Taking Revalidation Forward Working With Others To

DoctorsReviewing revalidation connections to designated bodies for doctorsDesignated bodies are organisations that employ or contract doctors. They range fromlarge NHS trusts, private hospitals and membership organisations, to smaller independenthealthcare providers and locum agencies. They must appoint an RO who has a duty toprovide support to their doctors for their appraisal and revalidation and makerecommendations about their continued fitness to practise. This link between a doctor anda designated body is called a prescribed connection and it is defined in the ResponsibleOfficer Regulations.The Department of Health and Social Care (DHSC) have reviewed these regulations toidentify potential changes that would make prescribed connections more meaningful andcover all doctors who need to maintain a licence and revalidate. The GMC and NHSEngland have made suggestions for changes using the knowledge and experience built upsince revalidation was introduced. DHSC have been given permission to amend theregulations, with a view to consulting on potential changes during 2019. The statutoryguidance that supports the regulations will also be revised once the changes have beenagreed. This will reference the role of the designated body and provide more detail aboutprescribed connections. Ownership of this guidance will also be discussed as part thiswork.The impact of revalidation on independent doctorsAs part of this programme of work, the Independent Doctors Federation (IDF) audited theimpact of revalidation on independent doctors. Over a 12 month period, the appraisals of500 doctors connected to the organisation were reviewed. These doctors are often selfemployed, work alone or in small groups, and undertake a wide variety of work. The finalreport has been published on the IDF website.“There are many learning points for myself and mycolleagues, and it has changed my perspective – Appraisee(in response to the percentage of significant events declared at appraisal)7

DoctorsFairness for doctors who raise public interest concerns (also known aswhistleblowing)We were already aware that some doctors felt that raising concerns locally had thepotential to impact on their revalidation. We wanted to address this by introducing greatersafeguards to make sure whistleblowers are treated fairly and that revalidationrecommendations are made appropriately. ROs have a duty to inform us about doctorswho are not engaging in appraisal and wider clinical governance locally. When thishappens, we now ask doctors to tell us if they have raised a public interest concern and ifthey feel it prevented them from meeting our requirements for revalidation. We also askROs to speak to their GMC employer liaison adviser before making non-engagementrecommendations or consecutive deferrals for doctors.Practical advice for doctors deciding if they need to hold a licence to practiseAs well as focusing on revalidation information, we’ve also provided more advice to guidedoctors on whether they need to hold a licence to practise and participate in revalidation.We reviewed enquiries and complaints we received on this issue over the last few years tobetter understand doctors’ concerns. We used this insight to create the licensing resourcehub. It includes advice on the most common enquiries we receive together with casestudies. We also have a discussion checklist for doctors and employing organisations tosupport their conversations about whether a doctor needs a licence for the work they do.Supporting doctors without a connection to a designated bodyThere are a small number of doctors who need a licence for the work they do, but don’thave a prescribed connection to an organisation that can support them with theirrevalidation. A ‘suitable person’ or SP is a licensed doctor we have approved to make arevalidation recommendation about some of those doctors who don’t have a prescribedconnection. As well as general improvements to our online connection tool, we’ve addedspecific advice and signposting for doctors to help them identify their SP so they can besupported with their revalidation.We have also updated our advice for doctors without a prescribed connection or SP. Ourguidance is now clearer on what they need to do to complete their annual return, and howto take the revalidation assessment if they need to. We contact these doctors at keystages during their revalidation cycle to understand their circumstances and offer tailoredadvice to address any concerns or queries they might have. Our staff have also receivedtraining so they can better support doctors to identify potential connections.In addition, we’ve reviewed our suitable person scheme to make sure it continues toprovide a high level of assurance. The review found that the process is robust, works well8

