The GMC s role in continuing professional development: Annexes

Transcription

1 The GMC s role i cotiuig professioal developmet: Aexes

2 Cotets Aex A: Review of the GMC s role i doctors cotiuig professioal developmet: fial report Executive summary Sectio 1: Backgroud Sectio 2: Defiig CPD for doctors Sectio 3: Remit ad objectives of the review Sectio 4: Workig methods Sectio 5: Regulatory cotext ad drivers for chage Sectio 6: Uderstadig the eeds of others Sectio 7: The role of the GMC Sectio 8: Addig regulatory value Sectio 9: Further work Sectio 10: Coclusios ad recommedatios Appedix A: Terms of referece Themes ad issues for the review Appedix B: Workig priciples for the review Appedix C: Workig group membership Appedix D: Models for regulatig CPD: iteratioal perspective Aex B: Draft cotiuig professioal developmet guidace for cosultatio Priciples of cotiuig professioal developmet Itroductio Plaig your CPD Carryig out your cotiuig professioal developmet Evaluatig the impact of your CPD Esurig quality ad value The role of others Help for doctors Appedix A Further readig Aex C: Summary of resposes from our survey o the role of the GMC i CPD March to August 2011 Geeral commets about the role of the GMC Aex D: Cosultatio questios A1 A2 A3 A4 A4 A5 A6 A8 A11 A14 A18 A18 A20 A21 A23 A24 A25 B1 B2 B3 B5 B7 B10 B11 B12 B13 B14 B14 C1 C3 D1

3 Aex A Review of the GMC s role i doctors cotiuig professioal developmet: fial report A1

4 Executive summary Doctors have a duty to keep their kowledge ad skills up to date. This cotiuig professioal developmet (CPD) is a itegral part of doctors professioalism. Although it should be rewardig i its ow right, CPD is ot a ed i itself. Its purpose is to eable doctors to cotiue to provide high stadards of care for their patiets throughout their careers. As the regulator, the GMC is resposible for esurig that doctors maitai those high stadards ad that their participatio i CPD activities supports the better care of patiets ad the public. This review has focused o how doctors should approach their CPD, how employers ad others ca create a culture ad eviromet which supports appropriate CPD ad the GMC s role i promotig awareess of relevat CPD. Ulike udergraduate ad postgraduate traiig, there is o formal CPD curriculum for all doctors to follow. Nor should there be. Each doctor s CPD eeds will be differet, depedig o the role they are udertakig, the eeds of the service i which they are workig ad, above all, the eeds of their patiets ad the commuity. The idetificatio of those learig eeds ad agreemet o how they are to be addressed should therefore be the resposibility of the idividual doctor i discussio with the idividuals, teams ad orgaisatios with which they work. The pricipal mechaisms for this are persoal developmet plas, job plaig ad appraisal. The GMC s role i regulatig doctors CPD is ot to prescribe what CPD doctors must do or how they must do it, but to provide a framework of priciples aroud which doctors should pla, udertake ad evaluate their CPD activity. The guidace which accompaies this report provides that framework of priciples. To have their full effect they must be embedded i the processes for appraisal ad i the way appraisal is quality assured. By usig appraisal to cofirm that doctors are practisig to the appropriate stadards revalidatio will provide assurace that they are participatig properly i CPD. Primary resposibility for doctors cotiuig learig rests with doctors themselves. But they must be supported i this by a workplace culture which provides opportuities for all staff to maitai ad develop their skills. This applies ot just to cosultats but equally to groups which sometimes struggle to access resources for their CPD, such as locums, sessioal GPs ad staff grade doctors. A umber of recet reports have recogised the importace of istitutioal support for CPD 1. The framework provided by our guidace offers a proportioate approach which balaces the legitimate iterests of employers ad cotractors of doctors services with the eeds of doctors. The GMC is ot a provider of CPD ad apart from i those areas where it has particular expertise related to its role as the regulator, it should ot become oe. However, the GMC s uique positio makes it well placed to brig to the otice of doctors treds ad issues affectig their professioal practice ad key developmets i medicie which are relevat for all doctors. It has already begu to do this i isolated istaces ad the itroductio of revalidatio will make this more importat i the future. This will help doctors to reflect o their learig eeds ad decide what CPD will be most valuable for them i meetig the eeds of their patiets. A2

5 Sectio 1: Backgroud 1 Lord Patel s March 2010 report Recommedatios ad Optios for the Future Regulatio of Educatio ad Traiig examied how the GMC s role would eed to develop i the light of the resposibilities it was about to take o for regulatig postgraduate medical educatio ad traiig 2. That report also recogised that doctors learig does ot ed with the completio of formal postgraduate traiig ad or does the resposibility of the GMC. 2 Oce out of traiig doctors still have most of their careers ahead of them. Durig that time what they leart at medical school ad i postgraduate traiig will eed to be updated to reflect chages i practice ad techology, ad i society s expectatios of the way doctors practice. 5 Lord Patel oted that the GMC had issued CPD guidace for doctors i But he was midful that much had moved o. His report therefore recommeded that: The GMC should update its 2004 CPD guidace ad re-examie how the regulatory role i CPD should be exercised so as to support doctors i meetig the requiremets of revalidatio ad providig high quality care for their patiets, whilst preservig the value of CPD for idividual professioals. 6 Lord Patel s recommedatio provided the impetus for a review of the GMC s role i doctors CPD. This report sets out the coclusios of that review. 3 Doctors aticipate ad respod to those chagig demads through CPD. The ous is o them to show that they are maitaiig appropriate professioal stadards. Revalidatio will provide the public with assurace that they are doig so ad evidece of participatio i CPD will be part of that assurace. 4 The challege for the GMC is to regulate doctors CPD activity i a way which serves the iterests of patiets, while also supportig doctors ad recogisig the eeds of those who employ or cotract their services. 1 Educatio ad Traiig: A report from the NHS Future Forum (13 Jue 2011) ad the Govermet respose to the NHS Future Forum report, Jue GMC, Fial Report of the Educatio ad Traiig Regulatio Policy Review: Recommedatios ad Optios for the Future Regulatio of Educatio ad Traiig, 18 March Ibid, review recommedatio 20 A3 4 World Federatio for Medical Educatio, Cotiuig Professioal Developmet (CPD) of Medical Doctors: WFME Global Stadards for Quality Improvemet, WFME Office, Uiversity of Copehage, Demark, 2003, p6. Academy of Medical Royal Colleges, Cotiued Professioal Developmet; Guidelies for recommeded headigs uder which to describe a College or Faculty Scheme, 2010, p3 Grat J, The Good CPD Guide: A practice guide to maaged cotiuig professioal developmet i medicie, 2d Editio, Radcliffe, 2011.

