REVALIDATION GUIDANCE FOR PSYCHIATRISTS

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1 REVALIDATION GUIDANCE FOR PSYCHIATRISTS Version 2 Dr Laurence Mynors-Wallis Registrar December

2 The Royal College of Psychiatrists is the professional and educational body for psychiatrists in the United Kingdom. It has been in existence in some form since 1841, receiving a Supplemental Charter to become the "Royal College of Psychiatrists" in The College has some members worldwide. The majority of members are based in the UK where there are six psychiatric specialties and three subspecialties. Trainees in psychiatry are the third largest group of medical trainees in the UK; they will revalidate through the Deanery processes. Psychiatrists not in training in the UK will need to follow the guidance in this report. Psychiatrists working outside the UK will need to revalidate if they wish to retain their licence to practise. They will need to follow the recommendations in this report but should consult the General Medical Council about who their Responsible Officer will be. Citation for this document: Royal College of Psychiatrists. Revalidation Guidance for Psychiatrists. London: Royal College of Psychiatrists, Royal College of Psychiatrists 17 Belgrave Square, London SW1X 8PG 2

3 Contents Introduction 4 College Aims of Revalidation 4 How Psychiatrists will be able to evidence meeting revalidation standards 5 Evidence that will be reviewed at appraisal - General information 9 - Quality improvement activity 11 - Case based discussion 12 - Clinical audit 13 - Clinical outcome measures 14 - Multisource feedback colleagues 15 - Patient feedback 16 - Continuing professional development 17 - Review of significant events 18 - Review of complaints and compliments 19 Other Revalidation Issues - Non-clinical Practice 21 - Academic Practice 22 - Research 23 - Teaching 23 - Private and Independent Practice 24 Responsible Officers 25 Remediation 28 Electronic Portfolio 29 Frequently asked questions 30 Summary of process 33 References 34 Appendix A Summary of Supporting Information 36 Appendix B Case Based Discussion Sheet 48 Appendix C Guidance for Case Based Discussion 50 Appendix D Criteria and Indicators of Best Practice in Clinical Audit 51 Appendix E Audit Proforma 52 Appendix F Multisource Feedback Colleague Structured Reflective Template 53 Appendix G Multisource Feedback Patient Structured Reflective Template 54 Appendix H Significant Event Structured Reflective Template 55 Appendix I Complaint Report Structured Reflective Template 56 3

4 Introduction Revalidation is the process by which licensed doctors will demonstrate to the General Medical Council (GMC) that they are up to date and fit to practise and that they are complying with the relevant professional standards. This document has been updated from Version 1 to reflect current GMC Guidance 1. revalidation is expected to begin in late College Aims of Revalidation The College aims of revalidation are:- Revalidation must command the confidence of patients, the public and the profession. Revalidation should facilitate improved practice for all members and fellows. The process should identify those whose practice falls below acceptable standards and give advice and monitoring to allow revalidation to be reconsidered. There should be early warning of potential failure so remedial action can be taken. The process should allow those who are working to college standards to revalidate without undue difficulty or stress. There must be equity across the specialty, independent of differing areas of practice, working environments and geographical location. Revalidation should be affordable and flexible, starting simple to allow further development. The process should incorporate as far as possible information already being collected in clinical work and use existing tools and standards where available. At the time of writing this document some aspects of revalidation are still being considered by the GMC and other bodies and will no doubt be altered over time. 4

5 How Psychiatrists will be able to Evidence Meeting Revalidation Standards All doctors will be required to collect a portfolio of evidence that will be reviewed at appraisal on an annual basis. Generic standards which apply to all doctors are set out in Good Medical Practice 2. Specialty standards for psychiatrists are set out in Good Psychiatric Practice Version 3 3. Revalidation is planned to take place on a 5 yearly cycle and hence the necessary evidence to provide assurance about keeping up to date and fit to practise can be gathered over a 5 year period. The GMC has grouped the standards of Good Medical Practice into four domains and twelve attributes. These domains and attributes are: The domains and attributes of the GMC module for Good Medical Practice Domain 1 Knowledge, skills and performance Attribute 1 Maintain your professional performance Attribute 2 Apply knowledge and experience to practice Attribute 3 Ensure that all documentation (including clinical records) formally recording your work is clear, accurate and legible Domain 3 Communication, partnership and teamwork Attribute 1 Communicate effectively Attribute 2 Work constructively with colleagues and delegate effectively Attribute 3 Establish and maintain partnerships with patients Domain 2 Safety and quality Attribute 1 Contribute to and comply with systems to protect patients Attribute 2 Respond to risks to safety Attribute 3 Protect patients and colleagues from any risk posed by your health Domain 4 Maintaining trust Attribute 1 Show respect for patients Attribute 2 Treat patients and colleagues fairly and without discrimination Attribute 3 Act with honesty and integrity Keeping up to date and fit to practise will be assessed within this framework of attributes and domains. 5

