Guidance on appraisals and revalidation
The following guidance provides information and clarity on common questions relating to appraisal and revalidation.
The role of appraisal in the regulation of pathologists
You cannot choose your designated body or who your Responsible Officer is.
There is a strict hierarchy of connections set out in legislation. There are tools on the GMC website which will help you to identify which designated body you should be connected with. In exceptional circumstances, such as where you have a prior relationship (personal or business) with the Responsible Officer, there may be a perceived conflict of interest in you being connected to the Responsible Officer for your own designated body, in which case you should be assigned to an alternative Responsible Officer.
If you work in a managed environment, in an organisation that does not have designated body status, there might be a Suitable Person, who is somebody who undertakes a similar role to a Responsible Officer and can provide the GMC with a revalidation recommendation about you.
Appraisal is not a pass/fail assessment.
Appraisal is, or should be, part of a formative and developmental process. It provides an annual chance to reflect with the help of a trained appraiser, in protected time. Beyond helping you to collect a portfolio of supporting information that meets your needs and enables your Responsible Officer to make a recommendation to revalidate, it is about facilitating your reflection and encouraging you to consider your personal and professional development needs and how best to meet them.
Appraisal should always include support, encouragement and stimulation; it is a valuable protected time with a trained peer to look back over the past year and review achievements and challenges and to look forward and plan for the coming year in the light of any aspirations you may have and any needs relating to the context in which you work.
The reflective process that is central to appraisal has an important role in helping us all to think about what has happened and to look for learning, recognising both what went well – those things we should try to do more of or share – and any areas for development, or that we find challenging – those things we should try to improve or change. The support of a trained appraiser can facilitate the process and help us in working out how to address learning needs before they cause any concerns. If any shortcomings in the portfolio of supporting information are identified, these should be addressed in a supportive way and plans to overcome them should be included in the agreed PDP.
Appraisers do not have the authority to make a decision about your revalidation recommendation.
Their role is to facilitate your reflection, support and stimulate your development and help you present an appropriate portfolio of supporting information for your Responsible Officer to consider. Part of their role is to provide a comprehensive summary of the evidence supplied to represent you to the Responsible Officer and show that you are complying with the requirements for revalidation.
Your Responsible Officer has the statutory responsibility for making a revalidation recommendation to the GMC. Their decision is based on their determination about whether you have sufficiently engaged in annual appraisal, provided a portfolio of supporting information that meets the GMC requirements, and whether there are any outstanding concerns for any part of your scope of work.
The GMC will make the revalidation decision about whether to continue your licence to practise.
Supporting you to produce an appropriate portfolio that covers the full scope of your practice includes helping you to plan your professional development in such a way that enhances the quality of your professional work. Insufficient engagement is often around the quality of reflection and the relevance of the supporting information across the whole scope of work, so the appraiser is a valuable resource to help you improve the quality of the documentation of your reflection and ensure your portfolio contains relevant supporting information.
If I share my concerns about another doctor with my appraiser, will my appraiser will have a responsibility to deal with it and I won’t need to be the whistle-blower?
It is your responsibility, as the doctor who has first-hand evidence of a concern, to act in accordance with the GMC guidance ‘Raising and acting on concerns about patient safety (2012)’. Your appraiser should provide you with support and can signpost the correct steps for you to take, but it is your responsibility to raise the concern.
The GMC provides guidance on how doctors should act on a concern
In training, appraisers are reminded that they should not go beyond the limits of the appraisal role to adopt other people’s concerns. Third party information is not good evidence, and an appraiser could be open to criticism if they repeat something potentially defamatory or destructive without first-hand evidence. There is very little that the appraiser can take responsibility for (beyond signposting) if they have heard something ‘on the grapevine’ – or even in appraisal. The doctor with the concerns has a duty to report them. Doctors who are fit to practise are fit to raise a concern, and the correct route is not through the appraiser, although the appraiser is one source of support. All the appraiser can know as a fact is ‘I know that my appraisee Dr X has concerns about Dr Y’.
The Royal College of Pathologists recommends that appraisers record the fact that there has been a whistle-blowing discussion, and the actions agreed with the doctor, as an aide memoire for the doctor, and a record for the next appraisal, in the summary of discussion, without recording or summarising the substance of the allegations.
If the appraiser has significant concerns from the behaviour of the appraisee, that the original concern will not be acted on, the Royal College of Pathologists recommends that the appraiser provides written advice to the appraisee on what to do, copied to the person that they ought to be contacting (usually the Responsible Officer).