Doctorsand is helping doctors without a prescribed connection to engage in revalidation. We nowplan to improve the support we offer SPs and develop an approach to quality assure thescheme.Supporting doctors who work in multiple locations including locum doctorsWe worked with partner organisations across all four countries to create UK-wideprinciples for sharing information. These principles should reassure doctors that appraisaldocumentation is confidential and that they should not be expected to share theirappraisal portfolios on a routine basis. The principles also provide clarity about whatdoctors should tell their RO and what information an RO can share about them.Our jointly published guidance the reflective practitioner emphasises the importance ofanonymising reflective notes wherever possible. It also makes it clear that we do not ask adoctor to provide their reflective notes in order to investigate a concern about them. Wehope this will support doctors to include their reflections and learning as they movebetween different roles and locations.We gathered intelligence from our employer liaison service to identify the kinds of issuesdoctors who work in multiple locations face with revalidation. We used this information tocreate a checklist summarising the responsibilities of designated bodies in relation torevalidation. This checklist emphasises that local systems should be put in place to supportlocums and others who work in more than one location.NHS England have published guidance for locums and doctors in short-term placementsalong with accompanying guidance for supporting organisations engaging with locums anddoctors in short-term placements. Recognising that these doctors are a valuable part ofthe workforce, the guidance aims to highlight ways they can be supported to enhancetheir work experience and provide safe care.Supporting doctors in trainingHealth Education England has updated its annual process for reviewing doctors inpostgraduate training, known as the Annual Review of Competency Progression or ARCP.The information in the ARCP about revalidation has been clarified. The revalidationrequirements are now highlighted to raise awareness among doctors in training andframeworks have been put in place to improve consistency.We’ve improved the revalidation information on our website for doctors in training and wenow provide advice on how their revalidation date is determined, what to do if they’retaking a break from training and what happens when they complete their training. We’re9

Doctorsalso signposting better to other organisations that can support them, such as theConference of Postgraduate Medical Deans’ website.We now also have separate sections in our supporting information guidance and protocolfor making revalidation recommendations specifically for doctors in training. And ourinformation sharing principles explain what information doctors working in UK trainingprogrammes should share with their RO, which includes any locum roles.We hope that collectively these changes will support doctors throughout theirrevalidation cycle, help to minimise the burdens they feel and allow them tofocus on learning from their reflective practice.10

PatientsImprovements for patientsSir Keith identified that revalidation is a mechanism for demonstrating that all licenseddoctors are up to date and fit to practise. He challenged us to consider how it couldbecome more effective in providing that assurance to patients. He also asked us to look atways that we and healthcare organisations could increase public and patient awareness ofrevalidation, and make it easier for patients to provide feedback to doctors.We worked with patients, lay representatives and healthcare organisations from across theUK to help us understand how we can raise awareness and increase patient and layinvolvement in local governance systems that support revalidation.We wanted to Help patients to understand revalidation and how we check thatdoctors are giving good care.Increase lay and patient involvement in providing assurance onthe revalidation processes in place at the organisations wheredoctors work.Review our requirements for how doctors get feedback from theirpatients to increase the impact it has on their practice.Helping patients to understand revalidationWe worked with patients and the public to create an explanation about revalidation called,‘how do we check doctors are giving good care?’ With the help of focus groups, we madethe explanation easy to understand and included the information patients told us theywanted to know. Before publishing it, we asked a patient participation group, provided bythe National Association for Patient Participation, for feedback on the content andlanguage to make sure we had it right. Ninety eight percent of the group said that theyunderstood what revalidation was after reading the explanation. Our explanation can beused by any healthcare organisation to explain revalidation in their own materials forpatients and the public. We have promoted it through our newsletter for patients andsocial media channels. We will continue to identify opportunities to use the newexplanation to help more patients understand revalidation.“The explanation is clear, easily understandable and userfriendly – Volunteer11

PatientsIncreasing lay and patient involvement in revalidationThe Academy of Medical Royal Colleges commissioned the Royal College of Physicians toreport on the current challenges relating to the collection, analysis and use of patientfeedback for revalidation. The report, improving patient feedback for doctors, waspublished on 13 April 2018, and has a number of key recommendations and options forimprovement. The Academy Revalidation and Professional Development Committee(ARPDC) are now considering how to take forward the next stage of this work.The AOMRC also published a report in December 2017 on lay involvement in revalidationactivities. The report shares examples of patient and public involvement in revalidationand the important contribution this makes. A survey is now underway to identify newexamples and seek views on both the benefits and challenges to lay involvement.We developed extra case studies to give doctors advice on how to collect feedback frompatients where it might be more challenging to do so. For example, from patients who aretoo young or too unwell to respond. The case studies show how doctors could collectfeedback in ways that reduce stress for the patient. They should also help to addresssome of the barriers patients may face when asked to give feedback about their doctor.We have also published case studies that show how some organisations have involved laypeople in their local clinical governance processes. And following feedback from the layrepresentatives on the Revalidation Oversight Group, we have a page on our websitededicated to involving patients in revalidation. We hope these encourage otherorganisations to think about how they can involve lay people in their local appraisal andgovernance processes.We recognise the important role that patients and the public can play in revalidation –helping to increase local accountability and patient confidence. We have developed a bestpractice measure to track whether designated bodies have lay representatives involved intheir governance processes that underpin revalidation. System leads across the UK canuse this to understand where lay representatives are influencing governance processes indesignated bodies. ROs can use this measure to help them introduce lay involvement intheir designated bodies.Reviewing our patient feedback requirements for revalidationWe have started to review our requirements for patient feedback for revalidation. So far,we’ve engaged with key stakeholders to help us understand how we could make it easierfor patients to provide feedback about their doctors, and make that feedback moremeaningful for doctors. We’ve heard that more flexibility in how feedback is collectedwould be welcome so all patients can respond, and that more frequent reflection onfeedback from patients would be useful for doctors. We’ll be consulting on ourrequirements in spring 2019.12