6 Sectio 2: Defiig CPD for doctors 7 The first problem for ay regulator becomig ivolved i CPD is beig clear about what it is tryig to regulate ad why. 8 There is o uiversally agreed defiitio of CPD for doctors. However, it is geerally uderstood to refer to all the processes ad activities pursued by doctors followig their completio of formal postgraduate traiig that eable them to maitai ad cotiually develop their professioal practice. Buildig o this ad with referece to the defiitios used by others our review has used the followig defiitio: 9 We have also bee clear that CPD is ot a ed i itself. Its purpose is to help improve the safety ad quality of care provided for patiets ad the public. It is therefore liked to doctors performace as idividuals ad as members of teams i the orgaisatios where they work. 10 As we will see i sectios 7 ad 8 of this report, this defiitio ad purpose of CPD shaped the way the workig group felt CPD should be regulated. A cotiuig learig process, outside formal udergraduate ad postgraduate traiig, which eables doctors to maitai ad improve their performace across all areas of their medical practice through the developmet of kowledge, skills, attitudes ad behaviours. It covers all learig activities, both formal ad iformal, by which doctors keep up to date. Sectio 3: Remit ad objectives of the review 11 The terms of referece for the review are reproduced at Appedix A. Our task was to examie ad make recommedatios o the GMC s role i CPD. 12 The required outputs were: a a report to the Cotiued Practice, Revalidatio ad Registratio Board ad to Coucil settig out recommedatios for the role of the GMC i CPD b followig cosultatio o the report ad draft guidace, a updated versio of the GMC s 2004 CPD guidace. 13 To support our terms of referece ad aid our developig thikig we established some uderlyig priciples for the review. These provided a template agaist which we could test our developig ideas (Appedix B). A4

7 Sectio 4: Workig methods 14 A small workig group, chaired by a lay member of the GMC, was established to udertake the review. The group comprised medical ad lay members from the GMC, as well as represetatives from the Academy of Medical Royal Colleges (AoMRC), NHS Employers ad the Committee of Geeral Practice Educatio Directors (COGPED). The full membership is show at Appedix C. 15 The workig group recogised that its thikig eeded to be iformed by a wider rage of views. These were sought i several ways. O 30 March 2011 we held a stakeholder semiar o our emergig ideas. The semiar brought together doctors (icludig cosultats, GPs, SAS grade doctors, ad traiees), employers, academics, represetatives of the medical royal colleges, departmets of health i Eglad ad Scotlad, deaeries, professioal associatios ad the idepedet sector, as well as medical ad lay members of the GMC s referece commuity. 16 Issues arisig from the review were also amog the topics discussed at two further semiars orgaised by the GMC for SAS grade doctors ad ew cosultats i May From March to mid July 2011 we ra a olie survey askig doctors their views of the GMC s role i CPD. Details of the survey were widely trailed i the GMC s e-bulletis to doctors ad i the commuicatios of other orgaisatios such as the medical royal colleges. The survey elicited 1,872 resposes. 18 As well as cosiderig the regulatio of CPD as it relates to medicie i the UK, we also looked at other professios both withi ad outside the health sector. This was supplemeted by a literature review of how regulators worldwide approached this issue. 19 We have also beefited from the results of research ito the effectiveess of doctors CPD commissioed by the GMC ad the AoMRC Details of the learig from the semiars, survey, literature review ad research are provided i sectio 6 of this report. 21 To supplemet the research ad egagemet activities already udertake, we also commissioed loger term research lookig at the liks betwee doctors participatio i CPD ad their practice ad performace. That research will ot be completed before this review reports its coclusios. However, we aticipate that the learig derived from the research will help to iform the GMC s future work. 22 The workig group met o four occasios betwee November 2010 ad July The recommedatios i this report represet the group s coclusios. They are iteded to provide the basis for a full public cosultatio o our future role. A5 5 Schostak J, Haso J, Schostak J, Brow T, Driscoll P, Starke I, Jekis N, The Effectiveess of Cotiuig Professioal Developmet, College of Emergecy Medicie, 2010