All medical appraisers should have been trained to start every appraisal with a confidentiality statement; everything discussed at an appraisal is confidential between the appraiser and the appraiser unless issues arise which may indicate a patient safety risk, in which case both appraiser and appraisee are bound by the GMC requirement to take appropriate action to safeguard patient safety.
The record of appraisal will also be accessible to your Responsible Officer (and/or Appraisal Lead, depending on how your Designated Body runs the process), because the Responsible Officer has to be able to confirm that an appropriate appraisal has taken place, with all essential elements covered, before making a revalidation recommendation. The Responsible Officer also has a duty to pass on any concerns about your performance or behaviour to your new Responsible Officer if you change employment.
Furthermore, some information discussed at appraisal may already be available to others by other routes; for example, your job plan will already be available to your local managers.
However, beyond this, appraisal documentation IS confidential. Unlike the appraisal process in most commercial settings, medical appraisal is NOT a management tool and the documentation should NOT be available to service managers - with the exception of the Responsible Officer, as explained above, who is committed to not divulging details of the information to other managers in your organisation. Appraisal documentation cannot be demanded by anyone else (with the possible exception of the court system, in exceptional circumstances).
Of course, as with any confidential personal information, you may choose to divulge it if you wish. For example, some release of appraisal information may be requested to allow practising privileged at private hospitals. However, it should be sufficient to offer evidence that your appraisal did indeed include a discussion of the work done at the private hospital; you are free to withhold or redact any information that is not relevant to that purpose.
Such requests for you to divulge appraisal information should be made subject to your informed and free consent. That means that the use to which the information will be put must be explained to you. It also means that there must be no element of coercion in making gate request. For example, it is not acceptable for you to be told that release of confidential appraisal information is essential or your laboratory will not gain accreditation, because that represents coercion.
Uploading certificates is not the only method whereby you can provide supporting information for your activities. You can provide a link to a website where there are details relating to the activity; you can provide a Digital Object Identifier (DOI), and you can write a short reflection of the activity stating what you learned.
The GMC requires doctors to provide appropriate supporting information across the whole of their scope of work that requires a licence to practise, not just clinical roles. You need to declare all parts of your scope of work and provide appropriate supporting information for each of them over the five years of the revalidation cycle. Your medical appraisal for revalidation has to cover your whole scope of work, including any roles outside the NHS for which you require a licence to practise. This should also include voluntary and unpaid work.
The Royal College of Pathologists recommends that you keep the documentation of your supporting information reasonable and proportionate while ensuring that you have demonstrated that you are up-to-date and fit to practise in every area of your work. Your appraiser is a resource to help you determine whether there are any gaps in your portfolio of supporting information and to support you in working out how best to fill those gaps.
Appraisers need to be trained and supported to provide whole scope of work appraisals and to facilitate reflection on supporting information from inside and outside the NHS.
Patient and colleague feedback
If you do see patients as part of your medical practice, no matter how briefly, you should attempt to collect feedback as recommended in GMC guidance. Examples might include a cellular pathologist taking fine needle aspiration samples as part of patient clinical management or a microbiologist assessing patients in an infection control role. Individual practice and the type or extent of patient involvement will vary within these groups. No standard model of patient feedback is likely to be applicable in all situations. However, the principle of attempting to secure patient feedback in all relevant circumstances is one that the GMC is keen to emphasise and is considered as important by patient representatives.
If appropriate, the College would encourage pathologists to adapt existing patient feedback questionnaires using the principles and guidance.
Any proposed questionnaire should first be discussed with your appraiser to ensure that it complies with your organisation’s relevant policies and GMC principles. They may be aware of other examples, be able to advise on how/when the feedback questionnaire should be used, or may not feel that patient feedback is applicable to your circumstances.
If you do not see patients as part of your clinical practice, you are not required to collect feedback from patients. Depending on your practice, you might want to collect multi source feedback from other service users.
The GMC questionnaires provide the template on which many appropriate patient and colleague feedback tools are now based. There is no GMC requirement to use the GMC questionnaires. They are not suitable for all patient / client groups, or accessible to all, and there may be better tools for your circumstances, whether they relate to a very specific scope of work, or a hard to reach group.
You do not need to use any tool in particular, unless that is a reasonable requirement of your employer; but you should choose one that is appropriate to your patient population and is accessible to all the different types of patient across your scope of work as far as possible. You should include feedback from at least the minimum number of patients required by the tool you choose to use.
The feedback should be gathered in such a way that the patients are entirely clear that their responses will be anonymous. The results should be externally collated into a report that gives you the feedback you need so that you can reflect on the results in preparation for your appraisal.
You only have to do one fully GMC compliant patient survey in the five year revalidation cycle.