6 The key process through which revalidation standards will be evidenced is appraisal. The NHS is piloting an enhanced appraisal process which will have both a summative and a formative component. The summative component of appraisal will involve looking back at what has been achieved and the formative part will be the agreeing of a Personal Development Plan as to the way forward. There is an expectation that appraisers will have been trained to ensure that appraisal is delivered in a professional, fair and transparent manner. The Royal College of Psychiatrists has established appraisal training, providing an opportunity for psychiatrists to train, not only using the recommended appraisal system, but also to know how the specialist standards for psychiatry can be evidenced. The College has produced Good Practice Guidelines for Appraisal to assist both appraisers and appraisees in meeting best practice standards 4. This document sets out guidance about the evidence that psychiatrists will be expected to collect in order to meet the requirements for Revalidation. The examples given are not exclusive. The decision as to the appropriateness of evidence will be taken in discussion at appraisal between the appraiser and the appraisee. At the completion of a 5 year cycle a Responsible Officer will need to be assured that evidence collected is sufficient to ensure that the doctor meets the revalidation requirements. If a particular standard has not been met, for a valid reason, agreed at appraisal between the appraiser and the psychiatrist being appraised, this should be documented so that the Responsible Officer will understand why decisions were made. Supporting Information All doctors will bring to their appraisal supporting information that provides evidence about the GMC twelve attributes. The supporting information that you will need to bring to your appraisal will fall under four broad headings:- i) General information providing context about what you do in all aspects of your work. ii) Keeping up to date maintaining and enhancing the quality of your professional work. 6

7 iii) iv) Review of your practice evaluating the quality of your professional work. Feedback on your practice how others perceive the quality of your professional work. There are six types of supporting information over and above general information that you will be expected to provide and discuss at your appraisal at least once in each five year cycle. These are: i) Quality improvement activity. ii) Feedback from colleagues. iii) Feedback from patients (where applicable). iv) Continuing professional development. v) Significant events. vi) Review of complaints and compliments. The nature of the supporting information will reflect your particular practice and your other professional roles. By providing all six types of supporting information over the revalidation cycle each psychiatrist should, through reflection and discussion at appraisal, have demonstrated practice against all 12 attributes outlined in the GMC separate guidance, Good Medical Practice Framework for Appraisal and Revalidation 5. This will make it easier for the appraiser to complete the appraisal and for the Responsible Officer to make a recommendation to the GMC about revalidation. It is not necessary to structure the appraisal formally around the GMC Framework, or to map supporting information directly against each attribute. However, some doctors may prefer to do this and some appraisers may find it useful to structure the appraisal interview in this way. 7

8 The purpose of collecting the evidence for appraisals over the five year cycle is not to tick boxes showing that a particular standard has been met, but rather to enable the psychiatrist to collect a body of meaningful information that will demonstrate continuing fitness to practise. It is expected that this process will facilitate ongoing professional development, the aim of which is to improve the standard of care that each psychiatrist provides for patients. Appendix A provides a summary of the supporting information requirements. 8

9 Evidence that will be Reviewed at Appraisal 1. General Information a) Personal details (including your GMC reference number) b) Scope of work This will include the organisations and locations where you have undertaken work as a doctor. You will also need to provide a description of the scope and nature of your practice. c) Record of annual appraisals d) Personal development plans and their review e) Probity Probity is at the heart of medical professionalism. Probity means being honest and trustworthy and acting with integrity. A statement of probity is a declaration that you accept the professional obligations placed on you in Good Medical Practice in relation to probity. It also includes the requirement to inform the GMC without delay if, anywhere in the world, you have accepted a caution, been charged with or found guilty of a criminal offence, or if another professional body has made a finding against your registration as a result of fitness to practise procedures. If you are suspended from a medical post, or have restrictions placed on your practice you must, without delay, informed any other organisations for which you undertake medical work and any patients you see independently. Good Medical Practice provides guidance on issues of probity as follows: Being honest and trustworthy (paragraphs 56-59). Providing and publishing information about your services (paragraphs 60-62). Writing reports and CVs, giving evidence and signing documents (paragraphs 63-69). Research (paragraphs 70-71). Financial and commercial dealings (paragraphs 72-73). Conflicts of interest (paragraphs 74-76). 9

