GMC did not impose annual appraisals to support revalidation

As a former responsible officer, Nadeem Moghal should be aware that annual appraisals have been a contractual requirement for doctors in the NHS for many years, and were not imposed by the GMC to support revalidation (Medical appraisal and revalidation – a pretence that is reassurance, not assurance, HSJ 18 March 2019).

Writing about the “GMC’s appraisal system” and “GMC constructed appraisal” is inaccurate. We do say that all licensed doctors must participate in an annual appraisal, but our requirements on the supporting information they should bring to those appraisals are high level and generic.

It is the medical royal colleges, not us, that provide the detailed guidance on how these requirements can be met by specialists and by GPs.

Responsible officers have a duty to consider all information available to them when evaluating any doctor’s fitness to practise on an ongoing basis. They cannot and should not simply rely on their local appraisal system

Neither do we set what Dr Moghal describes as “arbitrary” minimum hours of continuous professional development. Such requirements, where they exist, are also likely to come from the royal colleges.

Like them or loathe them, annual appraisals are a fact of life for many of us. We have always said that appraisals should be a positive experience for doctors. It is an opportunity for them to take time out, with one of their peers, and to reflect on their practice, their professional development and to consider how they are viewed by people they work with and they treat.

It is important to us that it doesn’t become a burden, especially at a time when doctors in health services across the UK are working under levels of pressure like never before. Those responsible for delivering appraisals need to make sure the process is consistent and valuable, and we are committed to delivering further initiatives to help with that.

But appraisals are only part of the picture. Responsible officers have a duty to consider all information available to them when evaluating any doctor’s fitness to practise on an ongoing basis. They cannot and should not simply rely on their local appraisal system. All good healthcare organisations should have robust systems of clinical governance in place which enable responsible officers to triangulate information about their doctors’ practice.

Dr Moghal refers to “dozens of measures already in place” in NHS organisations. These measures and outputs should be available to responsible officers when considering a doctor’s fitness to practise so they can be sure there are no outstanding concerns when making a revalidation recommendation to the GMC. Of course, ideally, those measures should also be available to the doctors themselves to consider as part of their appraisal, although we know this doesn’t happen routinely in every organisation.

Patients put their trust in doctors and expect they should be able to demonstrate that they are up to date and fit to practise in their chosen field. Revalidation makes an important contribution to providing that assurance, not simply because doctors participate in appraisal but because doctors work within a clinical governance system where they can be supported to develop and learn, and where emerging poor performance can be identified and managed early on.