1. Implementation of the GMC s requirements on the number of attempts at and the currency of specialty examinations.

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1 20 November 2012 Postgraduate Board 7 To consider Specialty examinations - currency and number of attempts Issue 1. Implementation of the GMC s requirements on the number of attempts at and the currency of specialty examinations. Recommendations 2. a. To note the progress made by royal colleges and faculties in ensuring that candidates will normally not be allowed more than six attempts at specialty examinations (paragraphs 14-21). b. To confirm that passes in specialty examinations obtained outside approved training programmes can be counted towards a CCT provided that the candidate enters, or where appropriate, re-enters approved training within seven years of the examination pass (paragraphs 14-21). c. To note that the GMC Council has decided that rules regarding admissibility of evidence of competence and performance within the CCT process must also apply to the use of that same evidence within the alternative routes to Specialist and GP registration (paragraphs 22-23). Further information 3. If you require further information about this paper, please contact us by gmc@gmc-uk.org or tel

2 Background 4. The General Medical Council sets standards for postgraduate training and, among other things, approves curricula and assessment systems including examinations, assessments and tests of competence. 5. On 9 April 2010, we sent a note to our key interest groups about the legal position on the recognition of national professional examinations (specialty examinations) for the award of a Certificate of Completion of Training (CCT). The note reflected the approach previously taken by PMETB and was based on legal advice that it had received in 2006 and We said that in order for an approved examination to be taken into account among the requirements leading to a CCT, it must be taken during a period of recognised training. This approach potentially affected doctors who had left their training programme by the time they passed the examination, doctors in service posts and doctors who took an examination during a period of unapproved training in another country. 6. A number of trainees and medical Royal Colleges raised concerns about this approach and we were asked to review the position. We sought advice from Leading Counsel. That advice made it clear that there is flexibility in the current legislation to allow (but not require) the GMC to approve curricula and assessment systems leading to a CCT even if national professional examinations (approved by the GMC) were taken when the trainee was not within an approved training programme. 7. The legal advice and the implications for the rules governing the award of a CCT were discussed at a meeting of key interest groups on 17 June At that meeting the GMC indicated that it wished to be as flexible as possible, consistent with maintaining the integrity of the training programmes and that it was anxious to ensure that the legitimate expectations of trainees in relation to the approval of success in examinations were met. 8. Following the meeting, and further constructive discussions with key interests, the GMC decided that doctors already in, or who entered, specialty including GP training by 31 October 2011 (subsequently extended) would be able to have any valid passes in previously approved national examinations counted, even if obtained outside approved training before they enrolled for a CCT programme. 9. At its September 2010 meeting, the Postgraduate Board decided that, pending a full review of the standards for curricula and assessment systems in due course, we should consult on some specific issues about examinations including about currency, timing and the number of attempts a candidate could make. 10. The consultation was held between 17 January 2011 and 31 March 2011 and the results were reported to the Postgraduate Board on 20 April In response to an offer made by the Academy of Medical Royal Colleges (AoMRC), the Board agreed that the Academy would be invited to lead discussions with a view to achieving agreement by 31 December 2011 in respect of the currency, timing and number of attempts at specialty examinations. 2

3 11. The issues were then discussed at meetings of the Academy Assessment Committee (AAC) on 15 June and 12 October This led to an Academy paper dated November 2011 which stated: At the latest meeting of the Academy Assessment Committee on 12 October 2011 agreement was reached on two of the questions that were put to the Committee. First it was agreed that demonstration of additional educational experience will be necessary for all candidates for each re-entry after six attempts It was decided that there should be a seven year limit on any single examination pass with the option of flexibility in individual cases subject to a detailed review of circumstances. 12. On 22 November 2011 the Postgraduate Board agreed that the AoMRC proposals were a reasonable approach to setting out a minimum requirement but that there should be some flexibility regarding individual cases. 13. Further progress was reported to the Board on 17 January The Board agreed that in future any valid passes in specialty examinations could be counted towards a CCT even if obtained outside approved training provided that the candidate enters, or where appropriate, re-enters approved training within seven years of the examination pass. Discussion 14. The Academy has continued to discuss the requirements and detailed guidance has been developed to address the complexities involved. Progress 15. In particular, on 23 February 2012, the AAC agreed that the seven years limit applied to any part of a specialty examination and to both UK and international trainees. Draft guidance was presented which was subsequently refined and discussed again at the AAC meeting on 21 June By this point it was becoming clear that there were divergent understandings of the seven years limit in particular. The GMC was aiming to clarify and standardise the position of examinations taken outside approved training programmes in relation to the award of CCTs. However, this point had become overlooked as Colleges and Faculties considered the feasibility of requiring that each candidate should complete each set of specialty examinations within seven years, irrespective of whether examinations were taken inside or outside approved training programmes. This confusion developed despite the GMC s position being explicitly stated on our website (and the text of the relevant page being on the AAC agenda on 23 February 2012). 3

