Revalidation for doctors in postgraduate training with Health Education East Midlands
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Revalidation is a GMC process that gives doctors a with a licence to practise positive affirmation of their fitness to practise based on assessment of evidence. This process gives reassurance to patients, the public and colleagues of a doctor’s suitability to work in their profession to the standards expected in the UK.
Yes. Revalidation has existed for post-training doctors for several years, and as of 3rd December 2012 has now come into effect for doctors in training who hold a full licence to practise (i.e. Foundation Year 2 and above). Since that date, fully licenced trainee doctors have been required to provide evidence for their revalidation to the Responsible Officer at their Designated Body, which forms part of their appraisal process and informs the Responsible Officer’s recommendation to the GMC about the doctor’s revalidation. The GMC is in discussions about applying revalidation to FY1 doctors as well, though this has not yet been determined.
For all non-military* doctors in a training programme (i.e. doctors holding a National Training Number) who hold a full licence to practise, your ‘Designated Body’ for revalidation is the Deanery/Local Education and Training Board (LETB) for the region of England or for the devolved nation in which you are working. The ‘Responsible Officer’ for revalidation for trainees is the Postgraduate Dean at that Designated Body.
So for trainees in the East Midlands, your Designated Body is Health Education East Midlands (HEEM) and your Responsible Officer for revalidation is the Postgraduate Dean, Professor Sheona MacLeod. HEEM’s Revalidation Team work under Professor MacLeod to handle the administration of revalidation for the three and a half thousand trainees in the East Midlands.
*For military trainees, your Designated Body is the Defence Postgraduate Medical Deanery, though copies of appraisal evidence and documentation may also be required by your regional LETB/Deanery. Your Responsible Officer for Revalidation is the Defence Postgraduate Medical Dean.
It is important to remember that your revalidation is ultimately your own responsibility. The HEEM Revalidation team will work to request information from you when required and process your revalidation recommendation to the GMC in good time, but you should be aware of the process and check that it is happening if your revalidation date is less than 2 weeks away.
The HEEM Revalidation team will contact you by email at certain times of the year (usually April and October) approximately two months before your ARCP to request that you complete a self-declaration form (Form R part B) about scope of practice, time out of training, significant events, complaints, compliments, and honesty & integrity. It is important that you complete the self-declaration form by the deadline requested, or it may not be processed in time for your ARCP, which means you could receive an Outcome 5 in your ARCP (insufficient evidence provided) or ultimately a non-standard outcome. Persistent failure to engage with the revalidation process will be flagged to the GMC and could jeopardise your licence to practise. For this reason, it is vital that you keep your Designated Body updated with your current email address and check it regularly. Failure to do this will not be accepted by HEEM or the GMC as an excuse for non-engagement.
Once HEEM has received your completed self-declaration form, this will be processed and the information will be provided to your ARCP panel as formal evidence. The panel will use this evidence, along with all other evidence reviewed in the ARCP, to make a comment on your ARCP form about your fitness to practise. Such a comment is made each time you have an ARCP and recorded by the HEEM Revalidation team. If concerns are raised that have an immediate effect on patient safety, they will be flagged to your employer and your Training Programme Director (TPD) will put measures into place to address this. If concerns are raised that are not a direct threat to patient safety but may develop into serious practise concerns, these will be recorded by the HEEM team and reviewed by the Dean (or an Associate Dean linked to revalidation on her behalf). Once your revalidation date comes around, the Dean (as Responsible Officer) or her delegates will review the comments made by panels since your last revalidation (or since enrolling if you have not had a revalidation yet) and determine whether or not a positive recommendation should be submitted to the GMC for your revalidation.
There are three different submissions that the Postgraduate Dean can make to the GMC. These can only be made once you are ‘Under Notice’, i.e. within 120 days of your revalidation submission date. The three options are:
1) A POSITIVE RECOMMENDATION. This means that the Responsible Officer has determined that there are no known current concerns about your fitness to practise based on the information that has been made available to the LETB and ARCP panels. It is not only trainees receiveing a standard outcome (Outcome 1, 7.1 or 6) who can receive a positive recommendation for revalidation. You may not have progressed sufficiently in your training programme to proceed to the next level, but could still be fit to practise as a doctor at your current level, for example.
2) A DEFERRAL. You may receive a deferral for two reasons: administrative or due to concerns.
An administrative deferral simply means that there is not enough evidence at the current revalidation date to make a positive recommendation, but this is not necessarily a negative reflection on your practise or provision of evidence. For example, the GMC has guidelines about when a trainee should revalidate (see section ‘When do I need to be revalidated?’). If your revalidation submission date is coming up soon but you are not ready to revalidate under these criteria, then we will simply submit one or more deferrals for you until you are. HEEM can only defer a minimum of 120 days (approx. four months) and a maximum of 1 year, so you may need to be deferred several times during your training programme.
A deferral due to concerns is when the Responsible Officer cannot confidently submit a positive recommendation for revalidation because there are unresolved concerns about your fitness to practise. These may be complete or incomplete investigations being held by your employer or former employer, for example. In this instance, your revalidation submission date would be deferred until a point where this issue is likely to have been resolved by other employer/LETB/GMC processes (which may require subsequent deferrals if this takes longer than anticipated).