8 Sectio 5: Regulatory cotext ad drivers for chage 23 To uderstad our possible future role i the regulatio of CPD, it is first ecessary to say somethig about the cotext withi which we operate ad the drivers for chage. The GMC s positio 24 Sectio 5 of the Medical Act 1983 gives the GMC the geeral fuctio of promotig high stadards of medical educatio ad coordiatig all stages of medical educatio. These geeral fuctios have ot, util recetly, bee accompaied by the sort of specific powers which might give the GMC direct regulatory purchase o doctors CPD. 25 Revalidatio will give the GMC ew legal powers 6 ad a focus for doctors future CPD activity. 7 This is because evidece of participatio i CPD will be part of the supportig iformatio that doctors will brig to their aual appraisals to show that they are keepig up to date ad workig to ehace the quality of their practice. 26 For this reaso, doctors eed clear guidace from the GMC about what is expected of them i relatio to CPD ad revalidatio. 8 Our 2004 guidace, Cotiuig Professioal Developmet, was well received at the time it was published but, as Lord Patel recogised, it is ow out of date. 27 More geerally, Good Medical Practice (2006) imposes a duty o all doctors to keep [their] kowledge ad skills up to date throughout [their] workig life ad regularly take part i educatioal activities that maitai ad further develop [their] competece ad performace. Doctors fulfil that duty through their participatio i CPD. How they have doe that has bee largely left to idividual doctors, the medical royal colleges ad other providers to get o with. Exteral drivers for chage 28 Revised CPD guidace is oe elemet, but revalidatio has also prompted calls for a more rigorous approach to CPD ad reforms to the oversight of cotiuig professioal developmet to support doctors i meetig the requiremets of revalidatio 9. Importatly for our review, the calls for more rigour have bee balaced by recogitio that [E]ffective CPD schemes are flexible ad largely based o self-evaluatio ad the importace of the lik betwee CPD ad appraisal 10. These cosideratios have shaped our thikig about how the GMC ca add value without itroducig rigidity ad disproportioate burde. 6 Amedmets to the Medical Act 1983 i relatio to revalidatio (ot yet i force) will eable the GMC to set the requiremets for retaiig a licece to practise. Oe of these requiremets will be participatio i CPD. 7 This existece of legislatio to support revalidatio meas that separate statutory powers specifically relatig to CPD are ot required at the preset time. 8 GMC, Respose to our revalidatio cosultatio, 2010, pp Govermet White Paper, Trust, Assurace ad Safety The Regulatio of Health Professioals i the 21st Cetury, HMSO, 2007, p71 10 Departmet of Health (Eglad): Medical Revalidatio Priciples ad Next Steps: The Report of the Chief Medical Officer for Eglad s Workig Group, 2008, p24 11 Royal College of Physicias, Doctors i Society: Medical professioalism i a chagig world, 2005 ad R Leveso, S Dewar, S Shepherd, Uderstadig doctors: Haressig professioalism, Kigs Fud, 2008 A6

9 29 There have bee other reports cocered with the challege of embeddig i medicie a culture of life-log commitmet to persoal ad professioal learig 11. These have recogised the risk that professioal values fostered durig a doctor s years of educatio ad traiig might atrophy durig the much loger period of established practice that follows. 30 Govermet proposals have also sharpeed the focus o who has resposibility for CPD. The Departmet of Health (Eglad) cosultatio Liberatig the NHS: Developig the Healthcare Workforce stated that the curret system lacks clarity about the resposibility for cotiuig professioal developmet ad this leads to uderivestmet ad wasted opportuities for staff to develop ad respod to chage I the ew NHS the resposibility for ivestig i the existig workforce ad esurig sustaiability of specialist skills will sit where it should with employers 12. This view has bee reiforced recetly by a report from the NHS Future Forum which recommeded that employers should prioritise the provisio of CPD 13. The Govermet has welcomed this recommedatio, otig that the NHS Costitutio commits all employers supplyig NHS fuded services to provide staff with persoal developmet ad access to appropriate traiig for their jobs Yet this curret emphasis o the importace of CPD occurs i a ecoomic climate which places cosiderable pressure o the resources available for CPD. This has iformed our guidace to doctors as to the focus of their CPD activities ad our thikig about how the guidace might be embedded i the workplace. The roles of others 32 Examiatio of the regulatory cotext must recogise the roles of others i doctors CPD. 33 Primary resposibility for remaiig up to date ad fit to practise rests with the idividual professioal. But, as we have see, employers have a resposibility to support doctors i this. The medical Royal Colleges ad Faculties, trade bodies, professioal associatios ad others also support their members by operatig CPD schemes, producig guidace for their members ad providig CPD. The AoMRC has doe much to itroduce a commo approach to the recordig, orgaisatio ad quality assurace of CPD schemes across the differet specialties I medicie there is both a culture of CPD participatio ad a ifrastructure to support it. This ecessarily affects the ature of the regulatory itervetios required. We eed to make sure that we add value ad do ot duplicate or usurp work that is carried out more appropriately ad effectively by others. This is what the Coucil for Healthcare Regulatory Excellece refers to as right-touch regulatio Departmet of Health (Eglad), Liberatig the NHS: Developig the healthcare workforce, December 2010, p24 13 Educatio ad Traiig: A report from the NHS Future Forum, 2011, p Govermet respose to the NHS Future Forum report, 2011, p See Academy of Medical Royal Colleges, Te Priciples for College/Faculty CPD Schemes ad Guidelies for recommeded headigs uder which to describe a College or Faculty CPD scheme 16 Coucil for Healthcare Regulatory Excellece, Right Touch Regulatio, August 2010 A7

