18 March 2013 Strategy and Policy Board 5 For decision Establishing a Regulatory Framework for Credentialing Issue 1. In 2012 Council agreed that the GMC should develop a regulatory framework for introducing credentialing. The Board is invited to agree how that work should be taken forward. Options 2. The options are: a. Option A: Establish a stakeholder working group with an external chair to develop a regulatory framework for credentialing (terms of reference at Annex A). b. Option B: Invite the Education and Training Advisory Board (ETAB) to lead work on credentialing. Recommendation 3. The Strategy and Policy Board is asked to choose between the options as above.
Issue Background 4. In December 2008 the Department of Health (England) invited PMETB to lead exploratory work on the concept of credentialing. A PMETB-led Steering Group (which included GMC representation) was established to take forward this work. The Credentialing Steering Group (CSG) defined credentialing as: a process which provides formal accreditation of attainment of competences (which include knowledge, skills and performance) in a defined area of practice, at a level that provides confidence that the individual is fit to practise in that area in the context of effective clinical governance and supervision as appropriate to the credentialed level of practice. 5. The CSG published its report in April 2010. 1 6. Following the merger of PMETB with the GMC in 2010, the GMC agreed that the feasibility of credentialing should be piloted in three areas of practice where there was no formal specialty recognition leading to a CCT or sub-specialty. 2 The three areas to be piloted were breast disease management, forensic and legal medicine, and musculoskeletal medicine. In the light of the pilots, in July 2012 Council agreed in principle that a regulatory framework for credentialing should be established, subject to the outcome of further developmental work. 7. Since Council s 2012 decision, other developments have continued to push credentialing up the regulatory agenda. First, the subject has featured prominently in the work of the Shape of Training review consultation process, where many respondents see it as a means of recognising doctors areas of competence which will benefit employers, patients and individual doctors. Second, we anticipate that the development of credentialing will be among the recommendations of Sir Bruce Keogh s current review of the regulation of cosmetic interventions. Third, the completion of the pilots has raised expectations among those involved that we will now press ahead with credentialing. Credentialing Workshop 8. On 21 January 2013 we held a stakeholder workshop on credentialing. Its purpose was to inform stakeholders of our plans and begin to explore some of the issues that we will need to address in developing a regulatory framework. This would help to provide the political and policy foundations for the detailed work ahead. 9. The workshop was successful in establishing a broad consensus of support for our plans. There remain, however, many detailed policy and operational questions to 1 http://www.gmc-uk.org/csg_report_april_2010.pdf_34123082.pdf 2 GMC Council Minutes, 8 December 2010, paragraph 7. 2
be answered before we are in a position to introduce credentialing. The aim of this paper is to secure agreement on how we take this forward. Options Option A: Establish a stakeholder working group with an external chair to develop a regulatory framework for credentialing. 10. Our preferred option is to establish a time limited stakeholder working group to support us in the detailed policy work. Though much of this work will be of a technical nature, the subject matter engages a range of interests; employer needs, patient protection, professional recognition and career progression, education and training and registration, among others. If our work is to have credibility we need to involve these key interests in any group we establish. 11. Credentialing is also a politically sensitive issue. In the past, the appetite for, or opposition to, credentialing has varied widely depending on how different groups have interpreted the credentialing agenda. One way of balancing these competing agendas would be for the group to be chaired from within the GMC executive. However, we feel that recent experience with, for example, the reviews of CESR and PLAB suggests that with an issue of this importance and external profile it is preferable to seek a senior external figure outwith the GMC who can act as an honest broker and bring together the key interests. 12. We therefore propose establishing a stakeholder working group with an external chair under the terms of reference shown at Annex A. The group would be accountable to the Strategy and Policy Board and its final proposals would be submitted to the Board for approval. 13. We envisage that the group would need to meet approximately six times over the next 12 months. The estimated cost would be around 7,000 plus expenses. This would include the cost of a further stakeholder seminar. It does not include the cost of any further piloting or implementation. Option B: Invite the Education and Training Advisory Board to lead work on credentialing 14. The alternative to establishing a credentialing working group would be for the ETAB to lead the work. While this would enable us to engage with many of the key interests, the ETAB would not be able to meet with the frequency or with the necessary focus on credentialing for us to progress the work. However, if we use a separate working group as proposed in option A, ETAB would be kept informed of progress and its views sought on key issues. 3
Supporting information How this issue relates to the Corporate Strategy and Business Plan 15. Strategic aim 1: To continue to register only those doctors that are properly qualified and fit to practise and to increase the utility of the medical register. 16. Strategic aim 2: To give all our key interest groups confidence that doctors are fit to practise. 17. Strategic aim 3: To provide an integrated approach to the regulation of medical education and training through all stages of a doctor s career. How the action will be evaluated 18. The conclusions of the credentialing working group will be evaluated first through its accountability to the Strategy and Policy Board and then through public consultation on its proposals. How the issues differ in relation to healthcare management and administration and/or legislative provision and/or regulatory structure in each of the four countries 19. The issues are not fundamentally different across the four countries of the UK. However, from our preliminary work on credentialing (as well as from the Shape of Training review) there is evidence of considerable appetite for credentialing in the other countries. This is particularly noticeable among employers in Scotland and England and in the Scottish government. What equality and diversity considerations relate to this issue 20. Credentialing is a potential means of recognising the competences of groups such as staff and associate specialist doctors (SAS grades) who do not hold CCTs. This was the strong view of the SAS grade representatives at our credentialing workshop in January 2013. Within the SAS population, women and international medical graduates tend to be over-represented. 