3. Supporting information March 2019

• 3.1. Myth: I must document all my learning activities
• 3.2. Myth: I need to scan certificates to provide supporting information about my CPD
• 3.3. Myth: I am not allowed to scan certificates to provide supporting information about my CPD
• 3.4. Myth: It is reasonable to spend a long time getting the supporting information together for my appraisal
• 3.5. Myth: I only need to provide all six types of GMC supporting information about my clinical role
• 3.6. Myth: All my supporting information must apply to work in the NHS
• 3.7. Myth: There are some parts of my scope of practice that my medical appraiser cannot appraise for which I will need an additional appraisal
• Myth 3.8: If I have already had an in-house ‘appraisal’ for one part of my scope of practice, I have to present all the same information again for my medical appraisal for revalidation
• 3.9. Myth: Supporting information from work overseas cannot be included in my appraisal portfolio
• 3.10 Myth: I cannot use any supporting information from overseas
• 3.11. Myth: Having a ‘disagree’ statement from my appraisal is always a bad thing
• 3.12 Myth: I must get sign off statements from all parts of my scope of practice every year

3.1. Myth: I must document all my learning activities

You do not have to document all your learning activities. We recommend that you focus on the quality not quantity of your supporting information.

You should be selective about documenting your reflection on what learning you have found most valuable and meaningful over the course of the year. You should not try to record and reflect on every learning activity.

If you find it convenient and helpful to record significantly more than 50 CPD credits for your own benefit (to capture your learning), or because you have to demonstrate sufficient CPD to keep up-to-date for several different roles, then that is your choice. Your appraiser will focus on the quality of your learning and reflection and challenge you to highlight what has been most important over the course of the appraisal period.

3.2. Myth: I need to scan certificates to provide supporting information about my CPD

The GMC has not set any requirements about exactly how CPD should be evidenced or recorded. Certificates of attendance may prove attendance at an event, but they are not proof of learning or development. They say nothing about what has been learned, or any changes you have made as a result. Recording and demonstrating your CPD by scanning and storing certificates is not likely to be a good use of your time.

A reflective note, no matter how brief, on your learning and what difference it has made (or will make), is more valuable evidence of reflective practice and continuing professional development than a certificate. A lot of valuable learning takes place in ways that do not generate a certificate, such as personal reading and professional conversations with colleagues. We encourage you to think about how and what you have learnt rather than collecting certificates

The RCGP recommends that you should keep a simple learning log in a way that is convenient to you so that you can capture your key learning points and their implications for the quality of your care.

There are several useful apps available, for example the GMC CPD app. Some electronic platforms include learning diaries that can be accessed or emailed from your Smartphone or other devices. A document record, table or spreadsheet can work just as well.

Appraisers should not be asking to see certificates of attendance; they should be asking what your most important new learning has been over the past year and what difference it has made to your practice.

3.3. Myth: I am not allowed to scan certificates to provide supporting information about my CPD

It is appropriate to include scanned certificates in your appraisal portfolio when scanning and storing them is going to be useful to you. Your aim should be to avoid duplication of effort.

Many CPD facilitators now provide certificates that include a structured format or template for you to write appropriate reflective notes about learning and planned changes that will have an impact on your practice. While the RCGP recommends that you capture your reflective notes in a way that is compatible with the appraisal system you are using (such as MARS in Wales) it is reasonable to scan in CPD certificates that include reflection if it is helpful to you. For most GPs, it will be less burdensome to choose not to complete the certificate at all and capture the reflective note elsewhere in a learning log or electronic toolkit.

You might want to scan certificates relating to training specifically required by your designated body or any organisations in which you work, often called mandatory training. This does not make them part of the GMC requirements for revalidation, but it does allow you to collect and keep important documentation securely and demonstrate your fitness for purpose to your employer. Your RO is entitled to ask you to keep this information securely for employment purposes.

If you prefer not to scan a certificate but you refer to it in your appraisal submission then your appraiser may reasonably ask to see it, so you should bring it separately to your appraisal.

3.4. Myth: It is reasonable to spend a long time getting the supporting information together for my appraisal

Organising supporting information into your portfolio, and making the sign-offs and statements before the appraisal discussion, should not take long.

We recommend that your supporting information should be generated from your day-to-day work and added to your portfolio as you go along. Producing a CPD log can be difficult and time consuming as a retrospective exercise. It is much easier to make regular entries into your learning diary throughout the year. There are now many tools and apps to help you to do this in a simple and timely way.

We recommend that the final stage of organising the supporting information and completing your portfolio before your appraisal should take no more than half a day, around 3.5 to 4 hours. This is based on the original financial provision for annual appraisal, which was for one day of activity, half to prepare and half to have the appraisal discussion.