10 Sectio 6: Uderstadig the eeds of others 35 A upublished 2010 survey of doctors about the cotet of GMC Today showed that CPD was the area of the GMC s work i which doctors were most iterested. This idicated a opportuity for us both to add value ad satisfy a umet eed. GMC stakeholder semiar 36 Our stakeholder semiar o 30 March 2011 (see paragraph 15 above) helped us to uderstad how we might begi to meet that eed. The key messages were: CPD should be directed towards improvig the care provided for patiets ad the delivery of the service. Doctors should be ecouraged to take resposibility for their ow learig. Reflectio drives chage i performace ad is the key to good CPD. The GMC should take a light touch, settig a framework of high level priciples supported by clear guidace. The GMC should avoid micro-maagemet of doctors CPD ad duplicatio of the work of others. Aual appraisal i the workplace is cetral to the idetificatio of doctors CPD eeds ad to moitorig the effectiveess of CPD activity. There is a eed for more advice o the use of CPD i appraisal. Revalidatio will make doctors more accoutable for their CPD activity, but it must ot reduce CPD to a tick-box exercise. It is importat to recogise that some aspects of CPD ca be valuable eve if their outcomes are difficult to measure. The GMC should sig-post CPD that might be relevat for doctors. Cosideratio should be give to the eeds of doctors i less tha full time practice ad those returig to medical practice. Research was required o how CPD (or the lack of it) is liked to poor performace ad cocers with fitess to practise. 37 These themes are reflected i the draft CPD guidace that the workig group has developed. A8

11 GMC olie survey 38 Some of the messages from the semiar have bee reiforced by the results of our olie survey of doctors (see paragraph 17 above). As this was ot a scietific study of doctors views we must be cautious about what we ifer from the resposes received. 39 Nevertheless, amog the 1,872 respodets there was a clear view that primary resposibility for doctors professioal developmet rests with doctors themselves (86%). 81% of respodets said they had the opportuity to discuss their CPD eeds ad persoal developmet at appraisal, but that this was ot ecessarily followed up. For may there were cocers about the quality ad effectiveess of appraisal at the preset time. 40 Ecouragigly, 79% of respodets said that their CPD activity over the last five years had helped to improve the quality of the service or care give to their patiets. Feedback o what CPD activities had iflueced or chaged practice yielded a wide rage of resposes. This poits to the importace of flexibility i the way CPD activities are uderstood ad regulated. Resposes also highlighted the value for may doctors of learig udertake with other members of the healthcare team ad with peers. 41 I terms of the GMC s role, doctors saw value i the developmet of high level priciples ad guidace, but did ot wat detailed or prescriptive requiremets imposed o them. May saw a role for the GMC i workig with employers to support access to CPD. This was a particular cocer for SAS grade doctors ad those i part-time practice. Not surprisigly, may wated clarity about the CPD requiremets for revalidatio. 42 May of these themes are covered by our proposed guidace. 43 A more detailed accout of the survey results is o our website at org/educatio/cotiuig_professioal_ developmet/review.asp. Effectiveess of CPD report 44 The study commissioed by the GMC ad AoMRC ito the effectiveess of CPD has provided importat isights ito our future regulatory role ad some helpful otes of cautio. 45 The report looks at how doctors view their learig or the learig of others withi their orgaisatios, how this relates to coceptios of CPD, its provisio ad uptake, ad what costitutes effective CPD. A9

12 46 The report shows a culture i which doctors participatig i the study viewed CPD as a atural part of professioal life, ecessary for patiet safety ad rewardig 17. There is o sigle, correct way of doig CPD 18 but it was see as more likely to be effective whe doctors were able to determie their ow learig eeds through reflectio withi the totally of their practice. There was a tesio betwee the value of iformal, opportuistic learig that happes o the job ad the demads for icreasig accoutability for CPD activity ad the quatificatio of learig 20. There was a perceived dager that the tick-box method evoked a feelig of beig regulated ad that this i tur fostered a autopilot respose to attai the credit ratig rather tha a reflective learig experiece that led to a deeper ad more eriched uderstadig of practice 21. This was eatly ecapsulated i the fear of revalidatio leadig to the idustrialisatio of CPD failig to capture may idividual s learig eeds 22. Sice CPD aims to improve the care provided for patiets, it is imperative that this does ot happe. Lessos from other regulators 47 We spoke to a rage of regulators ad other bodies i the UK about their approaches to CPD 23. We also reviewed the systems operated by medical regulators worldwide. A summary of the approaches cosidered is at Appedix D. A detailed report o iteratioal models is o the GMC s website at org/educatio/cotiuig_professioal_ developmet/review.asp. 48 How CPD is regulated varies widely ad it is likely to be shaped by a rage of differet factors. These iclude the uderlyig culture of the professio, the ature ad complexity of the regulated activity, history ad societal expectatios, the purpose of the regulatory itervetio (to esure compliace or foster excellece, or both), the regulatory risk to be addressed ad the extet to which CPD serves as a proxy for revalidatio. Just as there is o sigle, right way of doig CPD, so there is o sigle right way of regulatig it. 49 I the ext sectio we look at the feedback we have received ad what the learig from other regulatory models should mea for our role. 17 Schostak J, Haso J, Schostak J, Brow T, Driscoll P, Starke I, Jekis N, The Effectiveess of Cotiuig Professioal Developmet, College of Emergecy Medicie, 2010, p Ibid p Ibid p Ibid p Ibid p Ibid pa Geeral Detal Coucil, Nursig ad Midwifery Coucil, Health Professios Coucil, Solicitors Regulatio Authority, Geeral Teachig Coucil for Eglad, Bar Stadards Board, Royal Istitute of British Architects, Istitute of Chartered Accoutats of Eglad ad Wales. We also reviewed the approaches to CPD of each of the other UK health regulators through the iformatio o their websites. A10