10 f) Health A statement of health is a declaration that you accept the professional obligations place on you in Good Medical Practice about your personal health. Good Medical Practice provides the following guidance: Registration with a GP You should be registered with a general practitioner outside your family to ensure that you have access to independent and objective medical care. You should not treat yourself (paragraph 77). Immunisation You should protect your patients, your colleagues and yourself by being immunised against common serious communicable diseases where vaccines are available (paragraph 78). A serious condition that could pose a risk to patients If you know that you have, or think you might have, a serious condition that you could pass on to patients, or if your judgement or performance could be affected by a condition or its treatment, you must consult a suitably qualified colleague. You must ask for and follow their advice about investigations, treatment and changes to your practice that they consider necessary. You must not rely on your own assessment of the risk you pose to patients (paragraph 79). 10

11 2. Quality Improvement Activity For the purposes of revalidation, you will have to demonstrate that you regularly participate in activities that review and evaluate the quality of your work. Quality improvement activities should be robust, systematic and relevant to your work. They should include an element of evaluation and action, and where possible, demonstrate an outcome or change. Quality improvement activities could take many forms depending on the role you undertake and the work that you do. If you work in a non-clinical environment, you should participate in quality improvement activities relevant to your work. Examples of quality improvement activities include: i) Clinical audit evidence of effective participation in clinical audit or an equivalent quality improvement exercise that measures the care with which an individual doctor has been directly involved. ii) Review of clinical outcomes where robust, attributable and validated data are available. iii) Case review or discussion a documented account of interesting or challenging cases that a doctor has discussed with a peer, another specialist or within a multi-disciplinary team. iv) Audit and monitor the effectiveness of a teaching programme. v) Evaluate the impact and effectiveness of a piece of health policy or management practice. The College is recommending three key quality improvement activities:- i) Case based discussion. ii) Clinical audit. iii) Clinical outcomes. 11

12 Case Based Discussion The College is recommending that the case based discussion 6 technique is used as a key plank of appraisal. The system being proposed for those not in training has been adapted from that used by trainees to meet the different requirements of more experienced doctors. Case based discussion provides the opportunity for a specialist psychiatrist to discuss the care of a real case with a colleague. It provides an opportunity for the colleague to make an assessment of key clinical care standards set out in Good Psychiatric Practice. Case based discussion evaluates what the doctor has done in practise. It has the advantage over a simple review of case notes in that the doctor being appraised has the opportunity to explain and clarify the information that is contained in the clinical records and provide appropriate clinical background. A summary case based discussion sheet (Appendix B) records the relevant information. The expectation is that at each case based discussion, a discussion will occur as to whether the psychiatrist has satisfactorily met the standards being evaluated from Good Psychiatric Practice. Good points in the clinical care will be highlighted together with the identification of areas of improvement. Each area for improvement will then link to a Personal Development Plan which will be followed up at appraisal. The College recommends that a minimum of 10 case based discussions be undertaken over a 5 year period (2 per year). It will be the responsibility of each psychiatrist to ensure that an appropriate sample of the patients whom they are looking after are included in case based discussion. In order to achieve this, approximately two thirds of case based discussions should be chosen at random and the other third should be chosen by the psychiatrist being appraised. The purpose of random selection is to provide reassurance that care provided is satisfactory for cases that the psychiatrist has not particularly selected. The purpose of allowing a proportion of cases to be selected is to ensure that over a five year cycle, cases discussed broadly reflect the diagnostic case mix of the psychiatrist s workload. Selection also allows the psychiatrist to 12

13 discuss the management of complex cases that they consider would be of value for their own personal development. Guidance as to how to conduct a case based discussion is given in Appendix C. Case based discussion may occur in a one to one format but could involve more than one colleague and occur, for example, in the context of a peer group. Case based discussion could also occur in the context of supervision. If more than one colleague is involved in the case based discussion, it will be the responsibility of one person to complete the case discussion summary sheet with the ratings and action plans. Case based discussion is not the only workplace assessment that might be of value in Revalidation. If psychiatrists wish to use other techniques, for example, direct observation of practice by a colleague, this information can be included in the evidence set out at appraisal and would be a reasonable alternative to a case based discussion. Standard Undertake 10 case based discussions over a 5 year cycle and incorporate identified action points in a personal development plan. Clinical Audit It is expected that each psychiatrist will provide an audit over a 5 year cycle in at least two significant clinical areas of their practice with standards, based on best practice guidelines, re-audit, evidence of discussion in appraisal and appropriate action. It is important that the audits reflect the care provided by the individual doctor and focuses on key areas of clinical practice. The importance of audit is not the audit process itself but the evidence it provides that the psychiatrist is working to improve patient care. In discussion with an appraiser, a non-audit quality improvement process could be agreed in place of one of the audits, for example, a research project. It will often be the case that the psychiatrist will work with others to undertake the audit. The participation of the psychiatrist will most importantly occur in the setting of standards and the drawing up and implementation of appropriate action. Participation in national audits (where individual or team results can be 13