3) NON-ENGAGEMENT. The Responsible Officer can use this option to inform the GMC of a trainee’s persistent failure to engage with the requirements of revalidation, such as not submitting the self-declaration form. This is usually used as a last resort but the decision about this rests with the Responsible Officer.
Like the educational outcome of the ARCP process, the fitness to practise comment made by the panel reflects the panel members’ professional judgement and opinion based on written evidence presented at that panel. However, unlike with the educational outcome, the FTP comment is not subject to a structured appeal process in the same way. The FTP comment is based on professional judgements and opinions and only informs the Responsible Officer’s submission to the GMC. It is not a ‘final’ decision and so cannot be challenged in the same way that an educational outcome can. The Responsible Officer is not obliged to submit a submission pursuant to the panel’s comment if she feels that it is not a fair and reasonably complete reflection of the trainee’s fitness to practise, or if more investigation and evidence are required to inform the submission than was available prior to the panel. If a trainee has reason to believe that the fitness to practise comment made by the panel is unreasonable, the trainee can contact the HEEM Revalidation team to discuss this, and if appropriate, it will be raised to the Responsible Officer for further review or investigation.
Equally, the Responsible Officer’s submission to the GMC is also not subject to a structured appeal process in the same way. This, too, is based on the professional judgements and opinions of the Responsible Officer based on all the evidence available to her; and once again it is not a ‘final’ decision and so cannot be challenged in the same way that an educational outcome can. The GMC makes the final decision about a trainee’s revalidation based on the Responsible Officer’s submission and any other evidence it has available to it, but again it is not obliged to make a decision pursuant to the Responsible Officer’s submission if the assessing panel feel that it is not a fair and reasonably complete reflection of the trainee’s fitness to practise, or if more investigation and evidence is required to inform the final decision than was available to the Responsible Officer at the time that she made her submission. If a trainee has reason to believe that the fitness to practise comment made by the Responsible Officer is unreasonable, the trainee can contact the GMC directly on 0161 923 6277 to discuss this, and if appropriate, it will be raised to the appropriate department of the GMC for further review or investigation.
As explained above, it is important to remember that your revalidation is ultimately your own responsibility. Revalidation is a GMC requirement so you should familiarise yourself with the process and ensure that you are meeting the requirements of it.
The main practical concerns for you as a trainee are:
- ensure that your ePortfolio is kept up-to-date and that you are meeting all the requirements of your school/college curriculum and training programme
- keep HEEM and your TPD updated with your current contact details, as required by your training agreement
- return the Form R self-declaration to HEEM when requested to do so by HEEM, and meet deadlines set for this. (See section ‘Form R’).
Remember that some of these requirements may still apply to you even if you are on OOP, Maternity Leave or long-term sick leave. If you are unsure, please contact the HEEM Revalidation team to discuss your particular situation.
Doctors in training in the East Midlands will be eligible for a revalidation submission to made to the GMC at all of the following times that apply:
- After holding your full licence to practise for five years since trainee revalidation was introduced in December 2012
- Five years after your previous revalidation, if your training programme is long enough for this.
- At the end of your Core Medical Training or Core Surgical Training programme in ‘uncoupled’ training specialties, if applicable.
- At the point of eligibility for Certificate of Completion of Training at the end of your higher specialty training. This submission would be made to the GMC after your final ARCP outcome is confirmed and before your CCT date.
- Upon release from training (Outcome 4)
- At the time of your GMC-assigned revalidation date, as long as this is not anticipated to be within one year of any of the above criteria.
After you are revalidated by the GMC and leave training, you will begin a five year cycle of revalidations, though evidence for these will still be gathered every year during that cycle, as before.
The GMC writes to each trainee by letter and by email to inform them of their revalidation date. If you have not had this letter or have misplaced it, you can log in to your GMC online account (GMC Connect) and go to the ‘My Revalidation’ section. Here you will find information on when your revalidation submission date is and who your Designated Body and Responsible Officer for Revalidation are. You can also change your Designated Body here if it is incorrect, though you may wish to contact your current/supposed Designated Body first to check that you need to change or that it is not too soon to do so. Do not change your Designated Body until you are actually working there or have actually left there.
The GMC can change this date for you if your Designated Body requests it. You cannot make this request yourself. Please contact the HEEM Revalidation team if you think your revalidation submission date is incorrect and needs changing. (See ‘Contacts’ section at the bottom of the page).
Please see the ‘Contact’ section.
- What is the self declaration form?
The self-declaration form is completed by trainee doctors. It is different to the annual 'Demographic Information' form (the Form R Part A), which asks for personal and contact information that is used to maintain our database.
The self-declaration form (Form R Part B) asks for information about your recent scope of practice, time out of training, and declarations relating to revalidation. This information informs the ARCP Panel's comment on your fitness to practise, which in turn informs the Dean’s recommendation to the GMC about your revalidation.
- Why do I need to fill in the self declaration form?