Responsible officers, suitable persons and healthcare providersImprovements for responsible officers, suitablepersons and healthcare providersROs and SPs play a key role in managing the systems that support revalidation. Makingsure they have the best possible guidance and support is essential to making sure localgovernance processes are working effectively, and revalidation recommendations aremade fairly and consistently.Sir Keith recognised the need to engage boards more in how governance processes thatsupport revalidation are working in their organisations. He felt setting expectations forboards and providing them with tools to help drive improvements could help do this.We wanted to Improve governance and oversight.Ensure fairness for doctors who raise public interest concerns.Improve guidance for ROs and SPs to make it more comprehensiveand easier to find.Encourage patient and lay involvement in revalidation processes bypromoting ways to embed lay representatives in designated bodiesand explain revalidation to patients. Improving governance and oversightOur handbook on effective clinical governance for the medical profession provides ahelpful guide for developing robust and effective clinical governance systems in designatedbodies and other healthcare organisations. We worked with stakeholders to review andupdate the handbook to capture learning and best practice from healthcare organisations.We have expanded the handbook so it covers the whole RO role. This includes appraisal,responding to concerns and pre-employment checks. Following RO feedback, we have alsodeveloped a self-assessment tool to help organisations review their governancearrangements.We are working with other signatories of the handbook to increase its impact. We havesent the handbook to all NHS chairs and chief executives. We are working with thehealthcare system regulators and improvement agencies to promote the handbook acrossthe four countries of the UK. We continue to engage with ROs through a number ofnetworks to support its use in their designated bodies.13

Responsible officers, suitable persons and healthcare providers“The document is well laid out and an easy 'high-level' read.I think it will be helpful to organisations as a guide and inplaces as a check-list against which to ensure engagementand standards – Educational bodyThe new information sharing principles should also help support the development ofconsistent practice across the UK healthcare system. This straightforward guidance shouldhelp ROs make decisions about whether to share information and when and give themconfidence in doing so. The principles highlight the importance of sharing informationwhere there is a patient safety concern and to maintain public confidence. They alsoaddress the issue of balancing the interests of doctors and patients to make sureinformation is shared legitimately and confidentially. Importantly, they provide support forROs to make sure that appraisal and revalidation takes account of information covering adoctor’s whole scope of practice. If ROs need further advice on applying these principlesthey can contact their GMC employer liaison adviser.“The guidance is easy to read and understand. ROs will beclear about how to apply this as a minimum expectation inorder to safeguard patient safety and public confidence –ConsultantIn spring 2018, NHS England circulated their Skipton house expert group statement onlocum and short terms doctors in secondary care. This statement was created by anexpert group on the use of locum doctors across the healthcare system. It includes astatement of principles, responsibilities and potential enablers to improve governance andpatient safety in this area.Our employer liaison service helped us to identify the kinds of issues designated bodiesand doctors face with revalidation where doctors work in multiple locations or frequentlychange their designated body. We’ve created a simple checklist for ROs and a checklist fordesignated bodies summarising their main responsibilities.14

Responsible officers, suitable persons and healthcare providersWe worked with partners to establish a framework and accompanying ‘best practice’measures to make sure we can continue to understand how revalidation is working inpractise and whether it is achieving its aim. The framework sets out ways of trackingwhether revalidation activities are happening and what the impacts are. ROs can usethese measures to understand whether aspects of revalidation are working as expected intheir designated bodies. In the long term, we hope this will help us understand where wecan improve revalidation.The Wales Revalidation Support Unit has started a programme of revalidation qualityreview visits on behalf of the Chief Medical Officer to understand how well revalidationprocesses are working. Each designated body in Wales will be visited over a two yearperiod with an emphasis on supporting development, promoting consistency and sharingbest practice.Assuring decision making for doctors who have

In 2016, we commissioned Sir Keith Pearson to undertake an independent review of revalidation. The report that followed, Taking revalidation forward, provided valuable insight into how appraisal and revalidation were working in practice. Sir Keith made a number of