9 Revalidation: Planning for Rollout - Annex B Options for roll-out Option 1: Random approach 1. The UKRDG considered a random approach which involves distributing recommendations evenly over the roll-out period using each doctor s GMC reference number. UKRDG members concluded that a random approach does not sufficiently meet the roll-out principles. 2. Pros: Basing the roll-out sequence on a doctor s GMC reference number ensures that no doctor is missed in the first revalidation cycle. The approach should be easily understood by doctors. It avoids peaks and troughs and should therefore be manageable and sustainable for the GMC. 3. Cons: The approach is based on the assumption that local systems within the NHS and other healthcare providers would be ready at the same time across the UK to support revalidation. This assumption is likely to be incorrect and the option therefore does not meet the readiness principle. The option would be unfair for those doctors working in environments that do not have appropriate appraisal processes and/or clinical governance systems in place. On this basis, the option does not meet the fair, equitable and non-discriminatory principle. Randomising which doctors go when also takes control away from local organisations, and would therefore impact on manageability for organisations and their ROs. Option 1: Random Even distribution by GMC number (5 year roll-out) Even distribution by GMC number (3 year roll-out) 45,000 45,000 45,000 45,000 45,000 75,000 75,000 75,000 B1
Option 2: By geographical location 4. The UKRDG considered a geographical approach whereby doctors would be revalidated in a sequence which is determined by their place of practice. For example, roll-out could be sequenced by country or by region. UKRDG members concluded that a geographical approach does not sufficiently meet the roll-out principles. 5. Pros: Similar to the random approach, it is simple and easy to understand. 6. Cons: Similar to the random approach, it assumes that all organisations within a country or region will be ready at the same time. It may involve bulk recommendations which may not be manageable or sustainable for ROs to prepare and deliver to the GMC. It may also encourage doctors to move locations to avoid revalidation. Option 2: Geographic location (3 5 year roll-out) Practicing in England (or particular region in England) Practicing in Wales (or particular region in Wales) Practicing in NI (or particular region in NI) Practicing in Scotland (or particular region in Scotland) Practising in the UK but have a non-uk address 52,500 52,500 52,500 3,000 3,000 3,000 2,000 2,000 2,000 6,000 6,000 6,000 1,500 1,500 1,500 Practicing in wholly outside the UK 9,000 9,000 No clinical practice 4,000 4,000 4,000 Unspecified 500 500 500 Total 69,000 69,000 69,000 9,000 9,000 B2
Option 3: By sector/grade 7. The UKRDG considered a sector/grade approach which would involve rolling out based on the doctor's specialty, sector or grade. Doctors would be revalidated in a sequence determined by the sector or grade in which they work. For example, rollout could commence with GPs, trainees or a particular specialty. 8. UKRDG members concluded that a sector/grade approach does not sufficiently meet the roll-out principles. 9. Pros: Enables us to move forward with revalidation and roll-out in sectors which have processes in places ready to support revalidation. This may be seen as fairer amongst peers if doctors working in a similar role are revalidated at the same time. It should remove the risk of doctors moving locations to avoid revalidation. 10. Cons: Assumes that a sector or grade will all be ready in every organisation at the same time, which is incorrect. Leaving high risk groups of doctors to the end would not be seen to be equitable between different grades or types of doctor. Option 3: By Sector/Grade (3 year roll-out) Primary care in the NHS (including mixed practice) Secondary care in the NHS (including mixed practice) 63,000 63,000 63,000 NHS other - including trainees and medical managers Non-NHS (clinical, non-clinical & outside UK) ** 12,000 12,000 12,000 Total 75,000 75,000 75,000 B3
Option 4: By a combined readiness, managed and risk-based approach 11. The UKRDG considered a combined approach, starting where organisations are ready, but also ensuring that all groups of doctors (both NHS and non-nhs) are engaging in revalidation from the first year of roll-out. The UKRPB also considered this option at its meeting on 7 June 2011. 12. Both the UKRDG and UKRPB concluded that, with revisions, this option provides a reasonable basis for moving forward with rollout planning. 13. Pros: Complies with a risk-based approach to regulation by considering all groups of doctors from (meaning that we are not leaving high risk groups to the end); and by incorporating a readiness element, it is being fair to doctors and organisations who still need more time to be able to fulfil the requirements of revalidation although there will be an end date by which they have to be ready. 