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Response to consultation document 'Medical Profession (Miscellaneous Amendments) Order 2008'

June 2008

Q1. Do you support the transferring of the statutory powers of the GMC Education Committee to the GMC from January 2009, when the new GMC Council will be established?
We support the transfer of the statutory powers to the GMC’s Council, but suggest that the GMC continues to operate an Education Committee to consider the detail of its policies and the intricacies of educational issues. This is particularly important for the BMA’s Medical Students Committee which currently contributes to GMC discussions on the regulation of undergraduate education through its seats on the Education Committee. We are concerned that this representation will be lost with any potential transfer of the Education Committee functions to the GMC Council.

Q2. Do you agree with the amendments to Part 3A of the Medical Act 1983 which will enable the GMC to begin work around revalidation including issuing licences to practise? We agree with the amendments to Part 3A of the Medical Act on the basis that changes to legislation relating to revalidation are inevitable. We believe that revalidation should be implemented for all groups of doctors at once, or introduced randomly. It should not be implemented first for doctors in certain specialties or localities where systems are already in place

We note that the consultation document refers to revalidation pilots and believe that these need some clarification, for example:

• Where are the pilot sites that are referred to?
• What outcomes are being measured?
• What will success look like there?
• What is the status of the pilot (i.e. what happens if a doctor “fails”? Would his/her case be referred to the fitness to practise procedures? What would happen to such a doctor if it were later discovered that the pilot was flawed in some way?)

Q3. Do you agree with the amendment to the 2003 Order, which will reinstate the GMC’s previous power to allow late entry onto the Specialist Register in certain circumstances?
We agree with this amendment to the 2003 Order as it is essential to allow the consultants who did not make the appropriate application and who failed to take advantage of the "grandfather clause” to get on the specialist register and we are pleased to see that this final change has now been solved in the best and simplest way.