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FAQs on GMC revalidation

Q: What is revalidation?

Revalidation is the process by which doctors will have to demonstrate to the General Medical Council (GMC), normally every five years, that they are up to date and fit to practise.

Revalidation is a new way of regulating the medical profession that will provide a focus for doctors' efforts to maintain and improve their practice, facilitate the organisations in which doctors work to support them in keeping their practice up to date, and encourage patients and the public to provide feedback about the medical care they receive from doctors.  In these ways, revalidation will contribute to the on-going improvement in the quality of medical care delivered to patients throughout the UK.

Q: What is the purpose of revalidation?

The purpose of revalidation is to assure patients and the public, employers and other healthcare professionals that licensed doctors are up to date and fit to practise.

Q: When will revalidation begin?

Revalidation will begin on 3 December 2012. From this date the GMC will accept recommendations about a doctor’s fitness to practice.

Q: How will revalidation work? 

Doctors must revalidate in order to maintain their licence to practise in the UK. The GMC is responsible for revalidating doctors and will require assurance that a doctor is up to date and fit to practise.
 
For non-training grades, revalidation will be based on a local evaluation of your practice through appraisal. You will be expected to participate in annual appraisal in the workplace over a five-year revalidation cycle and will need to collate a portfolio of required supporting information to bring to your appraisal as a basis for discussion. The supporting information will demonstrate that you are keeping up to date and have met the requirements for Good Medical Practice.
 
The GMC has set out its generic requirements for medical practice and appraisal in three main documents. These are supported by guidance from FPH which gives the specialty context for the supporting information required for appraisal. You should therefore ensure that you are familiar with the following documents:

  • Good Medical Practice
  • Good Medical Practice Framework for appraisal and revalidation
  • Supporting information for appraisal and revalidation
  • The revalidation pages of the FPH website.

You should also have regard to any guidance that your employing or contracting organisation may provide concerning local policies. Please see the Medical Appraisal Guide available from the NHS Revalidation Support Team (England).
 
A doctor will be recommended for revalidation to the GMC by their Responsible Officer (RO), normally every five years, based on:

  • information provided from the five annual appraisals
  • a completed portfolio of supporting information
  • an absence of concerns about their practice raised through local clinical governance routes.

An RO will be able to make one of three statements to the GMC:
1. That the doctor is up to date, fit to practise and should be revalidated
2. That the recommendation should be deferred while more information is obtained - for example where a doctor has taken a career break
3. That the doctor has failed to engage with any of the local systems or processes (such as appraisal) that support revalidation.
 
In the last case the doctor will be referred to a fitness to practise (FtP) panel of the GMC for consideration as to whether the licence to practise should be revoked. It is only the GMC that can give or remove the licence to practise.
 
Please note that if there are concerns arising about the doctor’s fitness to practice at any time preceding the revalidation date, those concerns should be raised with the GMC formally or informally – this should take place at the time concerns arise and not be left until the revalidation date.
 
Revalidation is not about ‘pass or fail’; it is a supportive and developmental process designed to provide assurance about a doctor’s fitness to practice and will enable doctors to identify areas for improvement at an early stage within a structured approach to personal development. These areas should be addressed at appraisal through the Personal Development Plan each year.

Q: How can I meet the requirements in my first revalidation cycle?

You must be participating in an annual appraisal process which has Good Medical Practice as its focus and which covers all of your medical practice.  You must have completed at least one appraisal, with Good Medical Practice as its focus, which has been signed off by you and your appraiser.
 
You must have demonstrated, through appraisal, that you have collected and reflected on the following information as outlined in the GMC’s guidance Supporting information for appraisal and revalidation:

  • Continuing professional development
  • Quality improvement activity
  • Significant events
  • Feedback from colleagues
  • Feedback from patients
  • Review of complaints and compliments.

Please also read the guidance provided by the GMC.

Q: How do I get an appraisal? 

Once you have confirmed your prescribed connection with a designated body, your Responsible Officer (RO) should advise you on how to access an appraisal and should ensure that adequate systems are in place in your organisation.
 
