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Whether you view it as a genuine motivator to improve standards and refine practice or an unnecessary burden, for now at least, revalidation appears to be here to stay.

Finally implemented in 2012 after many years of being mooted, the system requires all licensed doctors and GPs to be revalidated by the General Medical Council every five years.

Relying heavily on evidence gathered during the annual appraisal process, revalidation involves amounting 360 feedback, continuous professional development, explanation of significant events and evidence of reflection.

What is revalidation?

Revalidation is an evaluation of a doctors’ fitness to practise and a legal requirement to maintain a licence to do so.

The General Medical Council says it revalidates doctors to keep standards of care high and demonstrate doctors are up-to-date and competent.

Every doctor must revalidate every five years and provide evidence that knowledge is current, they are fit to practice, there are no outstanding concerns about them or their work and they provide good standards of care.

Revalidation is awarded by the General Medical Council (GMC) and is based on submissions made to it.

How does GP revalidation work?

For the majority of doctors the decision is based on the recommendation of a ‘responsible officer,’ who is usually a senior doctor within the applicant’s organisation. The responsible officer relies on annual appraisals and any other relevant information to make the recommendation.

In cases where a ‘responsible officer’ is not available, another senior doctor, known as ‘suitable person,’ can make the recommendation. When neither a ‘responsible officer’ nor ‘suitable person’ is available, an annual return can be completed by the applicant and a written knowledge test may be required.

What are doctors’ responsibilities in relation to revalidation?

The General Medical Council’s Guidance for doctors: Requirements for revalidation and maintaining your licence outlines the responsibilities doctors have in relation to revalidation.

They include the necessity to fully engage with the process of annual appraisals and collect evidence on a day-to-day basis.

Also on the list are:

  • Identify your designated body and responsible officer, or suitable person. Or inform GMC you don’t have one. There is a GMC tool to help you find out if you have a connection to a designated body or suitable person.
  • Collect suitable supporting information
  • Have an annual appraisal (or engage fully with your training programme if you are a
  • doctor in training) which covers your whole scope of practice.
  • Reflect on, and discuss with your appraiser, the supporting information you have
  • Collected.
  • Keeping your connection details up to date in your GMC Online account

A 2018 summary of changes by the Royal College of General Practitioners noted that locums must provide contact details of all the practices where they have worked as part of the process.

Necessary supporting information for revalidation

For revalidation to be successful six types of supporting information are required.

They relate to:

  • Continuing professional development
  • Quality improvement activities
  • Significant events
  • Feedback from patients or those to whom you provide medical services
  • Feedback from colleagues
  • Review of compliments and complaints

More information is available via the GMC’s ‘Guidance on supporting information for appraisal and revalidation’.

How long does preparation for revalidation take?

The amount of time necessary to commit to appraisals and evidence gathering for revalidation can be a controversial topic, with some GPs feeling the burden is too high.

Supporting information for appraisal and revalidation should be focused on quality rather than quantity of supporting information, according to the RCGP.

The guide ‘RCGP Mythbusters – Addressing common misunderstanding about appraisal and revalidation’ says: “We recommend that the final stage of organising the supporting information and completing your portfolio before your appraisal should take no more than half a day, around 3.5 to 4 hours. This is based on the original financial provision for annual appraisal, which was for one day of activity, half to prepare and half to have the appraisal discussion.”

It advises supporting information should be added to your portfolio on a day-to-day basis rather than retrospectively, which would prolong the process.

What recommendations can be made regarding revalidation?

When you have a responsible officer or suitable person to make a recommendation on your revalidation, as is usually the case, there are three options available to them.

They are:

  • Recommendation to revalidate
  • Recommendation to defer
  • Recommendation of non-engagement.

Recommendation to defer revalidation

There are two instances when a recommendation to defer is appropriate, those being:

  • Where, due to reasonable circumstances, it has not been possible for collection and reflection on all of the required supporting information. Reasonable circumstances include parental or carers leave, a sabbatical, a break from practice, or sickness absence.
  • An ongoing HR or disciplinary process

A recommendation to defer revalidation does not imply any judgement about a doctor’s fitness to practise and is not publicly available or published.

Recommendation of non-engagement for revalidation

This is the recommendation when a responsible officer or suitable person feels there has been either a failure to meet requirements or to sufficiently engage with the revalidation process.

When a recommendation of this type is received, the GMC will:

  • Write to the doctor concerned to inform them
  • Give the opportunity for representations to be made
  • If representations are made, refer them back to the responsible officer or suitable person for consideration
  • Consider deferring revalidation if efforts are made or representations show efforts to engage in the process

Outcomes and appeals in relation to GP revalidation

Where the GMC revalidates a licence there is no change to it and the rolling process continues with a new revalidation date set (usually five years in the future) and a need for ongoing annual appraisals and engagement with the process.

A decision to defer revalidation means you continue to hold a licence and can practise as normal and a new date for revalidation will be set.

If the GMC is considering withdrawing a licence it will notify of the reasons and allow 28 days for representations to be made. There is a right to appeal if a licence is withdrawn.

Concerns and questions around the revalidation process

Revalidation is a legal process and requirement for all doctors wishing to practise in the UK.

We offer specialist legal advice and representation, a telephone advisory service, training packages, workshops and courses for GPs.

Do contact us for further information.