Policy responses and statements

Name of organisation:

General Medical Council

Name of policy document:

Consultation on a review of the Future Regulation of Medical Education and Training [The 'Patel Review']

Deadline for response:

9 March 2010

Background: This consultation was an opportunity to comment on the draft report of the Medical Education and Training Regulation Policy Review, which is being led by Lord Naren Patel (the 'Patel Review').

The draft report makes recommendations for the future regulation of education and training for the medical profession in the UK. Comments received on the draft report will inform the final report, which will be submitted to the Council of the GMC at the end of March 2010.

Merger of PMETB with the GMC:

In September 2007, in the final report of his independent inquiry into Modernising Medical Careers, Sir John Tooke recommended that ‘PMETB should be assimilated in a regulatory structure with GMC that oversees the continuum of undergraduate and postgraduate medical education and training, continuing professional development, quality assurance and enhancement’. The Secretary of State accepted this recommendation. Work is now well advanced to merge PMETB with GMC by April 2010.

Although the merger will bring regulatory responsibility for the whole of medical education and training under one roof, this consolidation of functions will not, in itself, achieve the full benefits envisaged by Sir John Tooke’s report.

To ensure that those benefits are realised the GMC, with support from PMETB, invited Lord Naren Patel to lead a review of the current arrangements for the regulation of medical education and training and make recommendations that would inform future policy developments by the GMC.

The review:

The review has proceeded in three phases. Preliminary work during the latter part of 2008 concentrated on clarifying the scope and priorities for the review and gathering information. This began with a Chatham House style round table discussion and a series of interviews with individual stakeholders. The second phase involved consideration by a small working group of the views and information collected. The emerging views of the working group were then subject to debate within a wider reference group of stakeholders.

This public consultation on Lord Patel’s draft report is the third and final stage of the review. The outcome of the consultation will be used to inform the final report which is to be submitted to the Council of the GMC at the end of March 2010. It will then be for the GMC to decide how it wishes to take forward the review recommendations.

COMMENTS ON
General Medical Council
Consultation on a review of the Future Regulation of Medical Education and Training [the ‘patel review]

The Royal College of Physicians of Edinburgh is pleased to respond to Lord Patel’s policy review and agrees with the majority of recommendations. The following comments are referenced to the recommendations in the report:

1. The College agrees that it is important for the Regulator to work closely with education and training providers, and that lead responsibility for ensuring the delivery of high quality training rests with the Deaneries.  However, the College is concerned about the morale of trainees, particularly following the implementation of the WTD, and of trainers struggling to discharge their training and assessment responsibilities with inadequate time in their job plans.  GMC support for protecting and enhancing training will be welcomed by our Fellows and Members.  In addition, the College would encourage further review of the effectiveness of the quality monitoring of education providers to ensure education providers are held to account for their training responsibilities (Recommendation 3).

2. The College agrees that a single regulator will improve the focus on the transition between stages of medical education as young doctors move from medical school to their pre- registration years and on to specialist training and, in turn, revalidation.  Training at all stages should be consistent with agreed standards and there should be integrated quality control processes.  This will support patient safety and the profession within a cost effective system (Recommendation 4).

3. The College agrees there would be benefit in national agreement (across the UK) on datasets and IT systems to support the effective flow of quality data between Deaneries, Colleges and the Regulator (Recommendation 5).

4. The College welcomes the move away from student registration and agrees that the regulator should evaluate its methods of engaging with students (Recommendation 7).

5. The College agrees there is a need to ensure that all doctors entering Foundation Year 1 meet the required standards of knowledge and ability.  This is a clear patient safety issue and applies equally to the graduates from UK, European and international medical schools.  The College appreciates there are different views on how best to achieve this and will participate fully in development work to progress this issue (Recommendation 8).

6. The College agrees that “sign off” for full registration has become a more burdensome task (if undertaken robustly) now that more F1s train away from their home medical school and spend less time with their identified supervisors due to the shape of Foundation training and regular rota changes resulting from EWTD.  It is critical that accredited trainers have time to assess and advise their trainees.  This also includes doctors exiting the Foundation Programme and entering specialty training (Recommendations 10 and 11).

