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Wessex Appraisal Service review of new GMC Guidance on Supporting Information for Appraisal & Revalidation

The new GMC guidance on Supporting information for appraisal and revalidation has been published (9th April 2018):

GMC Guidance on Supporting Information for Appraisal and Revalidation

It is written in plain English and worth reading in the original. There are very few significant changes as there was general feedback that what is needed is more consistency in application of the existing requirements rather than change.

Key reminders:

All doctors with a GMC Licence to practise in the UK, including doctors in training, and doing work outside training must collect a portfolio of supporting information about their UK practice as part of their annual medical appraisal for revalidation or Annual Review of Competence Progression (ARCP). You must demonstrate that you are practising in line with the standards laid out in Good Medical Practice: GMC Guidance on Good Medical Practice

The aim is to demonstrate that you remain up to date and fit to practise as a doctor for the whole scope of your practice in the UK. The supporting information falls under the same four broad headings:

  1. General information – providing context about what you do in all aspects of your work
  2. Keeping up to date – maintaining and enhancing the quality of your professional work
  3. Review of your practice – evaluating and improving the quality of your professional work
  4. Feedback on your practice - seeking and acting on feedback about the quality of your professional work

The GMC have also kept the same six types of supporting information you must collect, reflect on and discuss at your appraisal. They are:

  1. Continuing professional development (CPD)
  2. Quality improvement activity (QIA)
  3. Significant events (SE)
  4. Feedback from patients or those to whom you provide medical services
  5. Feedback from colleagues
  6. Compliments and complaints

Your supporting information must cover any work you do in:

  • Clinical (including voluntary work) and non-clinical (including academic) roles
  • NHS, independent sector and private work

The GMC requirements should be sufficiently generic to cover all doctors’ scopes of practice. If you cannot meet any of the GMC overriding requirements for supporting information you must discuss it at your appraisal and agree with your responsible officer (RO), suitable person (SP) or the GMC, how you will demonstrate your continued competence in a different way.

As this is about maintaining a UK Licence to practise, your supporting information should be collected in, or relate to, your whole scope of work in the UK. Supporting information from work done overseas will not normally be considered as demonstrating the quality of your practice in the UK, although it may provide additional information if agreed with your RO.

Key clarifications:

  • 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
  • Participating in annual appraisals that cover your whole practice means collecting, reflecting on and discussing supporting information in line with the requirements in the GMC guidance
  • You do not need five appraisals to revalidate and there is no requirement to ‘catch up’ on appraisals missed for good reason
  • The GMC do not require you to use any specific appraisal portfolio tools or systems for revalidation but your organisation may specify the portfolio tools they expect you to use
  • Appraisal can be used for other legitimate reasons as well as for revalidation but the GMC sets the overriding requirements for revalidation
  • The organisation where you work may set other appraisal or contractual requirements as part of your employment – these are not GMC requirements and, except in exceptional circumstances, failure to meet them should not influence the revalidation recommendation made about you
  • The GMC do not set a minimum or maximum quantity of supporting information you must collect - but you must describe your whole scope of practice and reflect on how you have done enough to keep up to date, review, maintain and improve the quality of your practice and seek and act on feedback about your practice across your whole scope of practice
  • You are referred to the Academy of Medical Royal Colleges, and individual colleges, faculties or specialty specific organisations for additional guidance about how the GMC requirements may be fulfilled 
  • You will not meet the GMC requirements simply by collecting the required information – you must demonstrate examples of your reflective practice
  • Your appraiser can facilitate further reflection, as needed
  • The appraiser should be appropriately appointed and trained but does not have to be from the same specialty as you
  • The GMC do not require you to document the detail of every event
  • The focus on learning at appraisal must include discussion of the changes you have made or plan to make and any areas of good practice you intend to maintain or build on as a result of your reflections
  • Learning needs and opportunities identified through the appraisal process must feed into your Personal Development Plan (PDP) and Continuing Professional Development (CPD) activities for the following year
  • Reflection on your supporting information and what it says about your practice will help you improve the quality of care you give your patients and the services you provide as a doctor

Key changes in emphasis:

  • You must make your RO and appraiser aware of all the places you have worked and the roles you have carried out as a licensed doctor since your last appraisal
  • You are encouraged to consider quality not quantity of supporting information – choosing clear examples within each supporting information category
  • You are encouraged to consider what evidence demonstrates your strengths as well as areas that may benefit from further development and to choose examples based on their ability to generate meaningful reflection and discussion during your appraisal meetings
  • Your professional obligation to make sure that your supporting information and any other evidence for your whole practice appraisal is honest, accurate and comprehensive is emphasised

Summarising the six types of supporting information in more detail:

CPD:

