Revalidation 2020-2021 

In March 2020, the GMC announced that it would defer for one year the revalidation of doctors due to revalidate before the end of September. Appraisals may restart in October 2020 and due to the unprecedented stress and impact of the Covid-19 pandemic, discussions have been ongoing towards achieving a consensus that the first appraisal during the pandemic will be more flexible, require significantly less documentation than previously and have an increased focus on the support and well-being of doctors.

At your next appraisal, you will be able to present any information gathered since your previous appraisal even though the time between appraisals may be longer than usual. This includes supporting information entered into your portfolio prior to the COVID-19 pandemic. You should keep your supporting information proportionate and present what is applicable to your whole scope of work between the two appraisals. If you need further information please contact your appraisal office or responsible officer.

Medical Revalidation

Doctors working in clinical informatics may need or want to hold a licence to practise. If you are unsure whether you should retain your licence to practise, the GMC provides discussion points that may help you decide.
To retain your license to practice you usually need to have an appraisal every year and to revalidate every five years. The GMC says, “Revalidation assures patients and the public that doctors remain up to date and fit to practise, in line with the standards of practice required in the UK. It is founded on the principle that you have met the professional expectations placed on you as a doctor practising in the UK. You have a professional obligation to give an honest and comprehensive picture of your whole practice for revalidation.”

How to revalidate

Regulations require you to engage with the following revalidation processes:

There is a clear set of rules that determines which organisation is your designated body. The rules are based on regulations and you cannot choose who will be your designated body or responsible officer.

The GMC has developed an  online help tool    to help you find which organisation is your prescribed designated body. Once you have identified your prescribed designated body you should contact that organisation’s responsible officer and also  inform the GMC . The GMC refers to this as making a connection.

For the majority of doctors in clinical informatics, it will be straightforward and your designated body will be your employer or national NHS board. This means that as you change employment over the years your designated body may also change. Some professional organisations have designated body status and the GMC help tool will indicate if you should make a connection where you are a member.

A small number of doctors in health informatics may not have a prescribed designated body. This may be due to a variety of reasons including contractual status or unemployment. Whatever your status, it is important that you keep the GMC informed of any changes. If you are unsure, you should work through the GMC tool and if you do not identify a prescribed designated body you will reach a set of questions including, “Are you currently a Health Informatics Practitioner?”. If you can say “Yes” to this (and “No” to  all  the preceding question sets) then you will be taken to a statement informing you that you may be able to connect to a suitable person who can act as your responsible officer.

Click on the link to the list of approved suitable persons and scroll down through that list. You will find the details of John Woodhouse, a suitable person who can act as a responsible officer for health informaticians. You can contact him to make a revalidation connection. It is important to note that you can only connect to a suitable person to act as your responsible officer if you do not have a designated body prescribed in regulations, so you should follow the GMC tool carefully.

FCI recommends making a connection. However, as an alternative to connecting with a suitable person, doctors with no connection may revalidate directly with the GMC but will need to undertake a GMC revalidation assessment (paper-based MCQ) in addition to other requirements outlined  here.

You should collect supporting evidence relating all your professional roles across each revalidation cycle. Bear in mind that your evidence is intended to show that you are: up-to-date, fit-to-practice and safe; have a realistic plan to improve the quality of your work (PDP); undertake effective, developmental learning (CPD).

Doctors with a connection:

  • Follow the advice and guidance of your responsible officer or suitable person
  • Collect and reflect on supporting information about your informatics practice in line with Academy of Royal Medical Colleges 

Doctors in training:

  • Participate in the requirements of your UK training programme (your responsible officer is the postgrad dean)

Doctors with no connection

 

You should have an annual appraisal for revalidation, which must consider the whole scope of your practice, i.e. clinical and informatics.

Doctors with a connection:

  • Your responsible officer will allocate you an appraiser for the purposes of revalidation
  • You will need to find a suitable appraiser with whom your suitable person is satisfied. FCI may be able to assist members if needed. 

Doctors with no connection

The GMC says, “Annual whole practice appraisal should be supportive and developmental, and is not a pass or fail exercise. You must participate in a whole practice appraisal every year unless there are clear and reasonable mitigating circumstances that prevent you from doing so. For example, you might not have had an appraisal one year because you were on maternity leave or long-term sickness absence. Providing there are clear and reasonable mitigating circumstances, we do not require you to ‘catch up’ on appraisals and you do not have to complete five appraisals to revalidate. You should discuss and agree this with your responsible officer before any period of prolonged absence, or as soon as you know how long you are going to be away from work.”