14 determined) eg. the Prescribing Observatory of Mental Health can be used as evidence of clinical audit as long as there is evidence of action plans, change implementation and re-audit. The College intends to identify and approve (kite mark) audits in key areas of psychiatric practice that colleagues can use if considering an audit. It is hoped that this will provide an opportunity to benchmark practice with colleagues. It is recognised that the meeting of standards in many areas of psychiatry involves the practice of colleagues and also the availability of appropriate resources. The development of action plans following audit may, therefore, be used as an example of working with clinical and managerial colleagues to bring about improvement in patient care. HQIP (Healthcare Quality Improvement Partnership) have set out criteria and indicators of best practice in clinical audit (Appendix D). The audit form (Appendix E) will provide the summary of the audit data for the revalidation portfolio. Standard To complete two audits of significant clinical areas of practice over a 5 year cycle. Clinical Outcome Measures The College is not recommending specific outcome measures to be used for revalidation at this stage. It is the College s view, however, that psychiatrists should be considering, with colleagues, the use of appropriate outcome measures as a way of working with patients to determine the benefit or otherwise of interventions chosen. The College has published a report on the use of clinical outcome measures to assist in the choice of relevant measures 7. The National Institute for Mental Health in England has produced an outcomes compendium 8 of potentially relevant measures. Using structured outcome measures to look at, not only clinical progress, but also outcomes relevant to patients is an example of good practice and a significant quality improvement activity. 14

15 Psychiatrists in managed care organisations should work with managers to ensure that organisation collected outcomes are made available for use in revalidation. Standard Demonstrate the use of appropriate outcome measures in clinical practice. 3. Multisource Feedback Colleagues It is a GMC requirement that colleague multisource feedback is obtained for all doctors. The expectation is that each doctor obtain feedback using standard questionnaires that comply with GMC principles 5. These principles are that the questionnaire:- a) be consistent with the principles, values and responsibilities set out in the GMC s core guidance, Good Medical Practice. b) be piloted on the appropriate population, and demonstrate that they are reliable and valid. c) reflects and measures the whole practice of the doctor. d) be evaluated and administered independently from the doctor and appraiser to ensure an objective review of the information. e) provides appropriate and useful information to the doctor that can be used in discussions with a supervisor or mentor, or through appraisal. f) helps the doctor reflect on his or her practice and identify opportunities for professional development and improvement. The GMC has also produced checklists for the development, administration and implementation of questionnaires. It is recommended that colleague multisource feedback occurs at least once every 5 years. The feedback should then be discussed with a colleague, either at or outside appraisal and an appropriate Personal Development Plan drawn up to address any issues that arise. 15

16 The requirement for multisource feedback is a minimum of one per 5 years and assumes that no significant concerns have arisen. If significant concerns have been picked up by multisource feedback, a second multisource feedback should be undertaken in the 5 year cycle, following appropriate action by the doctor concerned. You should be able to demonstrate that you have reflected on the feedback. Your appraiser will be interested in what actions you took as a result of the feedback, not just that you collected it. The discussion at appraisal should highlight areas of good performance and help you to identify any areas that might require further development. This should be reflected in your personal development plan and your choices for continuing professional development. Multisource feedback from colleagues allows psychiatrists to meet several of the standards for Good Psychiatric Practice concerned with teamwork and working with colleagues. The College ACP360 has been designed specifically for psychiatrists 9. Using this tool enables psychiatrists to be compared with their UK colleagues and provides a useful benchmark against which to draw up appropriate actions. A summary of the MSF findings to be included in appraisal documentation is provided in Appendix F. Standard Undertake one MSF from colleagues using a tool meeting GMC standards at least once in a 5 year cycle and take appropriate action. 4. Patient Feedback As with colleague multisource feedback, it is a requirement that there will be patient feedback (where applicable) using a questionnaire that meets GMC standards (agreed by appraiser) once in 5 year cycle. As with multisource feedback from colleagues, it is expected that any issues that arise from patient 16