14. Cons: May be more difficult to manage and there is a risk that some doctors working in unique environments are not captured in the rollout plan. May also be difficult to control the pattern of recommendations that are submitted to the GMC if it is based on readiness and ROs deciding the sequencing; consequently it may be difficult for doctors to understand when they are expected to revalidate. 15. Following consideration of the option in detail, the UKRDG and UKRPB have proposed the following: 16. The rollout approach should be driven by designated organisations and ROs who are best placed to know when they are ready to submit recommendations on particular doctors so that rollout is locally-driven, manages patient safety risks and is based on readiness. 17. The GMC will work with Delivery Boards and ROs to draft the rollout plan and commence populating the detailed schedule of doctor recommendations. While detailed planning will be managed locally, the GMC will oversee the overall rollout schedule to ensure it s manageable for ROs, organisations and the GMC; and to ensure that peaks and troughs during the rollout period are avoided. 18. The rollout plan should include a date by which all ROs need to commence submission of recommendations to the GMC (e.g. by the end of year three). The plan should also ensure that ROs of high risk groups are submitting recommendations from the first year of rollout, including locum agencies and other non-mainstream areas of practice. 19. As part of the planning process, the GMC will work with Delivery Boards and ROs to: define high risk and identify high risk groups; determine their position in the rollout schedule; and identify the support required to ensure they are ready. 20. In parallel, the GMC will continue to collect information about doctors and their area of practice via the Practice Questionnaire. The GMC also plans to ask doctors to identify their designated organisation and RO; this is in addition to each Delivery Board providing the GMC with a lit of designated organisations in their B4
country. The data will be used to ensure all doctors are captured in the rollout plan by identifying those doctors who have not yet linked, or are unable to link, to a designated organisations or RO. This issue of linking doctors with designated organisations will be addressed jointly between the GMC, the four departments of health and the RST. 21. The GMC should lead on communicating with doctors who are practising wholly overseas, to ascertain whether they require a licence and therefore need to revalidate. 22. The expectation is that 5 years of appraisal evidence is not, and cannot be, required for the roll-out period, and this should be communicated clearly to doctors and ROs. 23. The rollout period should be between 3-5 years. The UKRBP have indicated a preference for a three year rollout, with the majority of doctors revalidated in the first three years, followed by two years to address those outstanding. A decision on the end date of the rollout period will need to be reached within a timescale that allows sufficient notice to ROs and designated organisations of the volumes of submissions they will need to plan for, and sufficient notice to individual doctors of their first revalidation date. 24. The GMC will provide the necessary support and processes for roll-out, whether it is a three, four or five period. The GMC will therefore proceed with its internal planning on the basis of the highest potential volumes of submissions it should expect, which is over 3 years. 25. The table below was referred to by the UKRDG and UKRPB when considering option 4, and was based on the assumption of a three rollout, followed by two years to address those outstanding. This table will be revised as appropriate as the option is refined. B5
Option 4: Combined readiness, managed and risk based NHS in England (to be informed by RO roll-out plans) Boards & Trusts in Wales, NI and Scotland (to be informed by RO roll-out plans) Doctors practising in the NHS but have no UK address Trainees reaching CCT or 5 years post registration 35,000 35,000 35,000 0 0 7,000 7,000 7,000 0 0 1,500 1,500 1,500 0 0 11,000 11,000 11,000 11,000 11,000 Clinical doctors with no NHS work 1,500 1,500 1,500 1,500 1,500 Other non-mainstream doctors 2,500 2,500 2,500 2,500 2,500 Unspecified/other 500 500 500 500 500 Volunteers # # # Doctors revalidated as early adopters in 2012 Doctors practicing wholly outside the UK # 8,500 8,500 Deferrals # # Doctors not revalidated during the 3 year roll-out period # # New registrants in 2012 # TOTAL 59,000 59,000 59,000 24,000 24,000 Notes: 26. Numbers are for illustration purposes only and are estimates extrapolated from Scope of Practice data as at March 2011. 27. A percentage of deferrals will need to be allocated to years four and five. B6