It is unlikely that you will have free rein to choose your appraiser. ROs are obliged to ensure that there are sufficient numbers of trained appraisers in place in their organisations, and that those appraisers have completed the training prescribed by the NHS Revalidation Support Team. To satisfy themselves that you have an appraisal of the required standard for revalidation, your RO will ensure you are allocated an appraiser who has been through the necessary training. This fits with their obligations and responsibilities to quality-assure appraisal within their organisation. You should speak to your RO if you wish to enquire whether you can keep an existing appraiser. It is recommended that doctors have two different appraisers during the five-year cycle. 

If your designated body does not offer appraisal, there are external organisations who offer appraisal services. It is the responsibility of each doctor to arrange their appraisal. Independent organisations may not conduct appraisals.

The Independent Doctors Federation has appointed an RO for doctors without a prescribed connection to an NHS RO. The Federation of Independent Practitioner Organisations also offers an appraisal service.

Q: Should appraisers be of the same specialty as the person being appraised?

In general, it would be advisable for an appraiser to be of the same specialty (for example at the level of physician/surgeon/ophthalmologist, but not sub-specialty) if at all possible. However, this is not mandatory and will largely be dependent upon the decisions of the employer and the availability of trained appraisers within that specialty. Please speak to your Responsible Officer; all appraisers will need to have received the appropriate training.
 
Any appraiser should ensure that they have sufficient information about you, your specialty and specialty standards to complete the appraisal. Specialty information and advice is available to appraisers and appraisees, including the specialty-specific guidance.

Q: What forms do I have to fill in for appraisal?

It is very important that the inputs and outputs of your appraisal are accurately and effectively recorded over the revalidation cycle. In the first instance, you should speak to your appraiser or RO about your organisation’s forms or procedures for recording your supporting information and/or the appraisal discussion. Some trusts may decide to purchase an electronic integrated appraisal and revalidation system and these systems will include appraisal forms. The RO is responsible for providing an effective appraisal system – please confirm with him or her as to what is expect of you. The Revalidation Support Team also has forms available on its website, and there will be different support in the devolved nations. It is important to establish what systems your RO will expect you to use.

Q: What should I be doing now to prepare for revalidation?

Doctors should set up a GMC online account to check their details are up-to-date, and the details for their designated body are accurate. Doctors should now be having appraisals and starting to collect the relevant supporting information in line with guidance. This information should be kept on file ‒ whether this is electronically or on paper ‒ in the interim. It is recommended by the GMC that information is managed electronically for revalidation.

Q: When will I be revalidated?

The GMC will write to all doctors starting in December 2012 to confirm the date on which it expects to receive a recommendation about their fitness to practise. The GMC is aiming to tell every licensed doctor his or her first date by spring 2013 at the latest. The GMC will give a minimum of three months' notice of when a revalidation recommendation should be submitted but will let doctors know earlier if it can.

The current timeline is:

  • Year 0: 2012/13. All responsible officers (ROs) and some medical leaders to be revalidated
  • Year 1: 2013/14. 20% of licensed doctors at each designated body revalidated
  • Year 2: 2014/15. 60% of licensed doctors at each designated body revalidated
  • Year 3: 2015/16. 100% of licensed doctors at each designated body revalidated
  • Years 4 and 5. All remaining licensed doctors revalidated by the end of March 2018.
Q: Do I need to take up a GMC licence to practise?

If you are medically qualified, you will have received communication from the GMC explaining that you need to make a choice between simply staying on the register and taking up a licence to practise.

It is essential that all practising public health doctors take up a licence to practise. This is because the licence will cover your professional practice which is not limited to clinical activity. Without a licence to practise, public health doctors will not be able to take up a consultant post in the UK, advise local authorities on health-related matters, conduct or oversee clinical trials, act as a medical member on the HPA board or at NHS tribunals, sign cremation certificates or inspect premises for community care. These are only a few examples, with a full list of 400 activities available defined by statute.

Taking up your licence can be done simply and quickly online and FPH advises all of its practising members to do this at the earliest opportunity. Once revalidation begins you will need to be licensed to be revalidated.

Q: How will GMC revalidation work? 

