Annex III General Medical Council and General Dental Council revalidation schemes
1 GMC scheme
In 2000, in the wake of a range of well-known scandals and instances of egregious behaviour by doctors, the GMC voted by a substantial majority to commence work on creating a revalidation scheme for the whole profession. After much debate and revision the GMC model that is now being implemented builds on the distinction between registration, obtaining a licence to practise, and periodic revalidation of the licence.
The licence to practise is separate from registration. The licence gives doctors authority to undertake certain activities, such as prescribing and signing statutory certificates, which the law restricts to licensed doctors. It also obliges doctors to be familiar and comply with the current Good Medical Practice standards. Licences are generic (not activity-based) and so do not restrict doctors to work in a particular specialty or field of practice. Revalidation of an individual’s licence is functionally separate from the disciplinary process concerning fitness to practice which may affect registration under s.29 of the Medical Act 1983. However, concerns at revalidation may trigger a fitness to practise investigation, and, if necessary, lead to de-registration.
Revalidation operates on a five-year cycle, drawing on evidence doctors have gathered about their performance over the preceding five years. It is thus a process rather than point-in-time ‘test’. Revalidation is appraisal-based, and thus tied in with local management and appraisal systems. It requires doctors to undertake regular appraisal and compile a portfolio of supporting information which demonstrates how they are meeting the professional values and principles set out in the Good Medical Practice standards. This requires evidence across the four assessed domains: knowledge, skills and performance; safety and quality; communication, partnership and teamwork, and maintaining trust (GMC, 2011).
Revalidation decisions are made by the GMC on the basis of recommendations from each doctor’s ‘responsible officer’ (normally the medical director appointed for the employing organisation, such as a primary care trust or hospital). The responsible officer makes their recommendation on the basis of each doctor’s appraisal record and portfolio of evidence. The approach taken by the scheme is essentially a 360° feedback model, drawing on six categories of evidence:
- CPD activity;
- Quality improvement activity (eg audit);
- Significant events (ie critical incident analysis where something has gone wrong in the care of a patient);
- Feedback from patients;
- Feedback from colleagues;
- Review of compliments and complaints.
The Responsible Officer may recommend revalidation or deferral of the decision to revalidate, or notify the Registrar of the GMC that s/he cannot recommend revalidation. The final decision rests with the GMC. The Registrar has powers to request further information or hear representations from the practitioner, and may also refer any question arising from revalidation to a GMC Registration Panel for advice.
2 GDC model (proposed)
(GDC, various dates)
The GDC is reviewing its CPD requirements in the context of an overall move towards a revalidation process (see GDC, various dates), which, from 2014, will include assessment around four topics: clinical; communication; professionalism, and management and leadership.
The details of the scheme are still under consultation, but proposals at this stage indicate that the GDC is also considering an evidence-based approach in which dentists will need to gather supporting evidence to demonstrate competence against a set of standards over a five-year cycle. The framework will specify the evidence which will be acceptable, though it is anticipated that one item of evidence may demonstrate compliance with more than one standard. Evidence must be checked by an independent ‘approved external verifier’, and it is anticipated that the verification function may be met by both commercial organisations (approved by the GDC) and public bodies. It is proposed that verification will include a mechanism such as a practice inspection or individual performance appraisal, and existing voluntary quality schemes may be adaptable for this purpose. Evidence is likely to include patient feedback on individual dentist performance through validated questionnaires (eg on areas where only patient data provides clear evidence, such as informed consent to treatment).
The GDC model proposes a three stage re-validation process:
- A compliance check, which will apply to all dentists who must submit a declaration of compliance; there will be a random audit to check the veracity of declarations. In the random audit, the GDC will ask dentists to send in the certification from the approved external verifier, as evidence that their compliance with standards has indeed been checked;
- A remediation phase, which will provide an opportunity to dentists who do not pass Stage 1 to remedy deficiencies;
- An in-depth assessment, which will apply only to dentists who fail to demonstrate their compliance at the end of the remediation phase.
 Registration without a licence enables doctors to retain GMC registration, and to undertake activities not legally dependent on holding a licence: eg using the title ‘doctor’, practising overseas (subject to local licensure), non-clinical lecturing or research, or providing medical or medico-legal reports.
 This structure is set to change in the context of current reforms to the organisation of the health service, but the principles will remain the same.