13 Sectio 7: The role of the GMC 50 I defiig our role we first eeded to uderstad what it is we are tryig to regulate ad why. 51 The defiitio of CPD which we offered i sectio 2 (paragraph 8) makes clear that CPD is ot simply a matter of courses ad cofereces. It covers all learig activities, both formal ad iformal, by which doctors keep up to date. 52 The defiitio also emphasises that CPD is ot a ed i itself. Its purpose is to help improve the safety ad quality of care provided for patiets ad the public. It is therefore liked to doctors performace as idividuals ad as members of teams i the orgaisatios where they work. Supportig the purpose of CPD: some otes of cautio for the regulator 53 It is a truism that CPD is about idividual developmet. Professioal regulatio seeks to promote good practice. It does so by settig stadards ad requiremets, defiig outcomes, measurig compliace ad takig actio i cases of o-compliace. Our first challege is to esure that our regulatory tools do ot distort professioal developmet i a way which udermies the goal of ehacig patiet care. Ievitably, this iformal CPD activity is hard to measure ad resistat to providig the sort of assuraces a regulator might seek. 55 Measurig the effect o performace is eve more elusive. For this reaso, may regulatory models ted to record activity rather tha impact o practice. Typically, they require the accumulatio of CPD hours over a specified period. These models are helpful i professios where there is o established culture of CPD because the regulator ca audit a sample of CPD returs to moitor basic compliace, although these may say little about the CPD s effect o a practitioer s actual performace. Coutig CPD hours or credits may also be relevat where there are o itermediate structures betwee the regulator ad regulated practitioer which support the CPD. 56 I medicie, those structures do exist, for example through the work of the medical Royal Colleges ad Faculties (which require members to udertake 250 hours CPD over five years) ad professioal associatios, through the role of aual appraisal, job plaig ad doctors persoal developmet plas. Above all, revalidatio will give the GMC a isight ito doctors performace which makes our detailed scrutiy of the level of idividual CPD activity superfluous. 54 What we have leared from our semiars, surveys ad research is that for may doctors the most effective CPD is the sort of experietial learig that occurs aturally i the workplace, almost as a by-product of practice, rather tha through activities formally desigated as CPD. A11

14 57 Regulatory models differ i the extet to which they are prescriptive about the CPD professioals must udertake. The GDC, for example, curretly requires detists to udertake a miimum of 250 hours CPD across a five year cycle, of which 75 hours must be verifiable by the regulator. The verifiable CPD should iclude medical emergecies, disifectio ad decotamiatio, radiography ad radiatio protectio. Failure to comply results i removal from the GDC s register 24. I the USA several jurisdictios take a similar approach for doctors. Califoria requires all physicias ad surgeos to complete madatory cotiuig educatio i the subjects of pai maagemet ad the treatmet of the termially ill ad dyig patiets Our workig group did ot favour such approaches. Although prescriptive regulatory models provide certaity for the practitioer ad the public, medicie is too diverse, ad the regulator too far from the coal face of actual practice, to be able to determie what CPD is most relevat for each doctor ad for the service withi which he or she works. There would be a real risk of divertig doctors eergies ad resources from more valuable learig simply to comply with regulatory requiremets. 59 The workig group was clear that the CPD eeds of idividual doctors are best determied by the doctors themselves i discussio with their colleagues, teams ad the service withi which they work. The effective use of job plaig, aual appraisal ad persoal developmet plas should be cetral to this. The role of the GMC is to provide a framework of priciples ad guidace withi which those discussios should take place. The role of revalidatio 60 Revalidatio is fudametal to our regulatio of CPD, but it is importat that doctors do ot regard it as the impetus for, or the goal of, their CPD. A idividual s CPD must be directed towards improvig ad maitaiig practice. Revalidatio is simply a by-product of that process. 61 The clear message from the GMC s 2010 revalidatio cosultatio, The Way Forward, was the eed to simplify the model. Doctors will do what is ecessary for them to get through revalidatio, but the GMC must esure that revalidatio does ot drive doctors towards a level of miimum compliace which adds o developmetal value, oly regulatory burde. Clear priciples ad guidace aroud CPD from the GMC, rather tha detailed ad prescriptive requiremets, will support this. 62 Revalidatio will also serve the importat fuctio of eablig the GMC to look at doctors performace rather tha at the CPD which cotributes to performace. If a doctor is practisig to appropriate professioal stadards there is o eed for GMC regulatory scrutiy of the CPD iput ito that performace. Such scrutiy is more appropriate locally i the cotext of workplace aual appraisal. 24 Cotiuig Professioal Developmet (CPD) for Detists, Geeral Detal Coucil, December America Medical Associatio, State Medical ad Licesure Requiremets ad Statistics A12

15 Quality assurace ad accreditatio of CPD 63 We have cosidered whether the GMC should quality assure CPD provisio or accredit specific courses, evets or providers. It was suggested to us that the GMC should quality assure CPD i the same way that we quality assure udergraduate medical educatio ad postgraduate traiig. The workig group cocluded that we should ot do so. 64 As this report has already oted, the most effective CPD activity is ofte the sort of iformal, experietial learig that occurs i the workplace i the ormal course of medical practice ad which is least susceptible to measuremet. 65 Quality assurig or accreditig more formal CPD that is structured courses or programmes would ievitably result i the creatio of preferred providers ad preferred types of activity eve though the activities themselves may be the least relevat to the idividual. The resource implicatios are also likely to be formidable. 67 If the GMC is to be satisfied about high stadards of medical practice (to which CPD is a importat cotributor) it is more relevat to look at the outputs of revalidatio ad the systems which will support it. Plas for the quality assurace ad audit of revalidatio are beig developed. Withi this work, the GMC will cotiue to egage with the systems regulators to esure that orgaisatios have i place systems which will support access to appropriate CPD for doctors. 68 Above all, the workig group was midful that, i cotrast to our powers to regulate udergraduate educatio ad postgraduate traiig, the GMC has o statutory powers to regulate employig or cotractig orgaisatios or the providers of CPD. We do ot thik the GMC should seek such powers ad, at the preset time, it is ulikely they could be secured. 69 We have therefore cocluded that it must be a doctor s resposibility to esure that their CPD activities are relevat, effective ad provide good value for moey. 66 We also oted that whereas udergraduate ad postgraduate traiig have set curricula or outcomes that everyoe must meet ad there is clear orgaisatioal resposibility for delivery ad accoutability to the GMC, this is ot the case with CPD where doctors eeds are more idividualised. It is uclear what we would be quality assurig. A13