Revalidation will be based on a local evaluation of doctors' performance through appraisal. Doctors will be expected to participate in annual appraisal in the workplace and will need to maintain a folder or portfolio of supporting information to bring to their appraisals as a basis for discussion.

There will be some types of supporting information that all doctors will be expected to provide at appraisal over a revalidation cycle.  However, doctors can take any other additional information to demonstrate their practice at appraisal.

Information from the appraisal will be provided to a Responsible Officer who will make a recommendation to the GMC, normally every five years, on whether to revalidate a doctor.  In order to revalidate a doctor, the GMC will require assurance that a doctor is fit to practise.

Q: Who is my Responsible Officer?

The GMC has developed a tool to aid doctors in identifying their Responsible Officer.

Q: What has happened to recertification?

When the Government published its proposals for revalidation in 2007, it divided revalidation into two elements - relicensing and recertification. We have now moved to a single system of revalidation, which incorporates both of these elements into a simpler, more effective and more efficient process than the two separate strands originally proposed.

Q: Who will need to revalidate?

All doctors registered with the GMC with a licence to practise will be legally required to revalidate.

Specialists registered with the UKPHR will be required to revalidate in order to remain on the specialist register. Please refer to the UKPHR page for further details.

Those on the General Dental Council (GDC) register are very strongly encouraged to maintain similar portfolios of evidence, even if they are not FPH members. The GDC intends to introduce revalidation in due course. Please refer to the GDC website for further details.

Q: When will I need to revalidate?

Revalidation to the GMC is expected to commence in late 2012. This means the first cycle of revalidation will begin with all doctors holding a licence expected to revalidate by 2016.

 

Doctors who feel they have sufficient evidence can choose to put themselves forward for revalidation prior to 2016.

Q: How often must I revalidate?

For most doctors, revalidation will be a five-year cycle. Every five years the GMC will require confirmation from a doctor's Responsible Officer that they are up to date and fit to practise and that there are no significant unresolved concerns about their practice.

The GMC may vary the frequency of this cycle where the circumstances of the individual doctor require it. One example is where a doctor has taken a career break and their revalidation may be postponed for a period of time to allow them time to gather sufficient supporting information for the appraisal and revalidation.

Whilst a revalidation recommendation occurs once every five years, appraisal is an annual requirement.

Q: When will I need to start collecting supporting information for revalidation?

As soon as possible. You will already have much of the information needed, such as CPD information, annual appraisal information, MSF information, etc.

For more information about what doctors will be expected to bring to their appraisal, please contact your HR department or see our guidance on supporting information for appraisal and revalidation. The GMC has set out minimum requirements for revalidation.

Q: What will happen if I do not engage in appraisal and revalidation?

We expect that the majority of doctors will have no problem meeting the requirements for revalidation if they engage with the appraisal and local clinical governance processes.

If you choose not to engage, by not providing evidence to support your revalidation or failing to participate in an annual appraisal process, you cannot be revalidated and you risk having your licence to practise withdrawn.

Q: If serious concerns are raised about a doctor's practice what will be the consequences for their revalidation?

If concerns are identified about a doctor's practice that are sufficiently serious to raise questions about whether they should have a licence to practise and the Responsible Officer (RO) is therefore unable to recommend them for revalidation, the doctor will be referred to their regulator's Fitness to Practise processes.

 

Where concerns about a doctor's practice exist, these should be identified early and, where possible, addressed through relevant local clinical governance processes including appraisal. The identification of, and action on, concerns should not wait until a doctor is due to be revalidated but be dealt with through usual day-to-day systems or at appraisal. The RO might also want to immediately engage with the National Clinical Assessment Service or refer the doctor to the GMC if the concerns raised are sufficiently serious.

 

Where a doctor is referred to the regulator’s Fitness to Practise department for investigation, their revalidation will be deferred until the outcome of that investigation is known.


Q: What happens if I don’t work in the NHS?

Revalidation is based on maintaining your licence to practice, not your employing organisation. Regardless of employer, if you wish to retain your licence to practise, you will still be required to revalidate. Please refer to the prescribed connections flow chart to find your designated body for GMC revalidation.

Q: I work for a Primary Care Trust (PCT). Is FPH my designated body?

