Prepare for revalidation

Your responsible officer (RO) will be ethically obliged to be honest and trustworthy in making revalidation recommendations.

If there is a genuine conflict of interest, the regulations require that your organisation appoints an alternative RO to deal with this situation.

For doctors in training, you must engage with your training programme. This includes taking part in the Annual Review of Competence Progression (ARCP) as well as discussing your progress and learning needs with your educational supervisors, including causes for concern and any practice outside your training programme. You do not need to collate additional information.

You will be contacted in advance about your revalidation submission date, usually three months in advance of the date.

Find out more about revalidation for doctors in training.

For doctors who work for a number of organisations, or carry out work for a number of locum agencies, first identify which (if any) of the organisations is your designated body.

If you're not sure, you can use the GMC's connection tool to find out.

You should contact the responsible officer (RO) at the relevant area team of NHS England and check if you are already on their list of doctors to be scheduled for revalidation. If not, you will need to contact the GMC and 'make your connection' through your GMC Online account. The RO can then ensure you are able to participate in the organisation's appraisal process and revalidate when the time comes.

Your designated body is the organisation that will usually provide you with regular appraisals and support for revalidation. Most doctors have a clear connection with a designated body, such as their NHS employer or a training programme. GPs are connected to NHS England or their local health board. The GMC has an online tool to help doctors find their designated body.

If you do not have a designated body to connect to, update your information with the GMC. You can do this with GMC Online.

For doctors without a designated body, you will need to revalidate if you wish to retain a licence to practise. You will need to collect evidence about your practice and have annual appraisals with someone meeting the GMC's requirements.

If you do not have a connection to a designated body or GMC approved 'suitable person,' the GMC will expect you to pass their MCQ revalidation assessment, unless you have obtained an acceptable relevant fellowship or membership qualification in the last five years.

Your ability to revalidate largely depends on the success of the yearly appraisals, which are usually arranged by your designated body. If you don't have a connection to a designated body then ensure your appraiser meets the GMC's requirements.

If you have not had an appraisal recently, this should be addressed as a matter of urgency unless your responsible officer (RO) has agreed an alternative arrangement with you. If you don't engage with the appraisal process, this could damage your revalidation as your RO may notify the GMC of your non-engagement.

The GMC has acknowledged that appraisals may have been disrupted by COVID-19. In 2020, thousands of doctors had their revalidation deferred due to the pandemic. While it acknowledges the disruption, doctors are advised to follow the advice of their responsible officers.

Responsible officers (ROs) are senior doctors within an organisation, such as the medical director. The Medical Professional (responsible officers) Regulations 2010 describe their function. ROs have a duty to ensure your designated body provides you with robust appraisals.

The RO is responsible for making a recommendation to the GMC about your ability to revalidate. Their recommendation will be largely based on information relating to your appraisal, in conjunction with other information available to the RO, such as disciplinary processes or remediation programmes. 

Your RO can make one of three recommendations:

• a positive recommendation that you are up to date and fit to practise
• a request to defer the date of your recommendation
• a notification that you are not engaging in revalidation.

You can find out more about responsible officers on the GMC website.

Your responsible officer (RO) will normally be the one linked to the designated body where you are currently working. If you change organisations, your RO will also change.

Your new RO will, however, consider information relating to the whole five-year cycle, so will liaise with your former RO to ensure they have all the required information.

All doctors carrying out clinical duties must have a licence to practise and will need to revalidate to maintain it.

The GMC does not require doctors all doctors to hold a licence to practise. For example, if they are do purely medico-legal work (unless they are examining patients). However, some insurers and solicitors do ask that their experts to hold a licence to practise so you may wish to confirm with each instructing firm.

If you relinquish your licence to practise you should remember that you cannot carry out functions requiring a licence, for example, prescribing medications.

You'll need to provide information about yourself, your work, your appraisals and revalidation status (for example, if you are in the process of an appeal), and make declarations about probity and health.

In terms of other supporting information for revalidation, you'll be expected to have collected, reflected on, and discussed various types of information at appraisals throughout your revalidation cycle. The GMC has detailed guidance on the required supporting information.

Your evidence will fall into six types:

• continuing professional development (CPD)
• quality improvement activity
• significant events
• feedback from patients of those to whom you provide medical services
• feedback from colleagues
• compliments and complaints.

During your appraisal discussions throughout the revalidation cycle, you'll be asked to demonstrate, using this supporting information, that you're up to date, fit to practise, and have reflected on your practice, identifying any areas for improvement.

The information you provide for revalidation will include your personal development plans and reviews of those plans made during the revalidation cycle.

You will only have one responsible officer (RO), but you will be required to present supporting evidence covering every area of your practice. This means your supporting information must cover all your roles as a doctor, including locum work, private practice and NHS practice.

You're expected to tell your responsible officer and appraiser about all the places you have worked since your last appraisal. You are also expected to share the following information at any of the places you have worked:

• if you're involved in a significant event
• if a complaint is made about you
• if there is a concern about your fitness to practise
• if you are suspended or have restrictions placed on your practice (by an employer or the GMC). You must also tell any patients you see independently.

Your RO will consider information from the whole of your practice when making a recommendation to the GMC.

You can find out more about revalidation and working in multiple settings from the GMC website.

It is possible that litigation could arise as a result of an appraisal and/or a decision on revalidation. For example, a claim could be brought by a patient who has been harmed by a doctor in circumstances where his/her appraisal was found to be satisfactory and responsible officer (RO) made a recommendation for revalidation which the GMC accepted.

The patient may allege the doctor was deficient and that deficiency, which should have been picked up, caused them harm. We do not expect that this would happen very often. If such a circumstance arose for an NHS patient, the claim would be brought against the NHS employing organisation and would fall under NHS indemnity.

It is also possible the appraiser or the RO could be sued by a doctor on the grounds they had not been recommended for revalidation and that it has harmed their employment prospects.

Each case is judged on a case-by-case basis. If you are a responsible officer or appraiser and an MDU member, you can contact the advice line for more information.

Provided you are engaging with the appraisal process, your responsible officer (RO) can ask the GMC for a deferral in a decision about your revalidation. The RO can request a deferral for up to 12 months which simply postpones your revalidation.

You should then work with your organisation to obtain any outstanding supporting information as soon as possible.

Appraisals have been affected by the COVID-19 pandemic as doctors may have become ill and unable to collect evidence of CPD or attend an appraisal meeting. The GMC does not require that a doctor literally has an appraisal every year if there's a legitimate reason for the appraisal being missed, such as the pandemic. The GMC postponed the revalidation dates for doctors due to revalidate between March 2020 and March 2021 for up to a year. While it acknowledges the disruption, it advises doctors to follow the advice of their responsible officers.

If the matter is still being investigated by your employer when your revalidation is scheduled, it is likely your responsible officer (RO) will request that the date is deferred. For GPs, this will usually be a performance review by the organisation that manages the Performers List on which your name is included.

In its protocol for ROs, the GMC says that deferral requests can be made for doctors who "are participating in an ongoing local governance process, the outcome of which is material to your evaluation of the doctor's fitness to practice and your ability to make an informed recommendation." Your RO will be asked to specify the length of the deferral which can be up to a year.

Once the investigation is completed, you will still be able to revalidate provided the findings do not cast doubt on your fitness to practise. It will be important to demonstrate that you have reflected on what happened, any lessons you have learned, and be prepared to discuss this during your next appraisal.

If your clinical performance is under investigation by the GMC, then your revalidation will have been put on hold by the GMC pending the outcome of their investigation(s).