The self-declaration form is part of the evidence required for your ARCP and revalidation. It will be requested from you twice annually, even if you are on an Out of Programme (OOP) rotation.
- When do I need to fill in the self declaration form?
As part of the revalidation process, your regional Deanery or LETB (Local Education & Training Board) will collect a self declaration form from you twice annually during your training programme.
Soon, we will have an electronic system where you can log in to complete the Form R online. Until this is implemented, all trainee doctors will need to submit their COMPLETED AND SIGNED Form R by downloading a copy of the editable PDF form and submitting it to firstname.lastname@example.org
- How do I fill in the ‘Form R (Part B)’?
As well as asking trainees for a self-declaration (the Form R Part B), the HEEM Revalidation team will also request a report twice annually from each of your employers since your last ARCP. This report asks about similar areas to the self declaration form, such as unresolved significant events/SUIs, complaints and investigations. For any trainees where there are concerns, an Exception Exit Report (containing more information about the concerns) will be completed by the DME or appropriate delegate at the employer and returned to the HEEM Revalidation team for submission to the ARCP panel as evidence. For each trainee who has an Exception Exit Report completed for them, the HEEM Revalidation team will forward a copy of this report to the trainee by email with instructions about how to comment on or refute formally any information in it for the ARCP panel’s information.
If you move to another region during your training programme (IDT or Inter-Deanery Transfer), similar processes to these will be continued by that region's Deanery/LETB. Please ensure that you log on to your GMC Connect account, go to ‘My Revalidation’, and change your Designated Body for Revalidation from Health Education East Midlands to your new Deanery/LETB/Designated Body. You should also familiarise yourself with your new Designated Body's revalidation and appraisal policies.
- If you undertake an OOP (Out of Programme) status within the training programme for reseach, experience or career break, or take maternity leave, you will still hold your National Training Number with HEEM and we will still remain your Designated Body for Revalidation.
- Many trainees take a year or two out of training to go overseas, often before starting Core or Higher Specialty Training, on an OOPC (Career Break). Unless your work overseas specifically requires that you hold a UK GMC Licence to practice, the GMC recommend that you downgrade from a licence to just 'registered' status. If you have a look at their website (http://www.gmc-uk.org/doctors/fees.asp - under 'Annual retention fees' ) this costs only �£145 instead of �£390, and (barring any major concerns about your fitness to practice) it is a very straightforward process to reinstate your licence when you return. Reinstating usually takes less than 14 days and is free if you held a licence previously. (Note that the 'Restoration Fee' of �£300 is only charged for restoring licences that have been taken away from doctors involuntarily after investigations, etc., not for reinstating a voluntarily relinquished licence.) If you relinquish your full licence and are just registered, you do not need to be Revalidated anymore. Once you reinstate your full licence, you would be assigned a new Revalidation date by the GMC. This would probably be a year or more after the date of your reinstatement so that your new Designated Body has time to gather evidence of your performance and fitness to practice.
Visit http://www.gmc-uk.org/doctors/revalidation/13728.asp for more information. In the last paragraph of the third question down there are links to information about giving up and restoring your licence, which may be a better and cheaper option for you if you're going to be out of medical employment in the UK at the time of your next GMC-assigned Revalidation date.
- If you return and apply to a new core or higher specialty training programme, you need to decide whether or not you want to use your time worked overseas as experience in your application.
- If you do wish to use this experience as part of your application, you will need to keep any important documentation (e.g. appraisals, sign-offs, contracts, letters confirming appointment, and other similar things). There are no specific guidelines as everyone’s overseas work experience varies so much, so try to keep anything (documents or emails) that you think might prove useful in an application. There is no structured portfolio system for this, so you can just keep the documents/emails and bring them back with you, or if you still have access to do so, upload them to your ePortfolio.
- If you do NOT wish to use this experience as part of your application, you do not need to keep any evidence, though it wouldn’t be detrimental your interview to demonstrate that you’d been working whilst overseas if this is the case.
- If you leave your training programme and go into employment, your Revalidation will be undertaken by your new Designated Body, which will be the Hospital Trust/Employer where you take up work. Once again, please ensure in this case that you log on to your GMC Connect account and change your Designated Body for Revalidation once you have started work there.
- If you leave the training programme and start work as a locum appointed to service (LAS), you would have a new Designated Body. This would be either your locum agency if it is one of the few big ones on the GMC’s list of DBs, or more likely the hospital Trust where you start work. In this case your new DB will need to tell you what they require from you in terms of appraisal and evidence of CPD for the purposes of Revalidation.
- IF you start work in a non-locum staff grade service post (e.g. a permanent or rolling contract), your new DB will need to tell you what they require from you in terms of appraisal and evidence of CPD for the purposes of Revalidation.
- If you leave your training programme and do not go into employment, the GMC will instruct you in what you need to do as you approach your Revalidation date. You can call the GMC Contact Centre on 0161 923 6277.
The most important thing to do, whether you go on a career break in the UK or overseas, or remain in work, is to keep a regular eye on your emails and keep your LETB / Designated Body updated with any changes to your contact information, in case it is necessary to contact you about a matter relating to your Revalidation, assessments, etc.