No. The PCT is your prescribed connection. PCTs are legal entities until 31 March 2013 and have a legal obligation to carry out revalidation and appraisals for all doctors under their remit until this date. If you have trouble securing an appraisal from your PCT, please inform your HR department or RO.

Q: I will move to a local authority soon. Who will I revalidate through?

We are expecting the Department of Health (DH) to publish its response to the consultation proposal that local authorities and Public Health England become designated bodies.

Q: I do not have a connection to a designated body. What should I do?

The GMC is aware that some doctors do not currently have a connection to any organisation classed as a designated body and they plan to contact these doctors by the end of 2012.

If you are in this situation, you should make the GMC aware of your circumstances by updating your details using your GMC online account and stating that you do not have a designated body.

Q: What multi-source feedback (MSF) should I use?

The MSF for you to use is decided by your RO. There is no specialty-specific questionnaire for colleague or patient feedback. If you do not treat patients, you do not need to gather this type of feedback. However, the GMC recommends that you consider other relevant sources of information such as students and clients.

Q: What if I am not in active public health practice, but maintain professional registration?

Discussions are on-going around the professional needs of those members who are not in active public health practice. The needs will be different for fully retired members from those who are taking a sabbatical or career break or who are on long-term sick leave or maternity/paternity leave. However, if you wish to maintain your licence to practise, the requirements are the same as for any other doctor.

Q: Does revalidation affect my specialist registration or GMC registration?

No. Revalidation is required to maintain a licence to practise in the UK only.  It is not required to maintain GMC registration or specialist registration.

There is an option for doctors in some situations (eg. working abroad) to relinquish their licence to practise (and therefore not revalidate), but remain registered with the GMC and maintain their entry on the specialist register. This provides confirmation that their qualifications have been recognised and that they are in good standing with the GMC.  Licences can be reinstated if circumstances change.

The specialist register is a historical document recording the specialties in which you have trained.  If you no longer work in the specialty for which you were originally listed on the register you will not lose your registration if your revalidation is based on supporting information from practice in another field.  Revalidation is not about demonstrating that you are up to date in that registered specialty (in which you trained), but that you are up to date and fit to practise in your current fields and across your scope of work.

As a specialist, you will need to continue to meet the existing requirements, and this will be evident through the detail of the supporting information that you provide at appraisal.

Q: What if I work overseas?

We have confirmed with the GMC that doctors who are based exclusively overseas do not need a licence to practise in the UK. The licence to practise gives doctors legal rights and privileges in the UK that do not apply in any overseas country. Doctors who are based overseas must abide by whatever regulatory requirements exist in the country in which they practise.

Non-UK organisations should therefore not require their doctors to hold a UK licence to practise. You can remain registered with the GMC and maintain your entry on the specialist register without a licence. This provides confirmation that your qualifications have been recognised and that you are considered in good standing with the UK regulator. You can relinquish your licence to practise whilst working abroad and reinstate it on return to the UK. Once your licence is restored, you would need to link to a designated body, participate in annual appraisal in the UK and provide supporting information in line with guidance. Any relevant information gathered while working abroad, as well as evidence of on-going CPD, should be brought to your first appraisal on return to the UK. More information about giving up and restoring your licence is available from the GMC website.

If you choose to continue to hold your licence while practising abroad, you will have to revalidate in the same way as doctors practising in the UK and link to a UK designated body. If your employer or contractor is based within the UK it may be that they will be able to provide you with a link to a RO, and you should discuss your revalidation with them at the earliest opportunity.

If you have not already done so, you should confirm your current circumstances with the GMC through your GMC online account, so that the GMC can provide you with appropriate advice.

Q: I work for periods of time outside the UK. How will this affect my ability to revalidate?

It should be possible for you to collect supporting information, participate in appraisals and link to a RO through your practice in the UK. You should discuss management of your appraisal and supporting information (including additional supporting information to demonstrate your practice abroad) whilst in the UK with your RO and appraiser.

Q: I work across different specialties. Do I need to be revalidated twice?

No, revalidation is based on the entire scope of your practice. Ideally, you will have one appraisal to cover all of your roles. You will only have one RO who will make a recommendation to the GMC about your entire practice.