16 Should the GMC provide CPD? 70 The workig group cosidered whether the GMC should be a provider of CPD for doctors. We oted, for example, that the Good Medical Practice i Actio iteractive case studies o our website 26 offer somethig that looks very much like CPD. These provide the opportuity for users to apply the priciples of Good Medical Practice to real life scearios. We have particular expertise i this area that makes it appropriate for us to provide learig materials. We should be alive to other similar areas where our uique positio will eable us to add value. 71 However, we cosidered that such examples are likely to be rare. I geeral, others will be better placed ad have more relevat specialist expertise to provide CPD, ad it is more appropriate that they should do this. Nevertheless, we are of the view that the GMC does have a role i drawig to doctors otice key developmets which may be relevat to their learig eeds. We discuss this further i sectio 8 below which looks at where we ca add value. Sectio 8: Addig regulatory value GMC guidace o CPD 72 Oe of the required outputs from this review was a ew set of GMC guidace for doctors o CPD. The draft guidace is available o our website. 73 The guidace reflects the learig described i sectios 6 ad 7 of this report. I particular, this icludes the eed for the GMC to establish a framework of priciples ad behaviours to guide doctors i the way they orgaise their CPD rather tha attempt to prescribe or micro-maage their idividual activity. The guidace will provide olie liks to a rage of orgaisatios, tools ad examples of good practice which should help doctors to maage their CPD effectively. 74 The guidace makes clear that doctors have a professioal resposibility to idetify ad act o their idividual CPD eeds. But because CPD is aimed at improvig the safety ad quality of care provided for patiets ad the public, this must take accout of the eeds of the teams ad orgaisatios withi which doctors work, ad the eeds of their patiets ad of the wider commuity. 75 The guidace recogises the importace of flexibility i what is treated as CPD ad i how CPD eeds are met. Oe size, oe learig method, oe curriculum, will ot fit all. A14

17 76 The guidace also highlights the importace of plaig. Although doctors eed to be alert to the uexpected opportuities for learig that arise from their day to day practice, learig caot be left to happestace. Good Medical Practice requires doctors to reflect o their stadards of medical practice. This icludes reflectig o their learig eeds ad how they are to be addressed. Such reflectio is key to good CPD outcomes. We highlight the importace of appraisal, job plaig ad persoal developmet plas i this process. 77 Reflectio is fudametal to evaluatig the impact of CPD. The guidace suggests how the use of evidece, reflectio ad evaluatio, ad commitmet to practice chage as part of the learig cycle, are more likely to lead to chages i behaviour. Equality ad diversity issues arisig from the guidace 78 The workig group cosidered the positio of doctors who are i less tha full-time practice or who are plaig, or returig from, a career break. We are clear that patiets ad the public have a right to expect that all licesed doctors remai up to date i all areas of their work, regardless of the circumstaces of their practice. Doctors therefore eed to take advice from their college, their employer ad others to support them i this. 79 Our guidace also highlights the resposibilities of employers, cotractig orgaisatios ad maagers to esure that all members of their workforce have the opportuity to maitai ad develop their skills, icludig groups who sometimes struggle to access the resources that will support their CPD, such as sessioal GPs, locums ad staff grade doctors. Embeddig our guidace i local processes ad appraisal systems will help to reiforce this message. 80 By takig a flexible approach i our guidace to what costitutes CPD we have tried to esure that those who may have less ready access to formal modes of CPD are evertheless able to have their iformal activities ackowledged. 81 As explaied i paragraphs below, we also see opportuities for the GMC to use its uique positio to brig to doctors attetio issues that may be relevat for their CPD. Particularly for doctors who are ot part of a college, specialty or professioal associatio etwork, this will provide aother meas of helpig them to reflect o their CPD eeds. 82 Some of those we spoke with durig the course of our review felt the GMC should require Colleges, employers ad others to provide resources for, or access to, the CPD they required. The GMC has o regulatory jurisdictio over other orgaisatios ad we caot compel other orgaisatios to follow GMC guidace. Nor ca we require doctors to be members of those orgaisatios or follow the stadards that they set. However, our guidace to doctors sets out where we cosider that others have a resposibility to support doctors i meetig their CPD eeds. I the ext sectio we cosider what steps the GMC should take to embed its guidace i the practice of others A15

