Operations Department

1. Operations Department • Revalidation for • doctors in training • Health Education South London • Working also on behalf of Health Education North Central and East London and Health Education North West London

2. Principles of Revalidation • The GMC’s approach to the implementation of revalidation: • Confirms that a doctor with a licence to practise continue to be fit to practise. • Requires all doctors to engage with systems of periodic review. • Is not a point in time assessment. • Provides confirmation that a doctor with a licence to practise is working within a governed system. • Requires all doctors to have a prescribed connection to a designated body, and one Responsible Officer. • Should be implemented in a fair and proportionate way based on consistent principles.

3. Doctors in Postgraduate Training hold a Licences to Practise • …and will therefore need to revalidate • Revalidation recommendations will be made • 5 yearly AND at CCT • The Postgraduate Dean is your Responsible Officer • Health Education North East and Central London • Tim Swanwick • Health Education North West London • Julia Whiteman • Health Education South London • Andrew Frankel

4. Trainee alignment by Designated Body • Trainees are aligned by LETB according to the geographical location of where their programme is managed • For commissioned programmes this will be the location of their Lead Provider e.g. all trainees part of a training programme managed by UCLP will be connected to HE NCEL as their Designated Body and RO • Trainees will not otherwise change their Designated Body / RO connection for the duration of their programme; this includes when on periods out of programme, or acting up.

5. Principles of revalidation for trainees • In order to be ready to have a revalidation recommendation made about them, doctors in training must simply: • Participate in an ‘enhanced’ ARCP process There are no additional evidential requirements for doctors in training programmes over and above the requirements of their curriculum

6. Scheduling revalidation dates The revalidation date for trainees (i.e. the point at which the GMC expects to receive a revalidation recommendation) will be set at either: At CCT if the expected CCT date falls before 31st March 2018 (submission date is 60 days post CCT) Between 1st April 2016 and 31st March 2018 if the expected CCT date is after 31st March 2018. All trainees will have received communication from the GMC confirming a revalidation date.

7. Responsible Officer Recommendations • The 2012 RO regulations require ROs ‘to make recommendations to the General Council about medical practitioners’ fitness to practise’ • ROs already make ‘recommendations’ about the fitness to practise of doctors through referrals to the GMC’s Fitness to Practise processes – this should continue as now • Revalidation adds the positive affirmation of doctors’ fitness to practise to the current processes

8. Three categories of RO recommendations • Positive affirmation of suitability to continue to hold a licence • (occurs every 5 years and at CCT) • 2. Notifications of non-engagement: • Confirm that an RO cannot, or cannot envisage being able, to make an informed recommendation when it falls due, as the doctor has not engaged in processes that support revalidation • Appropriate grounds for non – engagement would be trainees absent from the training programme without approval, trainees repeatedly not engaging with the ARCP process • Not a mechanism for addressing concerns about a doctor’s fitness to practise • 3. Notification of non-engagement

9. Deferral Requests • 3. Deferrals • Can be requested if an RO is not ready to make a recommendation by the original due date. • Has no effect on the doctor’s licence to practise • Appropriate grounds for deferral requests include trainees being on maternity leave, long term sickness, out of programme, or involved in an ongoing local investigation or disciplinary process • HE South London will make deferral requests on behalf of the trainee and RO. • Deferrals can be requested when a doctor is within 4 months of their Revalidation date. • The maximum amount of time a revalidation date can be deferred is 12 months, this may mean multiple deferral requests are required; for example if a trainee is out of programme for research.

10. ARCP panels What stays the same • ARCP panel processes for making decisions on trainee progression and responding to fitness to practise issues will continue. • The information reviewed by an ARCP panel is confined to the evidence presented • Information withheld by a trainee is considered a probity issue • Referral to fitness to practise procedures can occur at anytime, according to circumstances, not just at ARCP.

