As part of the review of the quality assurance of medical education and training, the GMC has been developing a series of discussion papers. These papers explore some of the themes being tackled within the review and consider some options for the future. Previous papers have looked at the role of the medical Royal Colleges and the way the GMC reports its quality assurance findings.
The discussion paper looks at the subject of educational environments. This topic has added significance in the light of the recommendations from the Francis Report. Future papers will explore other themes, including the role of visits in quality assurance and measuring quality outcomes.
The GMC sought feedback on this paper, either on the five specific discussion points listed in the paper or on the content of the paper more generally. This will help the GMC to sense check some of its emerging thinking and inform its further development work.
Royal College of Physicians of Edinburgh
GMC Consultation on Approved Educational Environments
The College welcomes initiatives that will set and monitor standards for training delivered through Local Education Providers but is sceptical whether the range and extent of monitoring proposed is practical. Specific comments are referenced to the 5 discussion points as follows:
Discussion point 1: The GMC standards for the delivery of education and training should include explicit descriptors of the educational environments expected in local education providers. (paragraphs 29-33)
Agreed
Discussion point 2: The GMC’s standards for the delivery of medical education and training contained in Tomorrow’s Doctors and the Trainee Doctor are being reviewed. A provisional list of descriptors for the educational environment, which draw on the existing standards, the work of MEE’s Medical Indicator Group and the Educational Outcomes Framework, is provided at Annex A. Are these the correct descriptors? Are there things that should be added or taken away? (paragraphs 29-33)
The College is concerned that this level of detailed scrutiny may be difficult to achieve given the range of measures included and that it may be difficult for the LEPs to evidence their efforts. Also the document in some cases strays from specifying the "what" into the "how" and which may be excessively prescriptive, e.g. Under item 7 in clinical leadership and clinical and trainee engagement, the measures include detailed requirements of CEOs in terms of specific involvement with the recruitment of consultants and how they might achieve regular contact with clinical staff.
Discussion point 3: Do you agree that the deaneries (in England, HEE regions) should be responsible under the QIF for ensuring that the standards for educational environments are met (as they are for other standards) and that GMC approval of courses, posts and programmes should have regard to those standards? (paragraphs 29-33)
Agreed
Discussion point 4: What are the options for better co-ordination of regulatory activity across educational, patient safety and service concerns? (paragraphs 34-46)
Whilst agreeing that a holistic approach would be helpful in coordinating regulatory activity it is important to avoid duplication between the regulators which will be inefficient and distract clinicians from patient care.
The proposals for greater cooperation between regulators must take greater account of the different approaches in the devolved administrations and ensure that regulatory activity is consistent and proportionate across the UK.
The College is developing its own approach to responding to invited service reviews, part of which will be clear and explicit agreement that the College retains the right to and will report patient and doctor/trainee safety issues to the regulator in line with obligations of our Fellows under Good Medical Practice.
Discussion point 5: Do you agree that the approach described in discussion points 1-3 of this paper, coupled the options explored under point 4, would provide a proportionate way of ensuring the quality of the educational environment, without the need for a formal approval of deanery/local environments? (paragraphs 34-46)
The College understands that at a time of financial constraint and new commissioning arrangements in England, there will continue to be tension between the priority given to service and training at LEP level. The College believes that the present system of ensuring the quality of training through GMC scrutiny of Deanery/LETB commissioning and College externality has much merit and is beginning to settle. The Care Quality Commission and the GMC have different perspectives in their scrutiny of local providers and a single assessment inspection or reliance on the output from others may not best serve all needs.
The College would welcome opportunities to contribute further and would be anxious if change was introduced without clear supporting evidence and piloting to demonstrate benefit.