Operations Department
Revalidation for
doctors in training
Health Education South London
Working also on behalf of Health
Education North Central and East
London and Health Education North
West London
Principles of Revalidation
The GMC’s approach to the implementation of revalidation:
• Confirms that a doctor with a licence to practise continue to be fit to
practise.
• Requires all doctors to engage with systems of periodic review.
• Is not a point in time assessment.
• Provides confirmation that a doctor with a licence to practise is working
within a governed system.
• Requires all doctors to have a prescribed connection to a designated
body, and one Responsible Officer.
• Should be implemented in a fair and proportionate way based on
consistent principles.
Doctors in Postgraduate Training hold a
Licences to Practise
…and will therefore need to revalidate
Revalidation recommendations will be made
5 yearly AND at CCT
The Postgraduate Dean is your Responsible Officer
Health Education North East and Central London
Tim Swanwick
Health Education North West London
Julia Whiteman
Health Education South London
Andrew Frankel
Trainee alignment by Designated Body
•
Trainees are aligned by LETB according to the geographical location of where
their programme is managed
•
For commissioned programmes this will be the location of their Lead Provider
e.g. all trainees part of a training programme managed by UCLP will be
connected to HE NCEL as their Designated Body and RO
•
Trainees will not otherwise change their Designated Body / RO connection for
the duration of their programme; this includes when on periods out of
programme, or acting up.
Principles of revalidation for trainees
In order to be ready to have a revalidation recommendation made about
them, doctors in training must simply:
– Participate in an ‘enhanced’ ARCP process
There are no additional evidential requirements for doctors in training
programmes over and above the requirements of their curriculum
Scheduling revalidation dates
The revalidation date for trainees (i.e. the point at which the GMC
expects to receive a revalidation recommendation) will be set at either:
– At CCT if the expected CCT date falls before 31st March 2018
(submission date is 60 days post CCT)
– Between 1st April 2016 and 31st March 2018 if the expected CCT
date is after 31st March 2018.
All trainees will have received communication from the GMC
confirming a revalidation date.
Responsible Officer Recommendations
The 2012 RO regulations require ROs ‘to make recommendations to the
General Council about medical practitioners’ fitness to practise’
ROs already make ‘recommendations’ about the fitness to practise of
doctors through referrals to the GMC’s Fitness to Practise processes –
this should continue as now
Revalidation adds the positive affirmation of doctors’ fitness to practise to
the current processes
Three categories of RO recommendations
1. Positive affirmation of suitability to continue to hold a licence
(occurs every 5 years and at CCT)
2. Notifications of non-engagement:
– Confirm that an RO cannot, or cannot envisage being able, to make an informed
recommendation when it falls due, as the doctor has not engaged in processes that
support revalidation
– Appropriate grounds for non – engagement would be trainees absent from the training
programme without approval, trainees repeatedly not engaging with the ARCP process
– Not a mechanism for addressing concerns about a doctor’s fitness to practise
3. Notification of non-engagement
Deferral Requests
3. Deferrals
– Can be requested if an RO is not ready to make a recommendation by the original due
date.
– Has no effect on the doctor’s licence to practise
– Appropriate grounds for deferral requests include trainees being on maternity leave,
long term sickness, out of programme, or involved in an ongoing local investigation or
disciplinary process
– HE South London will make deferral requests on behalf of the trainee and RO.
– Deferrals can be requested when a doctor is within 4 months of their Revalidation date.
– The maximum amount of time a revalidation date can be deferred is 12 months, this
may mean multiple deferral requests are required; for example if a trainee is out of
programme for research.
ARCP panels
What stays the same
1. ARCP panel processes for making decisions on trainee progression
and responding to fitness to practise issues will continue.
2. The information reviewed by an ARCP panel is confined to the
evidence presented
3. Information withheld by a trainee is considered a probity issue
4. Referral to fitness to practise procedures can occur at anytime,
according to circumstances, not just at ARCP.