17 feedback will be subject to action points in a Personal Development Plan and be reviewed at appraisal. Many colleagues may wish to collect patient feedback in a variety of formats, providing evidence over and above the minimum requirement. This is to be encouraged. Those doctors working in managed care systems should endeavour to work with managers to facilitate the routine collection of patient experience data that could then be used as part of the supporting evidence for appraisal. You should be able to demonstrate that you have reflected on the feedback. Your appraiser will be interested in what actions you took as a result of the feedback, not just that you collected it. The discussion at appraisal should highlight areas of good performance and help you to identify any areas that might require further development. This should be reflected in your personal development plan and your choices for continuing professional development. A summary of patient feedback information to be included in appraisal documentation is given in Appendix G. Standard Obtain patient feedback using a tool meeting GMC standards at least once in a 5 year cycle and take appropriate action. The College recognises the important role carers play and recommends that, where possible, psychiatrists obtain feedback from carers. 5. Continuing Professional Development It is a requirement for revalidation that psychiatrists keep their knowledge and skills up to date; they are encouraged to take part in educational activities that maintain and further develop their competence and performance. The College recommends that psychiatrists are in good standing with the College for Continuing Professional Development (or have done equivalent CPD). The College has produced clear guidance for Continuing Professional Development 17

18 which reflects and is in line with the recommendations of the other medical Royal Colleges 10. The requirements for CPD can be summarised as follows:- i) Minimum of 50 hours per year (250 hours over a 5 year cycle). ii) The content of CPD will reflect the job of the psychiatrist and include an appropriate mixture of clinical, managerial, and professional activities. CPD should equip the doctor to meet the changing nature of their practice. iii) The meeting of the CPD requirements will be validated by a peer group chosen by the psychiatrist. If this is not possible this will occur at appraisal by the appraiser. The GMC advice for CPD emphasises the need for CPD to focus on outcomes or outputs rather than time served. A certificate of good standing for CPD in each of the 5 years should meet the GMC and College requirements for revalidation. The evidence supporting such a certificate can be held electronically for review if necessary. It is not expected that an appraiser will need to review the evidence in detail as this will have been examined via a peer group process. Standard Remain in good standing with the College for CPD in each of the 5 years or have done the equivalent professional development. 6. Review of Significant Events It is expected that psychiatrists will reflect upon significant events or serious untoward incidents involving patients in their care and identify, not only good practice, but also areas for improvement. The areas for improvement should be incorporated into a Personal Development Plan and be reviewed through the appraisal process. 18

19 A significant event (also known as an untoward or critical incident) is any unintended or unexpected event, which could or did lead to harm of one or more patients. This includes incidents which did not cause harm but could have done, or where the event should have been prevented. These events should be collected routinely by your employer, where you are directly employed by an organisation. If you are self-employed, you should make note of any such events or incidents and undertake a review. You should discuss significant events involving you at appraisal with a particular emphasis on those that have led to a specific change in practice or demonstrate learning. The numbers of significant events may vary across different specialities and it is the content and what you learnt, rather than the number that should be the focus in appraisal. A structured format for documenting reflection on serious untoward incidents is provided in Appendix H. Standard Reflect on each significant event and discuss learning and appropriate action at appraisal. 7. Review of Complaints and Compliments A complaint is a formal expression of dissatisfaction or grievance. It can be about an individual doctor, the team or about the care of patients where a doctor could be expected to have had influence or responsibility. Complaints should be seen as another type of feedback, allowing doctors and organisations to review and further develop their practice and to make patientcentred improvements. You might also choose to bring any compliments you have received to appraisal. 19

20 You should discuss any change in your practice that you have made as a result of any complaints or compliments you have received since your last appraisal. You may not have any complaints made about you or your team in a given appraisal period. The numbers of complaints may vary across different specialities and it is how you dealt with the complaint, rather than the number, that should be the focus of discussion in appraisal. A structured format for documenting reflection on complaints is given in Appendix I. Standard Reflect on each complaint and discuss learning and appropriate action at appraisal. 20

21 Other Revalidation Issues Non-clinical Practice Many psychiatrists spend a significant proportion of their time in non-clinical practice including academic work, both teaching and research, management activities, and medico-legal work. There is a range of supporting information that can be provided at appraisal to demonstrate good practice in these areas. Teaching Evidence to show that psychiatrists involved in teaching are meeting the standards of Good Psychiatric Practice could include information about the content of a teaching course together with feedback from students. A useful set of standards for medical educators 11 is provided by the Academy of Medical Educators. Research - Evidence of compliance with Good Medical and Psychiatric Practice would include information about meeting national and local research governance arrangements. The GMC has produced specific guidance for the roles and responsibilities of doctors in research 12. Medical Management and Clinical Leadership The GMC has produced guidance 13 and the former British Association of Medical Managers produced standards 14 for medical managers. Expert Advice Evidence of compliance in medico-legal work could include providing evidence of compliance with ensuring patients and psychiatrists understand the confidentiality issues and that the psychiatrist has ensured that their training has been kept up to date in the areas in which they are providing expert knowledge. The GMC and the BMA have provided guidance 15,16 for those acting as an expert witness. Standard Provide supporting information that teaching, research, management and expert advice activities meet standards set in Good Medical and Good Psychiatric Practice. 21

