Policy responses and statements

Name of organisation:

NHS Education for Scotland

Name of policy document:

The Governance of Postgraduate Medical Education and Training in Scotland

Deadline for response:

7 January 2008

Background: NHS Education for Scotland asked the College for comments on the developing infrastructure to support postgraduate medical education and training in Scotland.

The governance of postgraduate medical education and training has been evolving over the past half century. Recent significant changes introduced as a consequence of implementing MMC, together with the need to meet the standards defined by the regulatory bodies (The Postgraduate Medical Education and Training Board and the General Medical Council), require change to the current educational structure.

Postgraduate deaneries are responsible for ensuring the delivery of training to an appropriate standard. Health Boards are responsible for the employment of doctors in training and are increasingly being held accountable for the educational governance to support that training.

Nationally, the Scottish Government has set out new governance arrangements for MMC. This consultation document builds on these setting out revised arrangements to ensure that we can deliver training to the standards required. They represent a practical and robust framework yet sufficiently flexible to meet significant differences in size, services and specialties across Scotland and it is, as far as is possible, adaptable to accommodate inevitable change. They will provide a managed and accountable system for delivering postgraduate medical education and training. The arrangements build and depend on for their success a strong partnership of the service, Royal Colleges, universities, the profession and many others working with NES. Much of this framework is already in place and these proposals aim to make explicit existing best practice within NES and the service. They should not require significant amounts of additional resource.

COMMENTS ON
NHS EDUCATION FOR SCOTLAND
THE GOVERNANCE OF POSTGRADUATE MEDICAL EDUCATION AND TRAINING IN SCOTLAND - A DOCUMENT FOR CONSULTATION

The Royal College of Physicians of Edinburgh welcomes the opportunity to comment on NHS Education for Scotland’s consultation on The Governance of Postgraduate Medical Education and Training in Scotland.  Recent and future changes in the management of postgraduate training demand a clear governance framework to assure quality and avoid duplication.

The College welcomes the documentation of roles in the overall quality framework, with quality control vested in the Health Board providers of education and training, quality management at Postgraduate Deanery level and quality assurance by the regulators.  The College notes that NES considers its primary role to be at the quality assurance level, working in partnership with PMETB and the GMC, and it might be helpful to clarify within the document whether NES has a different and distinct role to the Deaneries.

Our specific comments follow:

In addition to advice and local support to the Health Board providers, all Colleges have an essential role in providing an informed, independent and external dimension to the quality management and assurance of training in the medical specialties at deanery level.  PMETB’s finalised Quality Framework requires this, and the College believes that the NES governance document would benefit from greater emphasis on this College role. 

The College also has a key role in the design/amendment of programmes for submission to PMETB for approval, and this important developmental element is missing from the document.

Speciality specific advice must be available to NES at both strategic and operational levels, and RCPE supports the Academy position that College advice should be available to NES Specialty and Foundation Training Boards and Deanery-led Speciality Training Programme Committees.  High level discussions at the NES Medical Quality Management Group must be able to access specialty advice via the Academy’s 2 members.

The College notes that appointments to the important role of Training Programme Director will be made jointly with the appropriate College.  The key players with the experience and competence to take on these posts will be known to the Colleges, and many will already be involved in a College role.  The RCPE anticipates further dialogue with NES and our sister College in Glasgow over this and other aspects directly applicable to the training of physicians.

The College notes that the contribution of Royal Colleges and Faculties is anticipated at Specialty Training Committee level.  However, Annex B is unclear on the status of College membership of these Deanery-based committees and RCPE hopes this will be addressed in the signalled future review.

The College notes the inclusion of College regional advisers and tutors within the overall education infrastructure in Scotland and suggests that the Academy of Medical Royal College and Faculties is added to Table 1.

Table 2 identifies the key players in many of the cells, but gives little information on role or responsibilities against the 4 areas (governance, workforce planning, selection and recruitment and managing delivery).  The College hopes that the updated version for 2008-9 will clarify remits and determine where roles meet and/or overlap. 

The Colleges’ key role as providers of specialist postgraduate education is omitted and should be added to the document.  In addition to supporting trainees in the medical specialties, the College is in an ideal position to support the development of a Scottish faculty and looks forward to working collaboratively with NES and other Colleges to develop and deliver effective training programmes.  It would be helpful for the NES governance document to emphasise the importance of releasing consultants and trainees to participate in such courses/programmes and acknowledge that a phased approach will be required.

The College welcomes the emphasis within the document on the time required within consultant job plans for training programme directors and educational supervisors, and believes that it should be stipulated that these are found from within PAs and not from SPAs. Also, there should be adequate provision within the job plans of clinical supervisors to accommodate the more robust assessment requirements of PMETB.  This is a Health Board responsibility, but the College believes the governance framework for Scotland should include guidance, particularly as the Boards have received no resources to support implementation.

There appears to be limited references to the role of trainers in Foundation Training within the document, and the College asks whether this awaits the outcome of the Tooke review.

Copies of this response are available from:

Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.

Tel: 0131 225 7324 ext 608
Fax: 0131 220 3939

[4 January 2008]