The enhanced ARCP
What’s different
1. Now covers the full scope of practice for which a trainee holds a
licence to practise including:
– Locum work
– Voluntary work e.g. St John’s Ambulance, medical officer to rugby club
2. Complaints and compliments arising across full scope of practice
3. Involvement in and learning from investigated significant events
arising across full scope of practice
4. Notification to the GMC of non-engagement with ARCP can result
in administrative removal of the trainees’ licence to practise at
any point in the revalidation cycle
Information to support revalidation via ARCP
1. Enhanced Form R
–
–
–
–
–
Self declaration
Full scope of practice since last ARCP
Involvement in investigated significant events arising from scope of practice
All formal complaints and compliments arising across scope of practice
Declarations of health and probity (including amount of sick leave taken since last
ARCP)
2. Educational / Clinical Supervisor sign-off of absence of fitness to practise
concerns
3. Updated ARCP Outcome form
4. Six monthly employer ‘Collective Exit Reports’ and where required ‘Exception
Reports of Concerns’
5. Routine notification of SIs, complaints and concerns with no changes to
information requirements
Employer Reporting
– Nationally Employers are expected to return information regarding a trainee’s
fitness to practice twice annually.
– This cycle currently occurs every April and November.
– Every LEP in London is asked to return information via ‘the Employers Portal’ for
trainees in post within the previous six months.
– We also collect data from KSS and EOE where London trainees rotate out into
these posts.
– More than one LEP maybe asked to report on an individual trainee if they have
rotated during the reporting period.
– Relevant information collected via the Employers portal is confidentially shared with
the ARCP panel to aid in their decision making with regards to fitness to practice.
Employer Reporting
Exit Report
– Completed by LEPs HR and DME for every training confirming whether there have
been any concerns or issues raised within the last 6 months in regard to:
•
Involvement in a Formal Serious Incident / Significant Event Investigation
•
Involvement in a Conduct, Capability Investigation
•
Named in Complaint(s)
Exception Report
– Where trainee involvement in any of the above occurs, the LEP must submit an
exception report providing more information, including:
– Summary of the incident, investigation or complaint
– Has the incident been satisfactorily resolved or is still ongoing?
– An indication as to the level of involvement of the trainee
What do others need to do?
•
Educational Supervisors are now formally asked to declare whether there are any
concerns re your fitness to practice as part of the ESR Form.
•
LEPs will be asked to provide an Exit Report for you (this may be more than one if you
have rotated within the reporting period). There should be ‘no surprises’ - if a notification
regarding SI involvement is made by an LEP the expectation is that they will have
discussed this with you. This occurs twice annually in April and November.
•
ARCP Panels triangulate information collected from ES Reports, Trainee Self
Declaration and Employer Reporting to make Fitness to Practice recommendations.
•
ROs and Health Education South London will collect enhanced ARCP information
annually in preparation for your revalidation and will make a recommendation for
revalidation at your 5 year cycle and/or CCT date.
•
The GMC will contact all Doctors automatically once you are within your notice period
for revalidation and again once a revalidation recommendation has been made and
revalidation occurs.
What do you need to do?
1. For your next ARCP:
– Complete Enhanced Form R & Self Declaration to include full scope of practice
(including any locum activity), since your last ARCP
– This is mandatory for your ARCP, no formal Outcome can be issued without both parts
of your Form R.
– Failure to provide in time for the panel may result in your ARCP being rescheduled or in
extreme cases a non engagement notification to the GMC.
– Ensure ePortfolio and personal library is up to date with all complaints and compliments
information so this can be referred to in your Enhanced Form R, including any
reflections or learning that has taken place as a result.
What do you need to do?
2. For trainees reaching CCT
– Ensure that you are providing all required evidence well in advance of your CCT date
to ensure that a revalidation recommendation can be made on your behalf before
you reach CCT.
– Notify your RO if you believe your Revalidation Date is incorrect
– Do not change your Responsible Officer with the GMC until you have received
confirmation that your revalidation recommendation has been made.
– A revalidation recommendation will be made by your RO once you are within 4
months of your revalidation date and all necessary documentation has been received
and is in order.
QUESTIONS?
traineerevalidation@southlondon.hee.nhs.uk
traineerevalidation@ncel.hee.nhs.uk
traineerevalidation@nwl.hee.nhs.uk