If your preparation is taking longer than four hours, or the effort feels disproportionate, you should discuss with your appraiser how you can simplify what you do. Some doctors with complex portfolio careers and several roles to include may reasonably take a little more time than this, but you should seek advice if it takes more than a day to organise.

3.5. Myth: I only need to provide all six types of GMC supporting information about my clinical role

The GMC requires doctors to provide appropriate supporting information across the whole of their scope of practice that requires a licence to practise, not just clinical roles.

You must declare all parts of your scope of practice and, for each of them where appropriate, provide all six types of supporting information over the revalidation cycle:

• CPD
• QIA
• significant events, if there are any
• patient feedback
• colleague feedback
• compliments and complaints, if there are any

We recommend 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 scope of practice. Your appraiser will help you determine whether there are any gaps in your portfolio of supporting information across your whole scope of practice and support you in working out how best to fill those gaps. Your responsible officer (RO) will tell you if your portfolio demonstrates sufficient engagement in reflective practice and provides the supporting information required by the GMC.

If you have any queries that your appraiser cannot resolve, we recommend that you seek early confirmation from your RO that what you are planning is going to be acceptable.

3.6. Myth: All my supporting information must apply to work in the NHS

Your supporting information must cover the whole scope of practice for which you require a licence to practise, whether you are working in the NHS or not.

There are GPs working entirely in private practice who maintain a licence to practise through revalidation. Even if the NHS provides your designated body and responsible officer, your medical appraisal for revalidation must cover your whole scope of practice, including any roles outside the NHS for which you require a licence to practise. Appraisers are trained and supported to provide whole scope of practice appraisals and to facilitate reflection on supporting information from inside and outside the NHS.

3.7. Myth: There are some parts of my scope of practice that my medical appraiser cannot appraise for which I will need an additional appraisal

It is inappropriate for a medical appraiser for revalidation to say that they cannot appraise any part of your scope of practice. They should have the training and support to provide a whole scope of practice appraisal for any type of work that you may undertake which requires a UK licence to practise. If your medical appraiser for revalidation suggests that they are unable to provide a whole scope of practice appraisal, you should discuss this with your RO and the RCGP as soon as possible.

Every separate place where you work has a duty to supervise and support you in the role they are engaging you for. Within this, it is good practice that they should undertake some form of performance development review with you on a regular basis. In some places this may be referred to as an ‘appraisal’. It is important to recognise the difference between a single-role performance review and your full scope of work medical appraisal. It can be helpful to reserve the term ‘appraisal’ for the latter.

The RCGP recommends that you include the outputs of performance development reviews from any part of your scope of work (where you have them) separately in your main medical appraisal. You should reflect on the outputs of these reviews in your main appraisal rather than presenting all the original supporting information again. It is not appropriate to duplicate effort and be appraised twice in the same way.

For some parts of your scope of practice, it may not be possible to have an external performance development review. For example, you may not be working in a governed environment with any oversight of your performance, so there may not be anyone to provide such a review. For these roles, you will need to provide all the GMC required supporting information to demonstrate that you remain up-to-date and fit to practise at what you do, reflect on it and discuss it at your main appraisal.

Myth 3.8: If I have already had an in-house ‘appraisal’ for one part of my scope of practice, I have to present all the same information again for my medical appraisal for revalidation

Where an employer offers a periodic performance or development review, whether or not it is called an appraisal, then the outcomes of that should be included in the medical appraisal, reflected on and discussed. There is no need to repeat the review of the original supporting information if it has already been reviewed in-house and the outputs included in the appraisal and revalidation portfolio, although it is appropriate to consider with your appraiser whether all the GMC requirements have been met for that role and to include the outcome of that discussion in the appraisal summary. Where there is no such review, you must collect and reflect on the GMC required supporting information for that part of your scope of work and discuss it at your medical appraisal.

3.9. Myth: Supporting information from work overseas cannot be included in my appraisal portfolio

The GMC Protocol for responsible officers (ROs) making revalidation recommendations states at 2.3.2:

‘Doctors may practise in settings where they do not require a UK licence – for instance, they may work abroad, or they may undertake specific functions in the UK that do not legally require a licence to practise. Where this is the case, it is at your discretion whether you consider supporting information from these practice settings in making your judgement. You should consider whether such information is material in your evaluation of their fitness to practise, taking account of whether it is demonstrably relevant to the doctor’s licensed UK practice and the proportion of the doctor’s supporting information that it represents.’

The GMC requirement is that your appraisal and revalidation portfolio should include supporting information about every part of your scope of practice that requires a UK licence. As the above makes clear, your RO has the discretion to consider supporting information from other settings in making their revalidation recommendation.

