation - for example, if the GP has been on sick leave or maternity leave - the RO can apply for the revalidation date to be delayed.

In cases where a GP has not engaged in appraisal or other revalidation activities, and all reasonable local processes have been exhausted in attempts to rectify the doctor’s failure to engage, then an RO can notify the GMC.

According the GMC protocol: ‘A notification of non-engagement can potentially result in the GMC withdrawing a doctor’s licence to practise, through the existing processes for administrative removal.’

If the GMC decides to begin the process of administratively removing the doctor’s licence to practise, they are informed and given 28 days to make representations to the GMC if they wish to appeal.

If an RO has concerns about a GP’s fitness to practise during the revalidation process they cannot make a positive recommendation about a doctor’s revalidation.

However the protocol reminds ROs: ‘Your recommendations about doctors’ revalidation are not a route for raising concerns about their fitness to practise with the GMC. Concerns about doctor’s fitness to practise must be referred to the GMC, through our existing processes for dealing with concerns about doctors, as soon as those concerns arise.’

‘If, for example, you wish to request the deferral of your recommendation, this should not be because you have identified a concern about the doctor’s fitness to practise that should be referred to the GMC.’

Before making a revalidation recommendation, ROs must consider:

  • a doctor’s participation in annual appraisals, where the doctor is not in a training programme.
  • the supporting information collected by the doctor.
  •  the assessments and other curriculum requirements of a doctor’s training programme, wherethe doctor is in a training programme.
  • the systems of clinical and corporate governance that are in place within the doctor’s workplaces.
  • information from all organisations in which the doctor has undertaken medical practice.
  • the doctor’s compliance with GMC conditions or undertakings that have been placed on their registration during the current revalidation cycle.

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