Responsible Officers (ROs) are the individuals within designated bodies who have overall responsibility for helping you with revalidation. A designated body is the organisation (likely to be your main employer) that will support you with your appraisal and revalidation.
You only have one designated body and one Responsible Officer irrespective of how many organisations you are contracted with or employed by. Only UK organisations can be designated bodies, because the legal rules that determine this - the Responsible Officer regulations - only cover the UK.
The specific responsibilities of an RO are:
- ensuring that effective systems to support revalidation are in place (including appraisal and clinical governance systems)
- evaluating the fitness to practice of all doctors with whom the designated body has a prescribed connection and making a recommendation to the GMC regarding revalidation
- identifying and investigating concerns about doctors' conduct or performance
- ensuring that support and remediation is provided where a doctors practice falls below the required standard
- overseeing doctors whose practice is supervised or limited under conditions imposed by the GMC
ROs may have additional responsibilities such as ensuring that, when designated bodies enter into contracts of employment or contracts for the provision of services with doctors, those doctors have appropriate qualifications and experience for the work to be performed, their identities are verified and appropriate references are obtained and checked. However, these additional responsibilities are nation specific.
ROs will make a recommendation about a doctor's fitness to practice to the General Medical Council (GMC). The recommendation will be based on the outcome of the doctor's annual appraisals, over the course of five years, combined with information drawn from the organisational clinical governance systems. Following the RO's recommendation, the GMC will make the final decision on whether the doctor can retain their licence to practise.
Fully registered and licensed
ROs should be fully registered licensed doctors with more than five years' practice and they themselves will be appraised and recommended for revalidation by other senior licensed doctors. This may often mean that the responsibilities of the RO are an extension of the current role of the Medical Director.
Read more about the role of a Responsible Officer on the GMC website
Frequently asked questions
Can doctors choose their Responsible Officer?
No, doctors cannot choose their Responsible Officer.
The link between a doctor and their Responsible Officer is determined by which designated body they are connected to, and there are a clear set of rules (the Responsible Officer Regulations) that determines which organisation this is. Doctors will normally relate to the RO within the organisation they work in.
The Responsible Officer regulations recognise that conflicts of interest (these might be personal, financial or similar) may arise between a doctor and their assigned Responsible Officer. In such instances, the designated body is responsible for nominating or appointing a second RO to act in the original RO's place.
You should also ensure that you can relate to a designated body and access a Responsible Officer.
Use the GMC's online tool to help you find your designated body
Read the A to Z listing of all the designated bodies
What about Responsible Officers for GPs?
Responsible officers sit within NHS England, with NHS GPs relating to responsible officers within their region.
Find out more about NHS England sectors and responsible officers
A survey made it clear that many sessional GPs require further support with the appraisal and revalidation process. We have provided suggestions on how to tackle many of the problems sessional GPs face and possible solutions that aim to make it a more manageable and positive experience.
Read our tips for sessional GPs
What is a conflict of interest?
Circumstances may arise where doctors will find that there is a conflict of interest or appearance of bias which affects the ability of the responsible officer or the appraiser to make an objective assessment about a doctor's fitness to practice.
There are two main areas where a conflict of interest or appearance of bias may occur.
1) It may be that there is a pre-existing personal relationship between the doctor and the responsible officer or appraiser, for example:
- A marriage or partnership;
- A familial relationship;
- A financial or business arrangement;
- Instances where a third party is involved (e.g., an affair or marriage breakdown);
- Where a responsible officer is also acting as a lead in a clinical complaints investigation against the doctor.
2) Alternatively, a conflict of interest may arise due to the dual roles of managers and clinicians:
- Where a clinical director is called upon to comment on the clinical practice of their own responsible officer; or
- Where a responsible officer who is appraised by a medically qualified chief executive then has to make a fitness to practice recommendation in respect of that chief executive.
What recommendations can a Responsible Officer make?
Responsible Officers can make one of the following three recommendations to the GMC concerning a doctor's revalidation:
- A positive recommendation:
this means that the RO believes that the doctor is up to date, fit to practise and should be revalidated. In order to have a positive recommendation it is mandatory that the doctor has engages with revalidation processes
- Request a deferral:
this could be because the RO needs more information to make a recommendation about the doctor. This might happen if the doctor has taken a break from their practice (for example, maternity or sick leave)
- Non - engagement:
this is when the RO believes that a doctor has failed to participate in the local systems or processes (such as appraisal) that support revalidation. The GMC define non-engagement as 'A doctor is not engaging in revalidation where, in the absence of reasonable circumstances, they: i) do not participate in the local processes and systems that support revalidation on an ongoing basis and or ii) do not participate in the formal revalidation process.' This recommendation is taken very seriously and can result in the removal of the licence to practice. Engagement in the process by individual is absolutely crucial in order to avoid this recommendation.
What should I do if there is a conflict of interest?
Situations where a conflict of interest or appearance of bias occurs is rare. However, if such a circumstance arises, there are mechanisms in place to resolve it.
If there is a potential conflict of interest or appearance of bias between an appraisee and appraiser, the doctor's responsible officer should be informed in writing, with a full explanation of the conflict and any relevant background information.
If appropriate, the responsible officer can then recommend that a new appraiser is appointed. This will be the responsibility of the applicable clinical director or appraisal lead in the organisation, rather than the responsible officer themselves.
If there is a conflict of interest or appearance of bias between a doctor and their responsible officer, the relevant designated body should be informed, in writing, with a full explanation of the conflict and any necessary background information.
If it cannot be resolved through local processes, the designated body has a duty to nominate a second responsible officer under the Medical Profession (Responsible Officers) Regulations 2010 to oversee the revalidation process.
Designated bodies in these situations are encouraged to seek advice on appointing a second responsible officer from the responsible officer's own responsible officer.