My Personal Development Plan (PDP)
There is nothing that the GMC requires your PDP to include – your goals should derive from your appraisal as an individual and your specific needs. The GMC requires you to make progress with your PDP each year (or explain why that has not been possible) and reach agreement with your appraiser on a PDP for the coming year that arises from your appraisal portfolio and the appraisal discussion.
Your PDP should be personal, developmental and a plan for the future that meets your needs in the context within which you work. The Royal College of Pathologists recommends that you develop SMART (Specific, Measureable, Achievable, Relevant and Timely) goals with your appraiser.
Performance objectives should be part of job planning and not necessarily part of your appraisal and revalidation PDP unless you wish to include them. It often helps to work out how you can demonstrate that a change you plan as one of your PDP goals has made a difference by considering what the impact on patients will be.
The only PDP goals that are inappropriate are ones that are flippant, not specific to you, or irrelevant to your needs. Your appraiser will have been trained to help you work out how to write your PDP in such a way that it is a professional record of your personal development planning appropriate to your needs.
The PDP goals should be balanced across the five-year cycle and across your whole scope of work. It is rarely appropriate to include non-specific goals in your PDP that could apply to any doctor and do not apply to your personal needs, or that are part of what you are required to do anyway e.g. ‘I need to keep up-to-date’. Such goals should be re-framed and described in more specific terms such that you can demonstrate where they have arisen, why they apply to you now, how you will achieve them, and how you will demonstrate that your goal has been met and that achieving the goal will make a difference.
Part-time and retired doctors
There is guidance: the GMC has worked with the BMA Retired Doctors Forum to produce a guidance document explaining the revalidation requirements to doctors retiring or thinking of retiring.
If I’ve retired from clinical practice and I continue to maintain my CPD, is this sufficient for me to revalidate?
This is not correct. If you choose to hold a licence to practise, the GMC requires you to revalidate in the same way as every other doctor by participating in annual appraisal and maintaining a portfolio of supporting information. If you are retired from clinical practice, it may be that you would wish to relinquish your licence to practise but maintain your registration with the GMC. This means that you do not have to revalidate, and it will show that you remain in good standing with the GMC. This will depend on whether you undertake any activity post-retirement which requires a licence to practise (e.g. if you work directly with patients).
If i’ve retired from clinical practice, but still write medico-legal reports as an expert witness, do I need to revalidate?
All doctors with a licence to practise medicine will have to revalidate. There are a number of components to this question, and a number of different types of medico-legal reports which require different considerations. If you retired from medical practice some years ago, and if you only occasionally provide an expert opinion on the standard of care which would have been considered acceptable at the time when you were in active clinical practice, then it may be reasonable not to retain a licence to practise medicine just for that purpose.
However, if you make yourself available for such opinions, then there are two very important considerations to keep in mind. The first consideration is (a) to make it clear from the outset to the instructing solicitor or other person seeking your opinion, and (b) to prominently state in the substance of your report to the court or tribunal, that you no longer have a licence to practise medicine. The other consideration is to make sure that your medical defence organisation subscription or insurance premium is appropriate for the work you undertake, and that not having a licence to practise is clearly known, whether that indemnity is arranged directly by you, or through an instructing solicitor for example.
Medico-legal reports in contemporary cases on the standard of care provided by another doctor will almost certainly have a requirement from the court or tribunal for a licence to practise. In the small number of cases which go to a court or tribunal hearing, the medical evidence may be challenged, and a medical expert witness without a licence to practise at the time the report was written could be placed at a disadvantage and criticised in public during cross-examination. Many medico-legal reports are based on a clinical examination for current condition and prognosis, and there is an expectation that all doctors with direct clinical contact with patients will be licenced. It is probable that courts and tribunals would be unhappy to rely on clinical evidence given by a doctor without a licence to practise medicine.
Furthermore, unless great care is taken, there is a risk that fully-informed patient consent to undergo the clinical examination could be challenged, even if you routinely mention to patients that you are 'no longer licensed to prescribe', and that in turn could raise a question of probity, and if such criticism is upheld, put your registration as a medical practitioner in jeopardy.
Doctors practising overseas
If I am registered with the GMC and hold a licence to practise but I work overseas, do I need to revalidate?
The GMC states: If you continue to hold your licence to practise while practising abroad, you will need to revalidate. This means you will need to connect to a UK organisation that will support you with your appraisal and revalidation.
However, you may not need a licence to practise if you practise entirely outside of the UK. You may decide it is better to give it up. You can still maintain your registration without a licence, and this will indicate you are in good standing with us. You can apply to have your licence restored if you need it at some point in the future.
There is published guidance on the GMC website