22 Academic Practice Academic Psychiatrists will be expected, as part of revalidation, to provide at appraisal supporting evidence covering both the clinical and academic aspects of the work they undertake. As with revalidation in general, Academic Psychiatrists will be expected to provide evidence to support meeting the standards of Good Medical and Good Psychiatric Practice for the roles they undertake, reflecting for many individuals specialised and expert areas of practice. The Follett principles of whole practice appraisal will continue to apply. There should be a jointly agreed appraisal scheme between the educational and clinical provider. Only one appraisal should be undertaken each year which will be structured so as to review both the clinical and academic work of the appraisee. The General Medical Council have published a report on non-clinical work and revalidation from the Non-Clinical Work Group of the Academy of Medical Royal Colleges (click here This report sets out standards for medical research and medical education together with supporting evidence that could be provided at appraisal. This report should be viewed as providing a menu of ideas about supporting information that could be brought to appraisal with regard to non-clinical work. There is no expectation that academics will be expected to provide any particular evidence over and above the standards of Good Medical Practice and Good Psychiatric Practice. It is also recognised that academic psychiatrists have widely differing job descriptions for both their clinical and academic roles, for example in terms of the nature and relative amounts of clinical work, research, teaching, and of management and leadership roles. As such, the process and content of appraisal should be similarly flexible, and proportionate, whilst remaining fully consistent with the principles of revalidation. 22

23 Research In the GMC core guidance, Good Medical Practice, doctors who are involved in research are advised that:- If you are involved in designing, organising or carrying out research, you must put the protection of participants interests first, act with honesty and integrity and follow the appropriate national research governance guidelines. More detailed guidance (32 points) are set out in the GMC Guidance Good Psychiatric Practice in Research (click here This Guidance also includes relevant confidentiality guidance. It is expected that academic psychiatrists involved in research will provide supporting evidence that the GMC standards are met. Point 4, and the related GMC guidance, applies primarily to clinical research with patients. Some academic psychiatrists may be engaging in preclinical research e.g. research with animals or cells, which falls outside the remit of revalidation. Nevertheless, it is still appropriate for such research to be included in the appraisal, with that component of the appraisal being led by the University appraiser. Teaching Key Teaching Standards for Medical Education set out by the Academy of Medical Royal Colleges include:- Use observation, feedback, up to date educational knowledge and research as sources for active reflection, evaluation and revision of your practice. Routinely audit and monitor the effectiveness of your programme. Ensure that assessment decisions are recorded and documented accurately and systematically. Develop a variety of clear, accurate presentations and representations of concepts, using alternative explanations to assist learners understanding and presenting diverse perspectives to encourage critical thinking. 23

24 Record and report results accurately and in a way that is transparent and open to audit. Teaching issues and standards fall equally within the University and NHS domains of appraisal. For example, educational training, and ongoing evaluation of teaching activities, will usually be a standard part of the academic s job description. The documentation and discussion of teaching activities during the appraisal should be conducted in a single and integrated fashion, avoiding duplication. Private and Independent Practice Those psychiatrists undertaking private work will revalidate to the same standard as those in NHS work. This guidance is for all psychiatrists and may need to be adapted according to the circumstances of each doctor e.g. if a psychiatrist is not seeing patients in a clinical context it is not expected that they provide feedback from patients using the standardised GMC appraisal tools. It remains unclear at the time of preparing this guidance who will be the Responsible Officer for those psychiatrists who have no links with managed care organisations. At present there is no legal requirement that doctors doing no other medical work except sitting on Mental Health Review Tribunals will be required to revalidate. It is the view of the College that psychiatrists in this situation maintain their licence to practise through revalidation. 24

