RCGP guide to supporting information - Context

This RCGP Guide to supporting information for appraisal and revalidation (April 2018) is based on the new GMC Supporting information for appraisal and revalidation (April 2018).

These key documents outline the types of supporting information required to demonstrate your continued competence across your whole scope of practice. There is no significant change to the six types of supporting information required by the GMC for a positive revalidation recommendation:

• Continuing professional development (CPD)
• Quality improvement activities (QIA)
• Significant events (SE)
• Feedback from patients or those to whom you provide medical services
• Feedback from colleagues
• Review of compliments and complaints

The GMC requirements are necessarily broad enough to fit every doctor, no matter what area, sector or scope of practice.

GMC requirements and Academy of Medical Royal Colleges (AoMRC) guidance have been interpreted by the RCGP for all GPs, irrespective of their scope of practice, and recognising that GPs are specialist generalists dealing with uncertainty and complexity. There is still a need to remove inconsistencies in the interpretation of earlier guidance and to reduce the burden of the amount of documentation required to successfully revalidate. Each section is structured to highlight the GMC requirement(s) (in red), followed by the updated RCGP general practitioner specific recommendation(s) (in black). This document provides additional detail for GPs on providing the supporting information required by the GMC.

GPs should also understand the process of annual medical appraisal for revalidation as defined for GPs in England in the Revalidation Support Team’s Medical appraisal guide, for GPs in Scotland in NHS Scotland’s A Guide to Appraisal for Medical Revalidation, for GPs in Wales in the Wales Deanery’s All Wales Medical Appraisal Policy and for GPs in Northern Ireland in documentation provided by the Northern Ireland Medical and Dental Training Agency.

Summary of changes to GMC guidance that inform changes to this guidance

• The GMC has clarified that every doctor is required to engage with an annual medical appraisal that covers their whole scope of practice. However, there is no need to have five appraisals in a revalidation cycle if there are reasons why a doctor has an ‘approved missed appraisal’ or the revalidation cycle is not five years long. There is no need for ‘catch up’ appraisals.

• The description ‘scope of practice’ is clarified to ensure that you are providing an appropriate level of detail for the responsible officer to be assured that all parts of your scope of practice have appropriate supporting information and reflection over the five-year cycle, and the contact details for the clinical governance review of any parts of the scope of practice outside your designated body have been shared.

• The wide variety of types of quality improvement activities that are acceptable to demonstrate the regular review of practice – particularly for sessional GPs and those working in relative isolation - is emphasised so that it will be better understood.

• There is no need to provide documentary evidence of reflection on all your learning. Quality not quantity is emphasised. You should be selective and provide high-quality examples of reflection on your most significant learning.

• The GMC definition of significant events (SEs) as events that reach a significant level of actual or potential harm to patients is reiterated. Many GPs will not have been personally named or involved in any SEs needing declaration in any given year and should declare this where appropriate.

• The GMC requirement that you seek formal feedback about your practice using appropriate tools for your scope of practice, that are accessible to the respondents and fully compliant with all the GMC requirements once in the five-year cycle from colleagues and patients or those to whom you provide medical services is re-emphasised. It is important to think broadly about who are your ‘patients’ and your ‘colleagues’ and to ensure that this formal exercise (or formal exercises) covers respondents from the whole of your scope of practice.

Summary of changes to RCGP guidance

• Going forwards, locum GPs will need to provide contact details of all the practices where they have worked, so the RCGP recommends setting up a log to capture this information in real-time.

• The probity and health statements are reviewed to ensure that you reflect on the implications of the requirements in Good medical practice (GMC, 2013) for your own practice.

• The RCGP recommends that you confirm your indemnity provision and make a declaration of any conflicts of interest between your roles in every appraisal.

• With the current pressure on provision of healthcare services, the importance of looking after your own health and wellbeing in order to avoid ‘burnout’ and remain ‘fit to practise’ is highlighted. The RCGP recommends that, in every appraisal, you reflect on how well you look after yourself and the safeguards that are in place to ensure that your health does not pose any risks to patient safety. If you have declared a health condition, it is particularly important to discuss the safeguards that are in place to protect patients (where applicable).

• The requirement to demonstrate appropriate continuing professional development (CPD) to keep up-to-date for each part of your scope of practice over the five-year cycle is reiterated. The RCGP recommends that 50 credits per twelve months in work across the breadth of the GP curriculum over the five-year cycle will be sufficient to keep up-to-date to provide undifferentiated general medical services. If your scope of practice is restricted or unusual you may need to do less, or more, learning in order to keep up-to-date at what you do. In this case, you should reflect on what you have done, and why, and agree it at your appraisal and with your responsible officer if appropriate.

• The definition of a CPD credit is clarified: one credit = one hour of learning activity.

• The former recommendation that all credits should be demonstrated through a reflective note on lessons learned and any changes made as a result has been removed because it was being interpreted in a disproportionate way and adding to the burden of revalidation. You should still include reflection on your CPD, and highlight the most important lessons learned and changes made as a result, but you need not reflect on every CPD credit.

• The recommendation that you should review your personal practice every year, through appropriate quality improvement activities, ensuring that you cover the whole scope of your work over the five-year cycle, is reiterated.

• Because of the GMC definition of significant events as patient safety incidents, the learning opportunities that GPs historically called significant event analysis should be renamed learning event analysis. Learning from events should be considered a normal part of review of practice and examples included in quality improvement activities.

• If you wish to seek feedback from colleagues in the non-clinical parts of your scope of practice separately so that it is easy to interpret in context, this does not need to be GMC compliant, particularly in terms of anonymity or respondent numbers, as you only need to complete a formal colleague feedback survey compliant with all the GMC requirements once in the five-year cycle.

• GPs, who see many patients, and have many sources of patient feedback, should reflect during appraisal on feedback received from patients every year. This does not need to be GMC compliant, as you only need to complete a formal patient satisfaction survey compliant with all the GMC requirements once in the five-year cycle. You are not expected to undertake additional formal feedback surveys, but you are advised to reflect on the variety of sources of feedback already available to you, including informal comments and compliments.

• Where exceptional circumstances dictate that any of the GMC requirements or RCGP recommendations cannot reasonably be met, then you must include in your appraisal portfolio a reflective note containing an explanation, analysis of the implications and the response agreed with your appraiser and your responsible officer. For example, GPs doing low volumes of clinical work (less than 40 sessions over 12 months in work) or unusual or restricted scopes of practice should complete structured reflection that supports them in demonstrating how they remain up-to-date and safe, particularly considering any factors that exacerbate or mitigate the risk to patient safety. They should discuss their reflection at their appraisal. Where appropriate, additional mitigating factors should be planned and included in the new personal development plan (PDP).