7. The College strongly supports the proposals to accredit trainers and training environments in secondary care.  This will require time and training for our Fellows and Members to discharge their responsibilities effectively, and the College is extremely concerned that this will be supported by the NHS at a time of public sector funding pressure.  The UK Academy of Medical Royal Colleges and Faculties recommends 0.25 SPA for each trainee supervised (Recommendations 12 and 13).

8. The College welcomes the proposed regulatory framework for the continuing education of SAS doctors, on the understanding that those working in specialist areas will be expected to follow the standards laid out in the specialist curricula developed by the relevant Royal College.  This will have resource implications for Colleges and Deaneries.  As proposals for revalidation evolve, with less emphasis on the separation of re-licensure and re-certification, it will be critical for public and professional confidence that College standards retain a prominent place in revalidation for all doctors working in specialist practice (Recommendation 14).

9. The College believes the GMC should have oversight of the assessment methods used in selection, but not in the selection of specific trainees.  Increasingly, trainees see selection as a very high stakes assessment, and the merger of PMETB and the GMC gives the opportunity to demonstrate that assessments such as MCQs or OSCEs used in selection are carried out as carefully as in MRCP(UK) or other College exams (Recommendation 16).

10. The College agrees that the Regulator has a role in defining the status and shape of sub- specialities to ensure rigour and appropriate quality control (Recommendation 17).

11. It is important that the equivalence rules under European law do not compromise patient safety and that all doctors practising in the UK meet all the required GMC standards. However, the College is not convinced that the solution lies in severing the link between certification and entry to the specialist register.  This uncoupling will create an unnecessary barrier to the specialist register for UK trainees and comes close to establishing a sub-consultant grade.  This will be unwelcome and demotivating for UK trainees and is opposed by the College (Recommendation 18).

12. The College understands the need to ensure the quality of locum doctors but questions the recommendation that all locum consultants should be on the specialist register. Recommendation 18, if enacted, would prevent doctors recently awarded a CCT from applying for locum posts and the NHS will struggle to fill such locum vacancies with competent doctors.  It is also important to be clear that this recommendation would not extend to “acting up” opportunities for senior trainees, which is a valuable part of preparation for becoming a consultant (Recommendation 19).

13. The College is concerned that the Regulator may risk duplicating the expert role of the Medical Royal Colleges in setting the specialty standards and monitoring compliance with specialty CPD and would wish to be involved fully in any discussions about changes in this regard.  In addition, the College already supports SAS doctors in their speciality CPD and expects them to follow specialty standards as relevant to their areas of practice, as will be required by revalidation (see para 8 above) (Recommendation 20).

14. The College is unclear how the GMC would benefit from increased legislative flexibility but agrees that the Regulator should increase its focus on outcomes in addition to important QA activity on processes.  The College would like to understand how/whether an increase in legislative flexibility will alter the relationships between the Regulator, the Deaneries, Colleges and individual doctors (Recommendation 21).

15. The College agrees that the GMC quality assurance processes should develop a stronger focus on outcomes where the data is available and would welcome the support of the GMC in calling for greater investment in support systems to capture and analyse such data eg investment in clinical audit (Recommendation 23).

16. The College welcomes the emphasis on working with other systems regulators to hold those responsible for providing the education and training infrastructure for the quality of education and training provision.  This should extend to requiring the performance objectives of senior NHS managers to include the delivery of education and training commitments (Recommendations 3, 25 and 26).

17. The College notes the implication in the report that central government financial support for PMETB will not be transferred to the GMC following the merger.  The College is concerned that this will add to the financial burden on the GMC and therefore either on trainees exclusively or the medical profession collectively.  The principle of “beneficiary pays” is understood but it must be accepted that the NHS and the wider public are the main beneficiaries of high quality education, training and regulation (Recommendation 27).

18. Other comments not linked directly to specific recommendations include:

• The College welcomes the stability afforded by not seeking to change the approach to curricula and assessment blueprints.

• The College is concerned that the GMC is considering an annual return from all doctors and questions the administrative complexities of such a task and the cost implications (para 46).

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

[8 March 2010]