  • You must carry out CPD activities every year, tailored to your scope of practice and needs, and they should be reflected in your PDP for the coming year
  • Your CPD activities must:
    • be based on your day to day work and what you think you will need in the future to carry out all the roles and responsibilities that are (or are likely to become) part of your scope of practice
    • be relevant to the current and emerging knowledge and skills needed for your specialty or area of practice, professional responsibilities and areas of development and work
    • prepare you for the unpredictable and changing nature of medical practice
    • meet the needs of your patients, colleagues and employers, where appropriate.
  • CPD should focus on outcomes or outputs rather than inputs i.e. what you have learned and how this could help maintain or improve the quality of your practice

QIA:

  • You must discuss with your appraiser or RO the extent and frequency of the QIA that is appropriate for the work that you do
  • You must participate in QIA relevant to all aspects of your practice at least once in your revalidation cycle but the GMC recognise that QIA can take many forms depending on the nature of your practice
  • You should participate in and reflect on the outcomes of any national audits or outcome reviews in your area of practice
  • Your focus should be on activities or work that you have been involved in that has focused on quality improvement
  • Evaluation and reflection on the results of the QIA, including any actions you have taken and the impact of any changes you have made should be discussed at appraisal, or included in the PDP for the following year

SE:

  • You must declare and reflect on every significant event you were involved in since your last appraisal
  • A significant event is any unintended or unexpected event, which could or did lead to harm of one or more patients. This includes incidents which did not cause harm but could have done, or where the event should have been prevented
  • Your reflection and discussion should focus on the insight and learning from the event, rather than the facts or the number of events recorded
  • If you are employed you should contribute to the processes for identifying and investigating SE in your organisation. If you are self-employed you should make a note of any such events or incidents and review them
  • If you have not been involved in any significant events you must declare it and you should either reflect on your local significant event process or what you have been doing well to mitigate the risk of an SE occurring
  • You should be able to show to your appraiser that you are aware of any patterns in the types of incidents or events recorded about your practice. You should discuss the action you have taken and any changes made to your practice to prevent such events or incidents happening again. Areas for further learning and development should be reflected in your personal development plan and CPD

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

  • At least once in your revalidation cycle, you must collect,  reflect on and discuss feedback from patients about their experience of you as their doctor, across your whole scope of practice
  • You should use an appropriate tool, accessible to a representative sample of your patients, which meets the requirements laid out by the GMC, or, in exceptional circumstances, agree an alternative with your RO
  • Feedback must be of a sufficient quantity to give a realistic and comprehensive picture of how your patients perceive you
  • If you do not have patients you should collect feedback from others to whom you provide medical services, or agree an alternative approach with your RO
  • You must reflect on what the feedback means for your current and future practice, and discuss it at your appraisal, identifying changes you need to make to improve the care or services you provide and identifying your strengths so you can build on them further

Colleague feedback:

  • At least once in your revalidation cycle, you must collect,  reflect on and discuss feedback from your colleagues about their experience of working with you
  • Your colleagues must be chosen impartially from across your whole scope of practice and must include people from a range of roles who may not be doctors
  • You should use an appropriate tool which meets the requirements laid out by the GMC, or, in exceptional circumstances, agree an alternative with your RO
  • Feedback must be of a sufficient quantity to give an accurate and comprehensive picture of how your colleagues perceive you
  • You must reflect on what the feedback means for your current and future practice, and discuss it at your appraisal, identifying changes you need to make to improve the care or services you provide and identifying your strengths so you can build on them further
  • Feedback should be anonymous where possible but if you are able to identify colleagues through the feedback, you must remain professional, particularly where the feedback may not be favourable

Compliments and complaints:

  • Compliments and complaints are important sources of evidence that can facilitate reflection on your practice – they are a type of unsolicited feedback
  • You must declare and reflect on all formal complaints made about you, and you should reflect on any other complaints that provide useful learning
  • You should think broadly about sources of compliments and complaints that you can learn from, including feedback about the team, or wider environment, in which you work, particularly where it has had an impact on your individual practice
  • At your appraisal you should discuss your insight and learning from the compliments, or complaints, and demonstrate how you have reflected on your practice and what changes you have made or intend to make
  • If you have no complaints or compliments in which you are personally named, you can consider reflecting on other relevant feedback that has helped you change your practice or confirmed good practice you already do

Additional information required for your appraisal:

  • Information about your practice
  • Probity statement
    • Including guidance on research, adequate and appropriate insurance or indemnity, being honest and trustworthy, providing and publishing information about your services, writing reports and CVs, giving evidence and signing documents, cautions, official inquiries, criminal offences, findings against your registration, and suspensions and restrictions on your practice, financial and commercial dealings and conflicts of interest
  • Health statement
    • Including guidance on registration with a GP, not treating yourself, immunisation, and consulting a suitably qualified colleague if you have, or suspect, a serious condition that could pose a risk to patients

Dr Susi Caesar (April 2018)