The implementation of revalidation will be a huge challenge for all concerned - and not all the BMA's concerns have yet been addressed.
Doctors can rest assured that the Association will continue to scrutinise the process and lobby to ensure it is fair and proportionate for all branches of practice and across the UK.
- Secondary care doctors will require more time and resources to complete revalidation, at a time when they are already under pressure to deliver a more efficient service. Many employers, NHS Trusts and or Boards have however only provided 1 SPA for this purpose and have reduced study leave budgets in their drive to make savings.
- In primary care, there are inconsistencies between Primary Care Organisations in the evidence they request as part of the appraisal process.
- Governance systems are not sufficiently robust to produce accurate and timely outcomes data for doctors to include in their evidence to support their practice. We also have concerns about how those doctors who do not work in managed environments, such as locums but also those who work in the private sector, will be able to collate the necessary evidence.
- Remediation arrangements in Scotland remain unclear, both in terms of the provision of funding for GPs but also in terms of the remediation framework which has not yet been published.
- NHS boards are unable to provide many secondary care doctors with appropriate clinical information at an individual level due to the inadequacies of NHS information systems, and there are no national plans for significant improvements. SAS doctors in particular are likely to have issues with supporting evidence.
- The Scottish Government has endorsed the CARE measure for patient feedback for all primary and secondary care doctors, but this is essentially a primary care feedback tool that has been extended to secondary care without prior evaluation to demonstrate its suitability for use by secondary care doctors.
- As well as a lack of progress in training new secondary care appraisers for the introduction of revalidation, many existing appraisers may be unwilling to undertake the recommended 10 appraisals per annum. Some may also be uncomfortable with the move to a more summative form of appraisal, exacerbating the potential shortage of appraisers.
- A standard online appraisal system has been developed for use across Wales, although there are concerns about the inconsistent application of the system as one Health Board - Betsi Cadwaladr - has produced its own system for use by doctors working in that area.
Branches of practice
- The availability of resources required for the process, both in terms of SPA time and also robust governance systems, remain a concern. The appraisal rates for consultants also remain low, despite being a contractual requirement for some time.
- Sessional, and particularly locum, GPs, will find it more difficult to participate in the process, because it will be less easy for them to collect the evidence required for revalidation than for GPs who are based within one practice and have a greater influence on how their practice is run.
- A large number of doctors are required to 'reflect' on Serious Untoward Incidents (SUIs) and Significant Event (SE) information as part of their specialty training this could therefore create a significant administrative burden and result in cases of double jeopardy.
- Responsible officers need to understand the importance of joint, Follett-compliant processes and ensure that the academic component of an academic trainee's job is reflected in appraisal and revalidation. The source of specific advice for academics also needs to be clarified, along with who will undertake the responsible officer function for medical academics without a clinical contract.
- As many public health doctors will be working outside the NHS, clarification is needed on who will undertake the responsible officer function to a doctor working in a local authority where the rest of their team are non-medical.
- The types of activities that a doctor could undertake that would not require a licence to practise (and subsequent revalidation) needs to be clarified, along with how a retired doctor can relate to a Responsible Officer.
- The appraisal rates for SAS doctors remain low and many governance systems are unable to provide individual work and outcomes data for SAS doctors.