4 17. The GMC revised its webpage in August 2012 partly in order to restate its position on currency and also to reflect the AAC s decision that the seven years limit applied to any part of a specialty examination. The revised webpage acknowledges that full compliance with the requirements may not be immediate: The royal colleges and faculties are developing their procedures to ensure that they meet our requirements or go further in relation to currency and the number of attempts. The full text of the revised webpage is at Annex A and at On 23 August 2012, the AoMRC circulated a link to the revised webpage to members of the AAC. As the AoMRC stated: The GMC also envisage including links to webpages from the individual colleges and faculties where trainees etc can find specialty-specific information on currency and attempts at examinations. The AAC members were asked to provide the GMC by the end of September 2012 with a link to a webpage setting out how the college or faculty is meeting, or planning to meet, the new requirements. 19. The table below provides a provisional and initial high-level summary of a complicated position for the specialties represented on the AAC. Compliance with the GMC s requirement on currency appears limited despite the circulation of the GMC s revised webpage. 20. The colleges and faculties are moving towards compliance with the requirement on limiting the number of attempts at their examinations. However, they do not all refer explicitly to requiring evidence of additional educational experience (as stated on the GMC webpage) where re-sits are permitted above a normal limit. Where that is the case, they are described below as probably compliant. Compliance with GMC requirements for specialty examinations Specialty Attempts Currency Anaesthetists Compliant Compliant Emergency medicine No reply No reply Dental surgery No reply No reply General practice Compliant for CCT route No stipulation but issue not expected to arise Intensive care medicine No reply No reply Obstetrics and gynaecology Probably compliant for candidates in UK-based training Not resolved 4

5 Occupational medicine Holding reply Holding reply Ophthalmology No reply No reply Paediatrics and child health No reply No reply Pathologists Probably compliant No information Pharmaceutical medicine Probably compliant Not resolved Physicians Psychiatrists Moving towards compliance from January Compliant for CASC. On written papers, moving towards compliance by Not resolved Not resolved Public health Compliant from June 2013 Not resolved Radiologists No reply No reply Surgeons specialty exams Surgeons intercollegiate exam Compliant Compliant on Part B. Compliant on Part A from April Not resolved Not resolved 21. The issues and the responsibilities of the colleges and faculties in relation to the GMC s requirements were discussed again at the AAC on 18 October. Subject to the Board s discussion, we will contact all the colleges and faculties again by the end of November to explain that we will require evidence of planning for compliance in all respects by the end of December. Recommendation: To note the progress made by royal colleges and faculties in ensuring that candidates will normally not be allowed more than six attempts at specialty examinations. Recommendation: To confirm that passes in specialty examinations obtained outside approved training programmes can be counted towards a CCT provided that the candidate enters, or where appropriate, re-enters approved training within seven years of the examination pass. 5

6 Review of routes to the GP and Specialist Registers 22. On 27 September 2012, the GMC Council considered the Report of the Consultation on the Routes to the GP and Specialist Registers. This covers entry onto the Specialist Register with a Certificate of Eligibility for Specialist Registration (CESR) and entry onto the GP Register with a Certificate of Eligibility for GP Registration (CEGPR) through the specialty equivalence route. The report states at paragraph 102: Care must be taken to ensure that the rules regarding admissibility of evidence of competence and performance within the CCT process must also apply to the use of that same evidence within the alternative routes. Thus, if the shelf-life for an examination within a CCT is set at a particular point an applicant who is unable to use the examination as evidence for progression towards a CCT should also be unable to rely on that examination evidence as the means of demonstrating competence for the purposes of a CESR/CEGPR. Similarly, an individual who has demonstrably failed to pass an examination required as part of the CCT must be required to provide compelling and overriding alternative evidence to offset the previous evidence of failure. 23. Council agreed to endorse the report and the recommendations. So Council expects that rules on evidence of competence and performance for a CCT must also apply to alternative routes to Specialist and GP registration. The rule in relation to entering or re-entering an approved training programme within seven years of passing an examination cannot apply to the alternative routes for candidates outside training programmes. But rules in relation to the number of attempts or the period of time to complete all parts of a specialty examination should apply whether the examination is intended to count for a CCT or for a CESR/CEGPR. We intend therefore to pursue this matter further with the colleges and faculties and to amend the webpage to make reference to Council s decision. Recommendation: To note that the GMC Council has decided that rules regarding admissibility of evidence of competence and performance within the CCT process must also apply to the use of that same evidence within the alternative routes to Specialist and GP registration. Resource implications 24. There are no resource implications for the GMC beyond monitoring the progress of the royal colleges and faculties and ensuring that appropriate information is published on the GMC website. Some opportunity costs will be borne by royal colleges and faculties in developing their arrangements. 6

