Department of Health
Wednesday, 14 October, 2015

Executive summary

  • The role of managers (be they medical or non-medical) and systems in healthcare is to provide the best possible environment in which clinical professionals of all disciplines can deliver high quality, effective and safe care that involves patients in decisions made about them. The care delivered by the majority of doctors registered with the GMC is of a high quality. To support this, on 1 January 2011, a new role, the responsible officer, was introduced in organisations involved in healthcare delivery and policy. The role of the responsible officer is to ensure organisations have in place processes that provide a framework within which doctors are encouraged to maintain and improve their practice.
  • Responsible officers play a crucial role in improving and maintaining the quality and safety of patient care. They are critical in ensuring that their organisations maintain a focus on the core components of their relevant national quality framework. The following components originate from the Department of Health in England, although other nations will have their own, similar framework:
    • Patient safety – by ensuring that doctors are maintaining and raising standards of professional performance.
    • Effectiveness of care – by supporting an ethos of professionalism, ensuring that clinical care is delivered by practitioners who are fit for purpose, appropriately trained and skilled for the role in which they are employed.
    • Patient experience – by ensuring that patients’ views are fully integrated into evaluations of a doctor’s performance.
  • Following a series of high profile failings, proposals were made for a system of revalidation for every licensed doctor in the UK. Revalidation enables licensed doctors to demonstrate to patients, the public, colleagues, organisations and the General Medical Council on a regular basis that they are up to date and fit to practise. A key role in the process is the responsible officer who will make recommendations to the GMC about the fitness to practise of doctors connected to them, usually, once every five years (the process of revalidation).
  • Background on the development of the role can be found in the following documents:
    • White Paper “Trust, Assurance and Safety”;
    • “Responsible officers and their duties relating to the medical profession” – a consultation, July 20082;
    • Response to the consultation - “Responsible officers and their duties relating to the medical profession”, May 2009;
    • “The framework for responsible officers and their duties relating to the medical profession” – a consultation on responsible officer regulations and guidance, August 2009; and
    • “Responsible officers in the new Health architecture” – a consultation on draft amendment regulations, December 2012.
  • The role and responsibilities of the responsible officer and the relationship between responsible officers and licensed doctors are described in this document. The responsibilities of organisations delivering healthcare in this regard are also described. The regulations were amended in 2013 and this version reflects those amendments.
  • The responsible officer arrangements will apply to the vast majority of practising doctors in the UK, who will relate to a responsible officer nominated or appointed by their designated body.
  • The arrangements for confirming the fitness to practise of the small minority of doctors falling outside this framework are set out by the GMC.

 

Response to the Department of Health on Medical Revalidation – Guidance on the role of the responsible officer

The Royal College of Physicians of Edinburgh is pleased to respond to the Department of Health on its consultation on Medical Revalidation – Guidance on the role of the responsible officer.

Q1. Do you think the responsible officer guidance sufficiently sets out the general principles underpinning the role, as set out in the 2013 Regulations?

Please give reasons for your response:

Yes, the updated guidance now clarifies the duties and responsibilities of both organisations and Responsible Officers that have come under statute.

Q2. Do you think the model of connections as described in Section 2 for England Scotland and Wales sufficiently explains the prescribed connections between doctors and their responsible officer?

Please give reasons for your response:

This model of prescribed connections now appears to be streamlined and clearer and seeks to provide guidance to address a range of employment arrangements and appraisal/RO options to manage any potential positions of bias. 

Q3. Do you think the guidance sufficiently supports responsible officers in helping them understand their roles and responsibilities?

Please give reasons for your response:

Yes, the changes to the guidance now reflect updated statute including statutory requirements for appointing organisations to have appropriate systems and resources in place and a requirement to support the Responsible Officer in their statutory responsibilities.

Q4. Do you think this guidance will have a positive or negative impact on supporting responsible officers in fulfilling their role?

Positive

Negative

Please give reasons for your response:

Positive for the reasons above - it reinforces existing guidance with statutory provisions.

Q5. Can you advise where you feel additional guidance may be needed?

The College has some concern that further specific guidance may be required for RO’s around the matter of the provision of remediation, re-skilling and rehabilitation, as alluded to in para 4.21.  Resources to assist RO’s in this task may vary widely across the country.  In addition, it is not clear how consistency in the application of such remediation will be achieved.

Q6. Do you have any further comments?

No.