Guidance on the appraisal of clinical informaticians

The following guidance is intended for all doctors working in clinical informatics, whether or not informatics is their primary role, their appraisers and responsible officers.

Since the introduction of revalidation, the Medical Royal Colleges and Faculties have worked with the Academy of Medical Royal Colleges and the General Medical Council (GMC) to provide guidance for doctors on appraisal and revalidation. Updated guidance was published in 2018 by the GMC and the Academy and form the basis of the FCI’s expectations for revalidation.

The GMC has outlined that medical appraisals for revalidation must be based on Good Medical Practice (GMP). There are six types of supporting information that you are expected to provide across your whole scope of practice for your annual appraisal for revalidation.

Keeping up to date:

  • Continuing professional development

Review of your practice:

  • Quality improvement activities

  • Significant events

Feedback on your practice:

  • Feedback from patients or those to whom you provide medical services

  • Colleague feedback

  • Compliments and complaints

The AoMRC framework document, Supporting information for appraisal and revalidation (2019), provides detail on how you can fulfil GMC requirements whilst protecting time for your core professional activities. The FCI aims to develop supplementary faculty-specific advice to be read alongside the Academy framework.

By providing a range of good quality supporting information over the revalidation cycle and through reflection and discussion at your appraisals you should have evidenced your whole scope of practice against all the domains and attributes of GMP. A key output of your appraisal is the summary of your appraisal discussion, which is agreed between you and your appraiser and structured around the four GMP domains.

Across the revalidation cycle, appraisals should consider the whole scope of practice. Clinical informatics is a diverse discipline operating across the whole cycle of information processes, programmes, products and projects, bringing benefit to people and users at service, system and population levels. Clinical informatics is a specialist skill set that colleagues and patients may not easily understand, indeed phase 1 of the Faculty’s Core Competencies Project (CCP) found that there remains confusion about the ‘what’ and ‘who’ of clinical informatics (2020).  This applies to doctors as much as other professionals and may mean that the clinical informatics aspects of a doctor’s practice may not be adequately considered within the appraisal.

In March 2020, the CCP published the following statements which, in the context of revalidation, may help appraisees and appraisers to clarify whether a doctor’s role may be considered to fall within the description of clinical informatics.

Clinical Informatics is the application of data and information technology to improve patient and population health, care and wellbeing outcomes and to advance treatment and the delivery of personalised, coordinated support from health and social care.

A clinical informatician uses their unique knowledge and experience of informatics concepts, methods and tools to promote care that is safe, effective, efficient, timely, person-centred and equitable.

A doctor’s role in clinical informatics is often interdisciplinary and the CCP noted that the role may include the following areas, amongst others:

  • How people interface with ICT in health and social care, including electronic record systems, apps and remote devices

  • Collect, manage, analyse and provide security for data

  • Clinical decision support, safety alerts, and data visualisation to facilitate health care delivery

  • Innovative communications with patients to facilitate health care provision

  • Ethical and information governance frameworks, and data usage policies

  • Leadership, strategy and policy formation, and change management

  • Research, design, implementation, evaluation and regulatory compliance of emerging technologies

  • Education and training

The nature of clinical informatics means it is particularly important for doctors to ensure that they are working within an effective and safe governance framework because of the potential to have a great impact on patient services or health protection. GMC’s handbook, Effective clinical governance for the medical profession (2018), makes it clear that organisations have a responsibility to ensure their clinical governance arrangements support the medical workforce to practice safely and meet their professional obligations. Further, safeguards should be in place to ensure clinical governance arrangements for doctors are fair and free from bias and discrimination. The GMC handbook includes a template that doctors can use to self-assess whether their organisation is meeting the outcomes of effective clinical governance. Clinical informaticians who work as contractors rather than employees may be working outside a formal clinical governance structure and FCI suggests that doctors should reflect on such circumstances in their appraisal. Clinical informaticians working independently from their medical peers should consider what steps they can take to reduce professional isolation. The Faculty runs an informal mentoring scheme which can provide support and more information is available at https://facultyofclinicalinformatics.org.uk/professional-mentoring-scheme .

