Policy responses and statements
- Name of organisation:
- General Medical Council
- Name of policy document:
- Merger of the Postgraduate Medical Education
and Training Board with the GMC - Consultation on draft
Rules and Regulations
- Deadline for response:
- 5 January 2010
Note: PMETB will merge with the GMC in 2010. When that happens PMETB’s
current functions will be transferred to the GMC. This consultation
sought opinions on the content of draft rules and regulations that
will govern the way the GMC carries out its new responsibilities.
Background: In September 2007, Sir John Tooke's independent
inquiry into Modernising Medical Careers recommended that ‘PMETB should be assimilated
in a regulatory structure within GMC that oversees the continuum of
undergraduate and postgraduate medical education and training, continuing
professional development, quality assurance and enhancement.’ In
February 2008 the Secretary of State accepted the inquiry’s recommendation
to merge PMETB with the GMC. Since then, work has been progressing
to put in place the legislative provisions and the practical arrangements
necessary for the merger to take place.
Purpose: The GMC wished to gather opinion on the content
of the draft rules and regulations. They will use responses to the consultation
to ascertain whether the proposed rules and regulations will ensure the smooth
transfer of PMETB's functions following its merger with the GMC.
COMMENTS ON
GENERAL MEDICAL COUNCIL
MERGER OF THE POSTGRADUATE MEDICAL EDUCATION AND TRAINING
BOARD WITH THE GMC: CONSULTATION ON DRAFT RULES AND REGULATIONS
The Royal College of Physicians of Edinburgh is pleased to respond to the
General Medical Council’s consultation on the draft rules and regulations
relating to the Merger of the Postgraduate Medical Education and Training
Board with the GMC.
Q1. Do you agree that the principles that have informed our
approach preparing the rules and regulations are the right ones?
Yes, but see response to
Q2 below.
Q2. If not what should be the guiding principles?
The principle of “fairness” may be compromised marginally by the
adoption of (different) PMETB fee structures eg for appeals – see
Q.8 below.
Q3. Do you agree that the rights and responsibilities set out
in the Award of Certificate Rules are appropriate?
Yes.
Q4. If not, what is missing or inappropriate?
n/a.
Q5. Do you agree that the rights and responsibilities set out
in the applications for General Practice and Specialist Registration Regulations
are appropriate?
Yes.
Q6. Is not, what is missing or inappropriate?
n/a.
Q7. Do you agree that the rights and responsibilities set out
in the Registration Appeals Procedure Rules are appropriate?
No.
Q8. If not, what is missing or inappropriate?
The new rules on fees are
unclear and may be inconsistent. This Statutory Instrument replaces
completely the previous GMC rules on registration appeals and the effect
of Para 5 would appear to create differences with either:
- a fee payable only against decisions that previously would have been taken
by PMETB, or
- the
institution of a new fee for (previously) GMC decisions.
Also, the provision of a
chair’s casting vote gives significantly more authority and/or power
to the chair of panels with an even numbers of members operating in a system
where abstention is prohibited.
Also, the requirement for
all chairs of registration appeals panels to be legally qualified will restrict
the eligibility of candidates for chair and the opportunity for some experienced
people to continue to contribute to this aspect of GMC work
Q9. Do you think that the approach we have taken to the underlying
principles and to the details of the rules and regulations described in this
consultation will have an adverse impact on any particular group?
The effect of introducing
fees for appeals and the option for the panel to award costs against an unsuccessful
appellant may deter appeals from doctors applying to the specialist register
on limited incomes (whether as a result of working overseas or for part-time
UK-based doctors). Both could be viewed as discriminatory and may be
exacerbated further if legally qualified chairs command a higher fee.
Denying lay and medically
qualified people the opportunity to act as chairs potentially limits the pool
of experienced panel members available to the GMC and may deter the recruitment
of new panel members.
Q10. If you think that there will be an adverse impact on particular
groups, or you have any further comments, such as how any adverse effects
might be mitigated; please provide details.
The GMC could choose to absorb
any additional costs of recruiting legally qualified chairs to ensure appeal
panel costs are not inflated.
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
[5 January 2010]
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