18 Embeddig CPD i the practice of others 83 Our guidace will oly be effective if it is successfully embedded i the way doctors approach their CPD ad i the way CPD is supported by orgaisatios ad medical maagers, icludig Resposible Officers. The guidace makes specific liks to appraisal ad persoal developmet plas so as to embed our CPD priciples i workplace processes. It also makes referece to the roles of others i supportig doctors CPD. We ote, for example, that the Resposible Officer Regulatios impose a statutory duty o Resposible Officers to cooperate with the GMC i relatio to the GMC s revalidatio fuctios. The GMC should reiforce this by settig out its expectatios o CPD i its guidace to Resposible Officers. Liks should also be made through the Resposible Officer guidace issued by the Health Departmets ad through the documetatio beig developed i Eglad by the Revalidatio Support Team. 84 The GMC must also work with the systems regulators to esure that provisio for CPD is properly reflected i the stadards required of orgaisatios across the UK ad with accoutable employers orgaisatios to esure that GMC guidace is embedded i local processes. 85 Some of those with whom we spoke wished us to go further ad specify the ature of the CPD provisio that Colleges, employers ad others must make, particularly i relatio to resources for, ad access to, CPD. However, the workig group was clear that the GMC has o legal power to impose requiremets o other orgaisatios i relatio to CPD. It was also clear about the eed to recogise the boudaries betwee the role of the regulator ad that of employers, Colleges ad other providers of CPD. Sharig what we kow 86 I paragraph 81 we state that the GMC should ot, i geeral, be a provider of CPD. Nor should we attempt to prescribe the CPD that idividual doctors must udertake. The GMC should, however, do more to use its uique positio ad relatioship with doctors to help them idetify areas of learig which may be relevat to them. 87 Util recetly the GMC held very little iformatio about either idividual doctors or treds across the professio as a whole. That is chagig. For example, our fitess to practise procedures provide a wealth of data which help us to idetify treds ad potetial areas of regulatory risk. Research tells us that doctors pose a higher regulatory risk at key trasitio poits i their careers. We also have research which highlights issues with prescribig errors, ot just amog traiees, but across all grades. We publish this sort of iformatio o our website, but might do more to follow it up i ways which would ecourage idividuals or groups of doctors to reflect further o their ow practice ad their ow particular CPD eeds I The state of medical educatio ad practice i the UK 2011 report published i September 2011, the GMC bega the process of drawig upo the wide rage of iformatio it holds to provide a picture of today s medical professio ad some of the key challeges it faces. The aim of the report is to iitiate discussio about these challeges with professioal bodies, patiet groups, employers, educators, other regulators, ad doctors themselves. A16

19 88 For example, we kow that iteratioal medical graduates are more likely to face challeges i makig the cultural trasitios ecessary for UK medical practice. We have a resposibility to promote the sort of good practice which will help these trasitios. At preset, iteratioal medical graduates receive a copy of Good Medical Practice whe they register ad are the left, by the GMC at least, to get o with thigs. The curret review of the PLAB test will look at this. But the GMC should do more to miimise the kow regulatory risks by highlightig areas where reflectio might be valuable. This is ot to usurp the resposibilities of employers to provide suitable iductio ad support. However, the ivolvemet of the regulator i drawig attetio to the issues amog relevat groups may provide impetus for actio where that is eeded. 89 Durig our work we saw a umber of reports of cocers about deficiecies i medical expertise i particular areas of practice. Where these relate to specialties ad where doctors are liked to colleges or other specialist etworks there are established mechaisms through which they ca access the learig they eed. Yet we saw examples of groups (otably locums, doctors o career breaks ad those workig part-time) who reported difficulty i accessig CPD. We also leared of rapidly developig fields of practice, such as geomic medicie, which are ot specialty specific ad with which doctors i all types of practice will icreasigly eed to become familiar. 90 The GMC would ot have the expertise to provide CPD i such areas, or should it. However, the workig group cosidered that the GMC should use its uique ad authoritative positio to highlight the importace of particular developmets i medical practice or wider issues of professioalism. Particularly for doctors who are ot part of a college, specialist associatio or other etwork, or who may be professioally isolated, the GMC is i a positio to help them make the lik to the iformatio they eed. 91 Revalidatio will, over time, give the GMC much richer iformatio about idividual doctors tha ever before. The GMC will kow about their scope of practice; their specialty; grade; the stage they have reached i their career, whether they are ew to UK medical practice or returig to practice. The workig group oted that it may, i future, be possible for the GMC to use its uique database to make coectios with idividual doctors or groups of doctors by targetig iformatio likely to be relevat for their professioal developmet. 92 This would be a sigificat step for the regulator to take. The GMC would eed to cosider carefully ay data protectio ad other legal implicatios. It would also eed to be clear that its role was ot to dictate the cotet of doctors CPD activity, but to facilitate doctors access to relevat learig or facilitate reflectio o whether that learig would be useful. Doctors have told us that they are iterested i receivig more iformatio from the GMC about CPD. This would be a step towards meetig that eed. A17

20 Sectio 9: Further work 93 This report sets out recommedatios for the GMC s future role i regulatig doctors CPD. But it is ot the fial word. The healthcare ladscape is costatly chagig ad the GMC s role i CPD will eed to reflect developmets. 94 Future chages to the shape of postgraduate traiig ad i techology may affect the way i which doctors eed to develop their kowledge ad skills oce they have completed formal traiig ad how those ew skills eed to be assured by the GMC. Other iitiatives, such as the credetialig of medical practice outside of traiig may also require the GMC to update the way it regulates. 95 The GMC must also esure that its approach cotiues to reflect research i the field, particularly the liks betwee CPD ad performace. The GMC should, for example, be able to use the learig from ogoig research to guide the sort of regulatory itervetios discussed i paragraphs Despite the ievitability of further chage, the workig group cosidered that the priciples set out i this report, ad particularly i the guidace, provide a good basis for the future regulatio of CPD. Sectio 10: Coclusios ad recommedatios 97 I 2010 the GMC assumed resposibility for regulatig the cotiuum of medical educatio ad traiig. The way i which it does this must reflect the differet ature of doctors educatio ad traiig eeds at differet stages of their careers. 98 Oce doctors have completed their formal postgraduate traiig their eeds, the eeds of their patiets ad of the service withi which they work will be particular to the circumstaces of their practice. The diversity of medical practice meas there is o CPD curriculum for all doctors to follow. 99 The GMC requires all licesed doctors to participate i CPD i order to maitai ad improve the stadards of their practice. Doctors do so because they recogise that this is itegral to their professioalism ad their duty to their patiets ad the public. What CPD activities will be appropriate must be for doctors themselves to determie havig regard to the eeds of their patiets ad the service i which they work. Revalidatio will show that they are doig so effectively. The task for the regulator, workig with others, is to provide a CPD framework which helps them to do this effectively. A18