 In order to support appraisal and revalidation of clinical informaticians, the FCI has developed a framework to provide guidance for doctors and their appraisers and responsible officers on the core professional attributes described by the CCP.

The behaviours laid out in the FCI Medical Appraisal and Revalidation Framework below would be appropriate to reflect on in preparation for appraisal, discuss in the appraisal meeting, and reference in the appraisal summary. Within each of the Good Medical Practice domains, the FCI framework is in four parts. First, the GMC requirements for all appraisals are listed and then the professional attributes of clinical informaticians as described by the CCP are noted. These are followed by indicative activities that are likely to be relevant to doctors practising clinical informatics and which link to the FCI’s mission, values and objectives and GMC guidance. Lastly, good leadership behaviours in clinical informatics are included that may be relevant for the doctor to reflect on and discuss with their appraiser. Leadership attributes are included primarily because effective clinical leadership is key to ensuring the protection of patient safety and also because doctors of all grades may be seen as leaders in multidisciplinary settings. Appraisers and responsible officers can find comprehensive information about competencies in clinical informatics in the Core Competency Framework developed by the University of Manchester and the FCI (2020, not yet published).

Whilst appraisal is a GMC requirement, a key purpose is to promote good practice and professional development. FCI believes that appraisal should be supportive and encourage continued improvement in the appraisee’s practice. The framework is intended to add value to the appraisal discussion by supporting appraisal preparation and written reflection with the aim of professional development and should not be used as a checklist.

The framework and this document will be reviewed in September 2021.  The FCI would like to acknowledge that the style of the framework draws from Faculty of Medical Leadership and Management guidance (2015).

Download the FCI Medical Appraisal and Revalidation Framework 

Download the FCI Medical Appraisal and Revalidation Framework 


Your revalidation recommendation

Your responsible officer or suitable person will usually make a recommendation to the GMC about you once every five years. You must take reasonable steps to ensure you engage with revalidation processes to enable your responsible officer or suitable person to make a recommendation about you before your revalidation submission date.


Multi-source feedback for revalidation

Formal Multi-Source Feedback (MSF) is a requirement of medical revalidation and must be undertaken once in each revalidation cycle. The General Medical Council (GMC) says that for your revalidation you must collect, reflect on, and discuss at your appraisal feedback from patients and colleagues across the whole scope of your practice.

Where a doctor does not provide medical services to patients there is no requirement to undertake a patient feedback survey but all doctors must undertake colleague feedback and the GMC says that the questionnaires should be validated and independently administered whenever possible to maintain objectivity and confidentiality.

Many colleague feedback tools that are currently used for revalidation may not be optimally suited to clinical informaticians for various reasons including a focus on clinical contact with patients.

FCI has developed a colleague feedback tool for medical revalidation which meets GMC criteria and reflects the values and principles of GMC’s Good Medical Practice. The tool may be suitable for all doctors whose scope of practice includes clinical informatics, whether or not they provide medical services to patients.

Some designated bodies may mandate a particular MSF tool and doctors can discuss with their appraiser whether the FCI-approved MSF is appropriate for them. If there is any doubt doctors should confirm that the responsible officer is content. John Woodhouse, suitable person, accepts a range of MSF tools and has supported the development of the FCI-approved MSF indicators.

In seeking colleague feedback for revalidation purposes, you should try to ensure that you ask a range of colleagues that is representative of the people you work with and across the scope of your practice.

GMC requires that the MSF process includes a supported discussion either through appraisal or a separate feedback session. FCI advises that you include in your appraisal portfolio some written reflections on the feedback you have received, ready to discuss at your appraisal.

The FCI-approved indicators were developed iteratively from the core GMC indicators, with particular thanks to the Faculty of Occupational Medicine and members of the FCI education and standards committee. The aims included keeping the number of indicators low and the rating scale simple and that the tool should be equally suitable for those that do and don’t have direct contact with patients. GMC guidance on the development of questionnaires was reviewed for compliance.

The MSF is available at https://www.fourteenfish.com/join/fci and can be viewed after registering with them. Registration is simple and free and there is a nominal charge for the survey which is payable once the survey is complete and you want to view the results report . FourteenFish Ltd is a small UK company that specialises in providing appraisal toolkits and did not charge a set-up cost to FCI. A 10% discount is offered to FCI Members and Fellows.

The MSF tool will be kept under review, if you would like to provide constructive comments on it, please contact FCI.