It's over 10 years since revalidation was introduced and for most doctors, it has become a well-understood and well-accepted integral element of their professional lives.
But here at Premier IT, with almost 100 healthcare clients using our latest appraisal and revalidation software, we still occasionally get challenged on its purpose. Here are some common examples:
Revalidation was not designed as, and never could be, a single solution to problems with the governance of the medical workforce. It was introduced as part of wider reforms including the creation of the Responsible Officer (RO) role. However, revalidation does play an important role in delivering assurance on doctors’ practice. Before revalidation, and in the absence of any serious concerns coming to light, a doctor could practise medicine from the start of their career to retirement without any regulatory checks. Revalidation has significantly improved oversight and scrutiny. The number of fitness-to-practice referrals from employers has fallen from almost 1300 in 2012 to just 195 in 2021. How much of this is the influence of revalidation is unquantifiable, but there’s little doubt that better systems of governance, including revalidation using electronic, secure software are a major driver. It also provides an opportunity to identify fitness to practise concerns at an early stage, so they can be dealt with before they escalate. Revalidation has also had a positive impact on doctors’ access to appraisals and to continuing professional development (CPD). Appraisals became a contractual requirement for most doctors in the early 2000s, but access for many remained limited until revalidation began in 2012. Access to CPD has improved similarly, driven by the requirement to demonstrate CPD at each appraisal. Since 2012 almost 6,000 doctors have had their licence to practise withdrawn, at least once, for not complying with revalidation requirements. Previously, these doctors would have still been able to practice in the UK.
Revalidation is a pain in the xxxx! Revalidation requirements reflect pre-existing good practices and are readily achievable for most doctors. The only new activity introduced for revalidation was patient feedback, and that is required just once per cycle. ROs have always been able to defer a doctor’s revalidation recommendation if more time is needed. When this happens there is no impact on the doctor’s licence. Premier IT would always encourage employers to support their workforce as much as they can, for example by reviewing their own appraisal requirements and, where possible, by automating the provision of supporting information using the inbuilt tools provided for in our toolkits.
Revalidation is a continuous process and not a point-in-time assessment. Doctors are required to engage continuously with the local clinical governance systems that underpin revalidation, including appraisal, complaints and incident reporting. The supporting information requirements include an annual discussion of complaints, incidents and CPD as part of a doctor’s regular appraisal. Patient and colleague feedback, and a quality improvement activity, are required at least once per revalidation cycle. ROs usually make a revalidation recommendation to the GMC once every five years, but they can notify the regulator if a doctor is failing to engage at any time.
Appraisal and revalidation are the same thing. Appraisal and revalidation are often conflated and thought of as synonymous, but the two are not the same. Doctors are required to engage in an annual appraisal as one element of revalidation but, in most cases, they are a local contractual requirement. Appraisals were introduced about 10 years before revalidation.
Doctors must make up appraisals they have missed if they have been away from work. Doctors should be in an annual cycle of appraisal, but if they have been away for a long time, for example on maternity leave, there is no requirement for them to make up the number of appraisals they have missed. Providing they meet the other requirements they can still revalidate even if they have missed an appraisal. There’s even a “special circumstances” tab in our systems to make this easy
I hope that by now Premier IT is a source of expertise in RO regulations because we work closely with ROs, but we are not the authority on them. They are ‘owned’ by the Department of Health and Social Care, in England, Scotland and Wales, and, in Northern Ireland, by the Northern Ireland Department of Health who are also our valued customers.
The regulations set out the statutory obligations of healthcare providers and ROs to put in place and monitor clinical governance systems. Specifically, that includes having systems in place to support the ongoing ‘evaluation of a medical practitioner’s fitness to practise’. The regulations also set out the hierarchy for doctors to connect to an RO. Yet revalidation itself is not mentioned in the RO regulations.
So, after 10 years revalidation has bedded in and is here to stay. No system will be perfect for everyone but we are always looking for ways to improve things and to support doctors and ROs as much as we can.
We really appreciate the commitment and hard work doctors and ROs put in to make revalidation happen and to make it effective and at Premier IT we are committed to making the journey as simple as possible.