21 Recommedatio 1: The GMC must provide a framework of priciples ad guidace to support doctors i plaig, udertakig ad evaluatig their CPD activities [paragraphs 36, 41, 46, 53-59]. Recommedatio 2: The effective use of job plaig, aual appraisal ad persoal developmet plas should be cetral to the idetificatio, cotet ad evaluatio of doctors CPD eeds [paragraphs 36, 56, 59, 62]. Recommedatio 3: The GMC should edorse the priciples ad guidace provided at Appedix 5 to this report [paragraphs 72-77]. Recommedatio 4: The GMC should work with the systems regulators, accoutable employers orgaisatios, the Health Departmets ad NHS Revalidatio Support Team to embed its CPD guidace i local processes of appraisal ad persoal developmet plaig [paragraphs 83-85]. Recommedatio 6: The GMC should ot quality assure or accredit CPD provisio. Istead, its focus should be o the outputs of doctors revalidatio, to which CPD is a iput [paragraphs 63-69]. Recommedatio 7: The GMC should explore how it might brig to doctors attetio developmets i medical practice or professioalism which may be relevat to their CPD. It will be for doctors to determie how those issues affect their practice ad whether they should be addressed through their CPD [paragraphs 86-92]. Recommedatio 8: The GMC should ot, i geeral, be a provider of CPD for doctors except i those discrete areas where its uique positio as the regulator eables it to add value [paragraphs 70-71]. Recommedatio 9: The GMC should commissio research o how CPD (or the lack of it) is liked to poor performace ad cocers with fitess to practise [paragraphs 36, 95]. Recommedatio 5: The GMC s revalidatio guidace to Resposible Officers should highlight the relevace of our CPD guidace [paragraph 83]. A19

22 Appedix A: Terms of referece Backgroud 1 Uder sectio 5 of the Medical Act 1983 the GMC has the geeral fuctio of promotig high stadards of medical educatio ad co ordiatig all stages of medical educatio. 2 Good Medical Practice requires doctors to keep their kowledge ad skills up to date throughout their workig lives. 3 I 2004 the GMC published the guidace booklet Cotiuig Professioal Developmet which made explicit ways i which doctors might idetify their learig eeds ad udertake their professioal obligatio to keep up to date. 4 Sice 2004, much has chaged. The merger of PMETB with the GMC has caused us to look across the cotiuum of medical educatio ad traiig ad to cosider our role at each stage. This icludes cosideratio of how we fulfil our objective of esurig proper stadards i the practice of medicie oce a doctor s formal traiig is complete. Progress towards the itroductio of revalidatio has placed greater emphasis o doctors CPD activity as a meas of demostratig that they remai up to date ad fit to practise throughout their careers. At the same time, the ecoomic dowtur is puttig greater pressure o the resources available to support doctors CPD activities. 5 These ad other developmets make it ecessary to update our 2004 guidace. I doig so we also eed to look more broadly at the role of the regulator i relatio to CPD. This was oe of the coclusios of Lord Patel s 2010 report settig out recommedatios ad optios for the future regulatio of educatio ad traiig. Lord Patel recommeded: GMC should update its 2004 CPD guidace ad re-examie how the regulatory role i CPD should be exercised so as to support doctors i meetig the requiremets of revalidatio ad providig high quality care for their patiets, whilst preservig the value of CPD for idividual professioals. 6 At its meetig o 13 July 2010 the Coucil of the GMC accepted this recommedatio. 7 A review of the GMC s role i CPD will follow the terms of referece set out below. Purpose 8 To examie ad make recommedatios o the GMC s role i CPD. A20

23 Themes ad issues for the review Theme 1: uderstadig the terrai what other regulators do 9 The examiatio of the appropriate role for the GMC will be iformed by a review of the respective regulatory approaches to CPD take by other UK regulators ad by medical regulators i other jurisdictios. This will iclude lookig at how CDP activity is assured ad how it fits withi their wider regulatory regime. Theme 2: uderstadig the terrai the role of the medical royal colleges ad the AoMRC, ad the resposibility of idividual doctors 10 The review will cosider the role of the medical royal colleges ad faculties ad of the AoMRC as the setters of the priciples ad stadards for, ad as providers of, CPD. I doig so cosideratio will also be give to the provisio ad recogitio of CPD outside of the College systems ad how groups of doctors who are ot members of Colleges are able to access quality CPD. 11 The review will also cosider CPD as part of the professioalism of idividual doctors ad how it might be supported by employers. Theme 3: quality, cosistecy ad improvig medical practice 12 The review will cosider what steps the GMC should take to esure the quality ad cosistecy of CPD. Issues will iclude: a the CPD s cotributio both to improved medical practice geerally ad specifically revalidatio b the sufficiecy of the CPD priciples ad criteria that were the subject of the GMC s 2010 revalidatio cosultatio c the proper relatioship betwee College CPD requiremets ad the requiremets for revalidatio d how the trasparecy ad accoutability of CPD is assured through appraisal. Theme 4: CPD ad regulatory risk 13 The review will cosider the role of CPD i helpig to address areas of regulatory risk, such as momets of career trasitio, etry oto the GP or specialist registers or etry ito UK medical practice by o-uk medical graduates. Issues will iclude: a feedback loops from the GMC s work o stadards ad fitess to practise ad from research b whether there is a role for the GMC as a promoter or provider of CPD c whether the GMC has a role i supportig the CPD eeds of particular groups who may ot otherwise be sufficietly served by existig arragemets. Theme 5: legislatio ad guidace 14 I the light of coclusios reached, the workig group will make recommedatios as to whether the GMC should seek specific statutory powers i respect of the regulatio of CPD ad/ or update the GMC s 2004 CPD guidace. A21