Myth 3.10: I cannot use any supporting information from overseas

At revalidation the GMC is issuing a renewed UK licence to practise so the GMC required supporting information must demonstrate your continued competence for your UK practice. Sometimes clinical work overseas has a significant overlap with clinical work in the UK. Your RO has discretion to consider any additional supporting information from work that you have done overseas where it is relevant to your UK practice in demonstrating your reflective practice, how you review and make improvements in your work, and how you seek and act on feedback. The RCGP recommends that this can provide powerful evidence of your professional behaviours and habits, one of which is to collect information that demonstrates that you remain up to date and fit to practise across your whole scope of practice wherever in the world you are. With modern electronic learning diaries and web-based portfolios, this should be easy.

Even in UK practice, you may attend CPD events overseas. It is appropriate to check that the content of such an event is applicable to your scope of practice rather than assuming that it will be acceptable. We recommend that you discuss any proposal to include any such additional supporting information with your RO in advance of your revalidation recommendation date.

If you are unsure, use your appraisal as an opportunity to reflect on what is appropriate and proportionate with your appraiser, and then agree it with your RO before your revalidation recommendation is due.

3.11. Myth: Having a ‘disagree’ statement from my appraiser is always a bad thing

There are five key sign-off statements that are normally agreed by your appraiser at the end of your appraisal. If your appraiser decides that one, or more, should be marked as ‘disagree’, this sends a message to you, your next appraiser and the responsible officer (RO) that something may not be ready for revalidation. This is not, in itself, a bad thing. It is an important part of ensuring that the appraisal supports you in preparing a portfolio of supporting information appropriate for a positive recommendation to revalidate. Ultimately, your RO makes the decision about your revalidation recommendation, not your appraiser.

There are two different comment boxes for the appraiser, and one comment box for you, to provide an explanation for the disagree statement. It is relatively common for a doctor to have made no progress with their previous PDP. This could happen, for example, because they had no previous PDP, in the case of a first ever appraisal in the UK, or because circumstances changed significantly during the year, making the earlier PDP goals less appropriate. In these circumstances, it is appropriate for the appraiser to mark ‘disagree’ to the statement about progress with the previous PDP and enter an explanation in the comments box.

Even the fifth sign-off statement, which states that there are no concerns arising from the appraisal documentation or discussion that suggest a risk to patient safety, may sometimes need to be marked as ‘disagree’. For example, if a doctor is currently under investigation, and has their annual appraisal in the period before the investigation is resolved, they could not be revalidated as there are outstanding concerns, and the appraiser should indicate this by marking the fifth statement as ‘disagree’.

It is important that the appraiser puts an explanation in the comments box provided in every case where they have marked a statement as ‘disagree’.

In all cases, you also have a box in which to enter your comments, although you do not have to comment if you have nothing to add to the appraiser’s explanation.

3.12. Myth: I must get sign off statements from all parts of my scope of practice every year

The RCGP does not recommend that you seek sign-off statements from third parties that there are no concerns about your practice in all of your roles every year. Instead, you should reflect on how the safety of patients is being assured and the governance, clinical or otherwise, of the systems you are working in. You should always know how to report on a significant incident and how you would find out if there was a complaint about you. It is important that you have declared all the different parts of your scope of practice and provided appropriate supporting information to demonstrate that you are keeping up-to-date, reviewing and maintaining (or improving) your performance and seeking and acting on feedback in each. It is also important that you ensure that your responsible officer (RO) knows how to contact the clinical governance leads from any part of your scope of practice that is not for your main designated body so that they can seek the assurance that they need when they need it.

We recommend that any governance concerns arising about a doctor should be communicated to the RO as and when they arise, by those responsible for the governance surrounding a doctor’s work. It is crucial that concerns can be dealt with in a timely fashion and that they are not linked to the revalidation cycle.

In some cases, a doctor will be working in an environment where there is no external governance and the reporting of any issues will depend on the professionalism of the doctor. Significant events and complaints can arise in every type of practice, and the GMC requires that all such patient safety incidents and complaints should be declared and reflected on at appraisal. We recommend that GPs talk to their RO, whenever they have a governance concern, to agree the best way forward and because the RO will often be able to signpost appropriate resources or courses of action.

In summary, normally concerns will be generated and ‘pushed’ to your RO as and when they occur to be dealt with in a timely fashion outside the revalidation process. As part of this, you are personally responsible, as a professional, for declaring any concerns that you are aware of as they arise. In addition, your RO needs to have up-to-date contact details for all parts of your scope of practice, by including in each appraisal the details of everywhere that you have worked since your last appraisal, to ‘pull’ information about your work at any time, should this be necessary.