25 Responsible Officers Responsible Officers will have a key role in revalidation. They will make a recommendation to the GMC, usually every five years, about whether an individual doctor should be revalidated. The Responsible Officer will also be responsible for ensuring that systems of clinical governance and appraisal in their organisation are working and are appropriate for revalidation. The Responsible Officer Regulations came into force in Northern Ireland on 1 October 2010 and in England, Scotland and Wales on 1 January The regulations specify the organisations or bodies which are designated bodies and which must appoint or nominate a Responsible Officer. Responsible Officers must be licensed medical practitioners, such as a Medical Director within a healthcare organisation. The designation of such bodies or organisations and the associated requirement to nominate or appoint a Responsible Officer will ensure that the vast majority of doctors, and particularly those whose work affects the safety of patients, will link to a Responsible Officer. Responsible Officers will be responsible for the doctors employed by, or contracted to, the designated body or organisation. Doctors will only link to one Responsible Officer. One of the key duties of a Responsible Officer will be to ensure that systems and processes are in place so that doctors within the organisation can meet revalidation requirements. Such systems will include a robust appraisal process in which all doctors are enrolled. At the end of each 5 year cycle, the Responsible Officer will be required to make a recommendation to the GMC as to whether the doctor has met the standards for revalidation. In areas where the decision to make a revalidation recommendation is uncertain it is likely that Responsible Officers will seek advice from College Advisors in making a revalidation recommendation. Responsible Officers may or may not be psychiatrists. The role of the College Advisor in assisting Responsible Officers has yet to be set out. The College has alongside 25

26 other Medical Royal Colleges agreed the following principles for the giving of specialty advice:- Consistency: advice given to ROs, appraisers and individual doctors must be consistent with guidance from other key revalidation partners, based on the standards and guidance already published by colleges and faculties, and consistent between different individuals providing advice. Commonality: common processes across all specialties should be agreed as far as possible in order to avoid inconsistency in methods of acquiring and providing advice. Legality: colleges and Faculties must not become involved in the decisionmaking process regarding the recommendation for revalidation, and work within the legal considerations (Appendix 2). Impartiality: advisors providing guidance/advice must be impartial and must not have any conflict of interest or vested interest in the individuals concerned. If locally sought, this may require the adviser to come from outside the area/region in which the doctor is employed. Generality: requests for advice must be in relation to a situation or set of circumstances and not to an individual doctor or appraiser. The final decision about making a revalidation recommendation will rest with the Responsible Officer. The Department of Health (England) has produced guidance about the Responsible Officer role, including how doctors can find out who their Responsible Officer is. Relevant extracts from the Responsible Officer Guidance, DH (England) July 2010 includes:- 1.6 The responsible officer, following the appropriate or necessary consultations with Medical Royal College representatives and where necessary the National Clinical Assessment Service (NCAS), will decide whether the necessary standards are met and if not will refer the doctor to the GMC on fitness to practise grounds. 26

27 3.10 The responsible officer should be informed by the appraiser about any significant concerns that arise, i.e. those of a sufficiently serious nature to call into question the doctor's fitness to practise, as these are likely to require specialist input from the appropriate Medical Royal College or Faculty, NCAS or other relevant body. Arrangements for remediation, supervision or suspension may also need to be put in place At the time of revalidation, the responsible officer, having assessed all the information and, if appropriate, consulted the relevant Medical Royal College or Faculty, will make a recommendation to the GMC regarding the doctor s fitness to practise. 4.7 Medical Royal Colleges and Faculties will offer support to responsible officers in evaluating the specialist practice of doctors. The responsible officer will want to ensure that there is appropriate liaison between their organisation and the relevant Medical Royal Colleges and Faculties to seek their input to the appraisal process as required, in terms of specialist practice. The responsible officer will decide when he or she needs advice on specialist practice. In cases where there are concerns relating to general practice or specialist clinical practice advice may be available from the Medical Royal Colleges. 4.9 The responsible officer will also be expected to liaise with the appropriate Medical Royal College or Faculty, where appropriate, through the College Regional Advisors or identified college contacts for independent advice on the relevant specialist practice and also, in cases of concern, for advice on the performance of the doctor The responsible officer is unlikely to make the decision to refer a doctor to the GMC in isolation; he or she will want to seek advice from appropriate sources, for example from the medical Royal Colleges and Faculties or the National 27

28 Clinical Assessment Service (NCAS) or other relevant body. The responsible officer must also ensure that remediation and disciplinary procedures, where appropriate, are followed The responsible officer will liaise, where appropriate, with the Medical Royal Colleges and Faculties for information and support regarding specialist and GP practice and potential recommendations. The guidance and further information about the Responsible Officer role is available on the Department of Health (England) website. The Department of Health, Social Services and Public Safety (DHSSPS) has published the regulations and guidance that apply to Responsible Officers in Northern Ireland. These can be viewed on the DHSSPS website. In Scotland the Executive Medical Directors of Health Boards (including special Boards such as the State Hospital Board) will be the responsible Officers within the NHS. Further information about this can be found at Scotland/paper/Revalidation/Officers Remediation There will be some psychiatrists for whom the revalidation process identifies the need for remediation. In these cases employers, the National Clinical Assessment Service (NCAS), the Deanery (for trainees) and the Responsible Officer may need to be involved in order to draw up a plan for remediation and assessment. The College was involved in the drawing up and supports the recommendation of remediation report produced for the Department of Health in England by the steering group on remediation