11. The enhanced ARCPWhat’s different • 1. Now covers the full scope of practice for which a trainee holds a licence to practise including: • Locum work • Voluntary work e.g. St John’s Ambulance, medical officer to rugby club • 2. Complaints and compliments arising across full scope of practice • 3. Involvement in and learning from investigated significant events arising across full scope of practice • 4. Notification to the GMC of non-engagement with ARCP can result in administrative removal of the trainees’ licence to practise at any point in the revalidation cycle

12. Information to support revalidation via ARCP Enhanced Form R Self declaration Full scope of practice since last ARCP Involvement in investigated significant events arising from scope of practice All formal complaints and compliments arising across scope of practice Declarations of health and probity (including amount of sick leave taken since last ARCP) Educational / Clinical Supervisor sign-off of absence of fitness to practise concerns Updated ARCP Outcome form Six monthly employer ‘Collective Exit Reports’ and where required ‘Exception Reports of Concerns’ 5. Routine notification of SIs, complaints and concerns with no changes to information requirements

13. Employer Reporting • Nationally Employers are expected to return information regarding a trainee’s fitness to practice twice annually. • This cycle currently occurs every April and November. • Every LEP in London is asked to return information via ‘the Employers Portal’ for trainees in post within the previous six months. • We also collect data from KSS and EOE where London trainees rotate out into these posts. • More than one LEP maybe asked to report on an individual trainee if they have rotated during the reporting period. • Relevant information collected via the Employers portal is confidentially shared with the ARCP panel to aid in their decision making with regards to fitness to practice.

14. Employer Reporting Exit Report • Completed by LEPs HR and DME for every training confirming whether there have been any concerns or issues raised within the last 6 months in regard to: • Involvement in a Formal Serious Incident / Significant Event Investigation • Involvement in a Conduct, Capability Investigation • Named in Complaint(s) Exception Report • Where trainee involvement in any of the above occurs, the LEP must submit an exception report providing more information, including: • Summary of the incident, investigationor complaint • Has the incident been satisfactorily resolved or is still ongoing? • An indication as to the level of involvement of the trainee

15. What do others need to do? • Educational Supervisors are now formally asked to declare whether there are any concerns re your fitness to practice as part of the ESR Form. • LEPs will be asked to provide an Exit Report for you (this may be more than one if you have rotated within the reporting period). There should be ‘no surprises’ - if a notification regarding SI involvement is made by an LEP the expectation is that they will have discussed this with you. This occurs twice annually in April and November. • ARCP Panels triangulate information collected from ES Reports, Trainee Self Declaration and Employer Reporting to make Fitness to Practice recommendations. • ROs and Health Education South London will collect enhanced ARCP information annually in preparation for your revalidation and will make a recommendation for revalidation at your 5 year cycle and/or CCT date. • The GMC will contact all Doctors automatically once you are within your notice period for revalidation and again once a revalidation recommendation has been made and revalidation occurs.

16. What do you need to do? 1. For your next ARCP: • Complete Enhanced Form R & Self Declaration to include full scope of practice (including any locum activity), since your last ARCP • This is mandatory for your ARCP, no formal Outcome can be issued without both parts of your Form R. • Failure to provide in time for the panel may result in your ARCP being rescheduled or in extreme cases a non engagement notification to the GMC. • Ensure ePortfolio and personal library is up to date with all complaints and compliments information so this can be referred to in your Enhanced Form R, including any reflections or learning that has taken place as a result.

17. What do you need to do? • 2. For trainees reaching CCT • Ensure that you are providing all required evidence well in advance of your CCT date to ensure that a revalidation recommendation can be made on your behalf before you reach CCT. • Notify your RO if you believe your Revalidation Date is incorrect • Do not change your Responsible Officer with the GMC until you have received confirmation that your revalidation recommendation has been made. • A revalidation recommendation will be made by your RO once you are within 4 months of your revalidation date and all necessary documentation has been received and is in order.

18. QUESTIONS? • traineerevalidation@southlondon.hee.nhs.uk • traineerevalidation@ncel.hee.nhs.uk • traineerevalidation@nwl.hee.nhs.uk