Your supporting information should reflect your entire scope of practice. Some elements of supporting information will be common to your entire scope of practice and will not need to be duplicated. If in doubt, talk with your appraiser.

Q: I work exclusively in a non-clinical role. How do I revalidate?

If you hold a licence to practise, you will revalidate in the same way as doctors in clinical roles, and the supporting information you bring to appraisal will reflect your non-clinical role.

The GMC states that if you want to continue to hold a licence to practise, then you will need to revalidate like every other doctor who is licensed. However, you may not need a licence to practise if you don’t carry out any clinical practice. If this is the case, you have the option of giving up your licence but maintaining your registration with the GMC.

If the type of activity that you are involved in could be 'related to patient care', you will need to confirm with your employing organisation whether you require a licence to practise. The term ‘practice’ refers to your professional work, clinical or non-clinical. This may include work with little or no patient contact; for example:

  • Interaction by correspondence, such as giving advice by telephone, email or letter
  • Requests for insurance medicals
  • Medico-legal work
  • Review of articles for a medical/specialty journal
  • Clinical-skills lecturing.
Q: I only work part time. How will this affect my revalidation?

You will be expected to revalidate in the same way as full-time doctors, including participating in annual appraisal and collecting supporting information in relation to the practice that you do.

Q: I have retired from the NHS but continue to work in an independent/or voluntary capacity. Do I need to revalidate?

Retired doctors may continue to work in many different capacities, and it depends upon whether you require a licence to practise to undertake any or all of the work that you do. You should speak to the organisation that you are working or volunteering for to ascertain whether that organisation requires you to hold a licence to practise. If you continue to treat patients you will require a licence.

If you do require a licence then you will have to revalidate in the same way as all doctors, linking to a designated body and RO, participating in annual appraisal and collating a portfolio of supporting information in relation to the work that you do.

Q: I have retired from active medical practice. If I continue to maintain CPD will that be sufficient for revalidation?

No.  If you choose to hold a licence to practise, the GMC requires you to revalidate in the same way as every other doctor by participating in annual appraisal and maintaining a portfolio of supporting information.

If you are retired from clinical practice, it may be that you would wish to relinquish your licence to practise but maintain your registration with the GMC. This means that you do not have to revalidate, and it will show that you remain in good standing with the GMC. This will depend on whether you undertake any activity post-retirement which requires a licence to practise (eg. if you work directly with patients).

Q: I am retiring in less than five years. Do I have to revalidate?

Yes.  If you hold a licence to practice in the years leading up to your retirement you will need to revalidate in what you are currently doing, up until the point you retire and relinquish your licence to practice.  You should discuss the management of your appraisal and supporting information with your RO if you are retiring before a full five-year cycle.

If you choose to retain your licence to practice in order to undertake practice post-retirement, you will still need to revalidate according to that activity.

Q: I only work part time. What are the requirements for revalidation?

You will be expected to revalidate in the same way as full-time doctors, including participating in annual appraisal and collecting supporting information in relation to the practice that you do.

Q: How will a short career break (for example maternity leave) affect my ability to revalidate?

Your ability to revalidate should not be affected if you take a short career break within a five-year revalidation cycle.  Our understanding from the GMC is that you will be expected to revalidate at the usual point in your five-year cycle on the basis of the supporting information you have collected and appraisals that you have attended within this time period.  If you have been unable to collect sufficient supporting information for your appraisal, your RO may recommend a deferment of your revalidation to the GMC, in order to allow you to collect additional information.

It is expected that doctors will want to take career breaks within their revalidation cycle, and there is flexibility in the process to manage this.  If you do plan a break you should manage your appraisals around that break as far as possible, so that you do not miss an appraisal prior to going on leave.  A 'return to work' appraisal may also be required by your employer.  Some of the supporting information is required over the five-year cycle, not annually, so again this may be able to be managed around the career break.  You should speak to your appraiser and RO to develop an agreed approach.  It is advisable to try to keep your CPD in your clinical areas up to date even if you are not actively practising, ie. by attending specialist meetings or using distance learning.

The Academy of Medical Royal Colleges has now drawn on various sources to produce guidance on return to practice.