29 Electronic Portfolio Each of the four UK devolved health departments have taken a different approach to standardising the documentation to be used in appraisal. England No standardised documentation to be recommended. It will be the responsibility of individual employers and Responsible Officers to determine what best meets their requirements. The College is examining, with other Medical Royal Colleges, the feasibility of recommending a cross specialty electronic portfolio to be used in England. Scotland Standardised portfolio based on SOAR which may be found at Wales Standardised portfolio based on GP appraisal documentation which may be found at Northern Ireland The appraisal documentation for psychiatrists working in Northern Ireland may be found at 29

30 Frequently Asked Questions 1. What is revalidation? Revalidation is the process by which doctors will have to demonstrate to the GMC, normally every five years, that they are up to date and fit to practise. 2. 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. 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 ongoing improvement in the quality of medical care delivered to patients throughout the UK. 3. How will 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. For more information, please see our guidance on supporting information for appraisal and revalidation. 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. 4. 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. 5. 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 30

31 revalidation may be postponed for a period of time to allow them time to gather sufficient supporting information for the appraisal and revalidation. 6. How will patients, carers and the public be involved in revalidation? One of the aims of revalidation is to assure patients and the public that licensed doctors are up to date and fit to practise. Patients will need to have confidence in the way that revalidation will work. Our consultation, Revalidation: The Way Ahead, explored a number of ways in which patients and the public might be involved in revalidation. Following the consultation, we have agreed that the information that doctors will discuss at appraisal will include feedback from patients, through patient questionnaires, complaints and compliments. It may also be appropriate for patient feedback received through other mechanisms, for instance through engagement with Patient Advice and Liaison Services ( to be included in appraisal discussions where it is available. 7. What should I be doing now to prepare for revalidation? Revalidation is not expected to roll out until In the meantime, you need to ensure that you are participating in annual appraisal. If you cannot access appraisal through your workplace, you should contact your Responsible Officer or relevant health board. Information about what psychiatrists will be expected to bring to their appraisal is in this document. You should ensure that you know who your Responsible Officer is. Guidance and further information about the Responsible Officer role is available on the Department of Health (England) website and the Department of Health, Social Services and Public Safety (DHSSPS) website. Responsible Officers have been in place since 1 January They will have a legal duty to ensure the local systems and processes which underpin revalidation are in place, including clinical governance systems and a system of annual appraisals. Doctors who have queries about finding their Responsible Officer should contact the DHSSPS or the Department of Health (England) for more information. Doctors may also wish to contact the organisations that employ or contract their services to confirm arrangements for linking with a Responsible Officer based in those organisations. In order to stay up to date with developments in revalidation and guidance that we are publishing you can sign up to the GMC Revalidation Update, a regular e-bulletin sent on behalf of the UK Revalidation Programme Board by the General Medical Council. In order to do this, please send an requesting addition to our mailing list to For more information about appraisals and revalidation in your country, you can visit: The NHS Revalidation Support Team website: (England) 31

32 The Health in Wales website: (Wales) The Scotland NHS website: (Scotland) The Health and Social care in Northern Ireland website: (Northern Ireland) 8. What will happen if I do not engage in appraisal and revalidation? The GMC 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. 9. If serious concerns are raised about a doctor's practise 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 is therefore unable to recommend them for revalidation, the doctor will be referred to the GMC's Fitness to Practice processes. Where concerns about a doctor's practise 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 they are due to be revalidated but be dealt with through usual day to day systems or at appraisal. The Responsible Officer 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 GMC's Fitness to Practise department for investigation their revalidation will be deferred until the outcome of that investigation is known. 10. Will there be a required minimum number of clinical sessions that doctors must undertake in order to revalidate? The GMC will not require doctors to undertake a set minimum number of hours or clinical sessions for revalidation as it is based on what a doctor's practice consists of on a day-to-day basis and different fields of practise have different requirements. Before making a recommendation, a Responsible Officer will need to be satisfied that a doctor is up to date and fit to practise, based on the information and discussions at appraisal. If you have any further questions about revalidation, please the College at 32

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