21. It should be noted, however, that others at the workshop questioned the use of credentialing to enhance recognition of SAS doctor competences, fearing that this would lead to the dismantling of the CCT. 22. The credentialing project will, therefore, need to address these different viewpoints and develop a framework which enhances public protection while ensuring that eligibility for credentialing and the assessment framework it employs is fair and accessible for all groups. If you have any questions about this paper please contact: Richard Marchant, Assistant Director, Regulation Policy. Email: rmarchant@gmc-uk.org; Tel: 020 7189 5024 4
5 Establishing a Regulatory Framework for Credentialing Annex A Draft Working Group Terms of Reference Background 1. In December 2008 the Department of Health (England) invited PMETB to lead exploratory work on the concept of credentialing. A PMETB-led Steering Group (which included GMC representation) was established to take forward this work. The Credentialing Steering Group (CSG) defined credentialing as: a process which provides formal accreditation of attainment of competences (which include knowledge, skills and performance) in a defined area of practice, at a level that provides confidence that the individual is fit to practise in that area in the context of effective clinical governance and supervision as appropriate to the credentialed level of practice. 2. The CSG published its report in April 2010. 1 The key conclusions were: Credentialing has significant potential for benefit because there is a strong need to articulate the nature of a doctor s practice and whether this meets national standards. Credentialing has the potential to complement revalidation for doctors providing specialist services. Credentialing could potentially provide trainee doctors with more flexibility to stop training at different stages, although this may be of interest to only a minority of doctors. Credentialing must be seen to be objective, reproducible, credible, validated and appropriate. 1 http://www.gmc-uk.org/csg_report_april_2010.pdf_34123082.pdf
There should be a further phase of work, a bottom up approach determining the need for and benefits of credentials including the development of pilots. 3. Following the merger of PMETB with the GMC in 2010, the GMC agreed that the feasibility of credentialing should be piloted in three areas of practice where there was no formal specialty recognition leading to a CCT or sub-specialty. 2 The three areas to be piloted were breast disease management, forensic and legal medicine, and musculoskeletal medicine. In the light of the pilots, in July 2012 the GMC s Council agreed in principle that a regulatory framework for credentialing should be established, subject to the outcome of further developmental work. Task 4. To: a. Define the purpose and characteristics of a model for regulated credentialing b. Describe the regulatory and related processes necessary to support delivery of the credentialing model. Principles to underpin the approach 5. The credentialing model must have regard to the following key principles: Patient and public interest: The primary and overriding consideration in the design of the credentialing model must be to ensure that patients and the public can have confidence in standards attained and maintained by credentialed doctors. Consistency and objectivity: The approach to credentialing must be capable of general application across different disciplines. Equality: Any proposed model must have regard to considerations of equality and diversity. Flexibility: The approach must support flexibility within the future workforce and potential changes to the healthcare systems of the UK. Proportionality: The approach developed must have regard to, and where possible, build upon existing regulatory structures A2
Themes and issues 6. In describing the model for future credentialing, the working group will address such issues as it considers pertinent, but this must include the following: Describing the purpose and characteristics of credentialing. Describing the standards for credentialing and the levels of practice signified. Describing the criteria to be applied for the recognition of credentials and how they should be prioritised. Describing the powers and privileges attached to holding a credential. Describing the future relationship between credentialing and sub-specialties. Describing the mechanisms for developing, approving, quality assuring and maintaining credentials. Set out proposals for how the development of credentials in different areas of practice should be funded and the costs of awarding credentials met. Describe the relationship between credentialing and revalidation. Set out proposals for how information about doctors credentials should be made transparent and accessible to patients, the public, employers and other key interests. Identify any legislative changes necessary to implement the proposed credentialing model. Identify the priority areas for developing credentialing. Outputs 7. The output of the credentialing project will be a report to the Strategy and Policy Board setting out recommendations in relation to the themes and issues referred to in paragraphs 4-6 above, and on such other matters as it identifies as necessary for the introduction of regulated credentialing. 8. Subject to the report being endorsed by the Board, its conclusions will form the basis of a public consultation by the GMC..Process: working group membership 9. The credentialing project will be undertaken by a working group drawn from members of the GMC executive (Education and Standards, and Registration and Revalidation) and representatives from key interests as listed below: A3
a. Working group chair appointed by the GMC s Strategy and Policy Board. b. Two representatives from the Academy of Medical Royal Colleges. c. One representative from employers. d. One representative from the Postgraduate Deaneries. e. One representative from SAS grade doctors. f. One representative from each of credentialing pilot groups. g. One trainee representative. h. One patient/public representative i. One representative from each of the UK administrations 10. The group may seek information and expertise from additional sources, as required. Working methods 11. To be determined by the working group. Accountability 12. The working group will report to the Strategy and Policy Board of the GMC. Timescales 13. The working group is expected to report to the Strategy and Policy Board 12 months from the date of its inception. A4