The DoH has published detailed plans for the new role of responsible officers (ROs) - the senior doctors who will act as the link between local health organisations and the GMC.
The plans start to flesh out the bare bones of revalidation.
'We are pleased they are making progress,' says Professor Mike Pringle, RCGP revalidation spokesman. 'ROs will be a major part of revalidation.'
ROs will be required to refer doctors to the GMC's fitness to practise processes and to oversee local arrangements for compliance with GMC conditions on practice.
The DoH has made its decisions on ROs after a three-month consultation on the new role. Guidance and regulations are now being drafted and will go out for consultation in the summer. The first RO appointments are expected in autumn 2010.
The DoH expects medical directors, suitably trained in a range of new competencies, to become ROs. There is no stipulation whether they work in primary or secondary care but they are expected to be licensed doctors.
ROs' required competencies include communications; mediation and arbitration; handling evidence; and understanding the principles of investigation.
Responding to evidence suggesting that ethnic minorities have been disproportionately represented with the GMC's fitness to practise procedures, the DoH specifies ROs must have equality and diversity skills.
Dr Sabyasachi Sarker, a Liverpool GP and chairman of the British International Doctors' Association, says: 'We have great anxiety about the treatment of ethnic minority doctors.
'Our worry is that 95 per cent of medical directors are from non-ethnic minority backgrounds and that trusts do not have the capacity to look at systems failures.'
Doctors working as employees, independent practitioners or locums will report to an RO within their own PCT.
The DoH is proposing a linkage hierarchy starting with the doctor's major employer or PCT; or if these are not applicable, a locum agency or professional federation relevant to the doctor's main clinical practice.
GPs outside mainstream practice will ultimately be charged with finding their own RO. Doctors not contracted to the organisation that provides their RO will have to pay their own costs.
'Allowing organisations to recover costs will enable all doctors to link to an RO but ensures that the organisation is not out of pocket for taking on this responsibility,' the DoH says.
Conflict of interest fears
Both the RCGP and the National Association of Sessional GPs (NASGP) had concerns about the conflict of interest under plans for locum agencies to appoint their own ROs, a model backed by respondents to the DoH consultation (see below).
Professor Mike Pringle says: 'We are not happy with locum agencies having their own ROs but we could see circumstances where it might be necessary.
'We can see a world in which other organisations such as pri-vate providers could take on that responsibility.'
He adds: 'If it's going to happen, they've got to be secure in their governance arrangements. They would struggle at the moment to have these in place.'
Dr Richard Fieldhouse, chairman of the NASGP, says: 'One locum could be registered with 10 different agencies and it could get very complex. But making the normal requirement through the performers' list with locum agencies allowed to appoint a RO sounds fair.'
Each organisation can have only one RO and they must hold an appointment at board level.
When a conflict of interest arises between a doctor and their RO, statutory guidance will stipulate what to do.
DoH Vision for ROs
- For most doctors, their main employer will provide their RO, and where there is no main employer, PCTs are the fall-back.
- Guidance will specify that doctors should know who their RO is, and ensure they are linked to one.
- Organisations will not be allowed to appoint more than one RO.
- ROs must be licensed doctors.