7 Equality 25. As the GMC webpage states: The requirements are not absolute and will be applied flexibly. This should help to avoid circumstances in which the requirements would otherwise adversely impact on particular categories of candidate. Communications 26. This paper will be published on the GMC website. The GMC intends to revise the webpage to incorporate links to pages on the websites of royal colleges and faculties where specialty-specific information is available. 7

8 7 - Specialty examinations - currency and number of attempts Annex A National professional examinations Context What's happening Expectations about the currency of examinations Expectations about the number of attempts at examinations Background documents Context In order to grant a Certificate of Completion of Training (CCT), we must be confident that the doctor has demonstrated the competencies set out in the specialty curriculum through assessments including national professional examinations. We approve specialty assessment systems and consider the assessments in light of our Standards for Curricula and Assessment Systems. We need to go further to satisfy ourselves and assure the public that CCTs are awarded only where doctors have met our standards and requirements for postgraduate medical education and training. So, we will need to be assured that past success in passing an examination is accepted as current when entering or re-entering a GMC-approved training programme. In addition, we will need to be confident that the doctor genuinely has the competencies indicated by the pass. The pass should not follow a long run of fails at the same examination. What s happening At our request, the Academy of Medical Royal Colleges has set expectations for the currency of examinations and the number of attempts. We have endorsed these expectations. They apply to both national professional examinations and to the separate Parts of the examinations. A1

9 The expectations set minimum requirements. Each royal college and faculty is welcome to set more stringent requirements for its own examinations in relation to currency and the number of attempts allowed. The royal colleges and faculties are developing their procedures to ensure that they meet our requirements or go further in relation to currency and the number of attempts. Expectations about the currency of examinations An examination may be taken before the candidate enters the relevant GMC-approved training programme or when they are on a break in the programme. In this scenario, the pass will be considered current as long as the candidate enters or re-enters the programme within seven years of passing the examination and satisfies any other currency requirements determined by the relevant royal college or faculty. These expectations are not absolute and will be applied flexibly. In individual cases, a royal college or faculty may undertake a detailed review of the circumstances and allow examinations to be counted which fall outside the expectations. The royal colleges and faculties may also wish to ensure that examinations taken during training programmes remain current and that long gaps do not occur that cast doubt on their currency. They can provide further information on their requirements. A pass in an examination taken after completing a training programme will not be acceptable for a CCT. In that situation, doctors may be able to demonstrate equivalence via the CESR or CEGPR process. Expectations about the number of attempts at examinations No candidate will normally be allowed more than six attempts at an examination. Following six failed attempts, a candidate must provide evidence of additional educational experience to the royal college or faculty for each re-sit. The royal colleges and faculties will determine what sort of evidence will count. But those evidence requirements must apply to all candidates, including those not currently in GMC-approved training programmes. Background documents Postgraduate Board paper - 17 January 2012 o Operational report (pdf) Postgraduate Board paper - 22 November 2011 o National Professional Examinations - Proposals from the Academy of Medical Royal Colleges (pdf) A2

10 Postgraduate Board paper - 20 April 2011: o National Professional Examinations - Outcomes of the Consultation (pdf) o Annex A - Responses to the consultation on the national professional examinations (pdf) GMC statement - 10 September 2010 (pdf) Joint statement - 8 July 2010 (pdf) GMC statement - 18 June 2010 Legal advice - 2 June 2010 (pdf) A3