This consultation sought views on the GMC’s role in regulating doctors’ continuing professional development (CPD). The GMC asked for feedback on three main areas of its work on CPD:
- Introduction of revised CPD guidance to provide a framework of principles to support doctors’ in planning, carrying out and evaluating their CPD.
- Incorporation of the CPD guidance into local processes of appraisal and personal development plans.
- Identification and dissemination of information about key trends, developments in medical practice or professionalism which may be relevant to doctors’ future CPD needs.
The consultation is relevant to all registered and licensed doctors because it sets out what the GMC expects them to do to maintain and improve their practice through CPD. It will also help them understand the CPD requirements for revalidation. The consultation is also relevant to employers and contractors of doctors’ services who have a responsibility to make sure that their workforce is up to date and practising to the appropriate professional standards. Patients and members of the public may be interested to understand what the GMC expects doctors to do in order to stay up to date and improve the safety and quality of care they provide.
Why the GMC is consulting on CPD:
In March 2010 Lord Naren Patel published a series of recommendations for the future regulation by the GMC of medical education and training. In his recommendations Lord Patel noted that the GMC had issued CPD guidance for doctors in 2004. But since then much has changed. He therefore proposed that:
‘The GMC should update its 2004 CPD guidance and re-examine how the regulatory role in CPD should be exercised so as to support doctors in meeting the requirements of revalidation and providing high quality care for their patients, whilst preserving the value of CPD for inpidual professionals.’
In the light of this the GMC has reviewed its role in regulating doctors’ CPD. The GMC's conclusions are set out in the final report.
Comments on
General Medical Council
The Review of Continuing Professional Development Consultation
The Royal College of Physicians of Edinburgh (the College) is pleased to respond to the General Medical Council’s consultation on The Review of Continuing Professional Development.
The College endorses the response to this consultation submitted by the Academy of Medical Royal Colleges (AoMRC), and would also like to make the following comments on specific consultation questions:
Yes – with CPD being embedded within the appraisal process, the result will be to strengthen the process. However, job planning may be dealt with at separate meetings. There may be a need to bring the clinical competence aspects of these two processes together.
The GMC should also recognise its educational responsibilities by working with the Colleges and Faculties to ensure that appropriate support and resources are being provided.
It is important to recognize that the quality of CPD and the ability of the doctor to reflect and learn from their CPD is probably more important than the quantity of CPD being done. Therefore it will be interesting as to how the GMC will commission research into how CPD is linked to poor performance.
- Do you agree that the GMC should provide a framework of principles and guidance to support doctors in their CPD rather than specifying in detail the activities a doctor must undertake?
If you think we should be prescriptive please say why and in what ways.
Yes – a framework of principles and guidance to support doctors should be provided.
However, the specifics of CPD should be determined by the doctor’s specialist society. Well established guidance, standards, quality assurance, advice on requirements and the amount of CPD that should be undertaken is already provided to a great extent by medical Colleges and specialist societies, and this should be recognised.
- Does the guidance place appropriate emphasis on doctors’ CPD activity being informed by the needs of patients and the public?
No- this could be strengthened. This consultation paper does perhaps not go far enough to protect the public interest.Whilst the proposals show that the GMC is conscious of the many problems surrounding CPD, there is a danger that the proposals are too light touch and too flexible to make CPD as effective a contribution to professional competence as the public interest demands.
- Does the guidance appropriately balance the CPD needs of the individual doctor and the needs of the team?
CPD tends to focus on the individual, and therefore there is a tendency to put emphasis on the needs of the individual doctor rather than the wider team. While there is mention of the needs of the team in the proposals, there is perhaps not a satisfactory balance.CPD is based upon a doctor’s Personal Development Planning (PDP). Therefore, the educational needs of a doctor may differ from the whole team. For example – The UK Stroke Forum is held yearly and is a multidisciplinary meeting with a number of parallel sessions. A doctor may wish to go to a very medical based session, a therapist may in contrast wish to hear about a new therapy programme for stroke patients. While the whole meeting will contribute to improvement in a patient’s care and global needs of the team, there are very distinct educational goals from any meeting.
- Does the guidance place the right emphasis on the role of appraisal and personal development plans in guiding doctors’ individual CPD activities?
Yes – as appraisal becomes embedded in normal practice, doctors will have PDPs written with their appraisers. This should reflect their continuing needs and developments over the next 12 months. This will then act as a guide for their forthcoming CPD. It is right that the aspirations and career development needs of the individual doctor should be acknowledged. - Is the guidance sufficiently clear about the responsibilities of employers and contractors in supporting doctors’ CPD activity?
The guidance specifies the need for the employer to ensure that the workforce is adequately trained.However, the GMC could make it clearer that they would expect employers to support doctors in achieving their CPD objectives, as identified through appraisal and job planning.
The GMC’s endorsement of the 250/5 year minimum credits agreed by the Medical Royal Colleges would also help make explicit to employers that they are expected to support doctors in achieving their CPD objectives, as identified through appraisal and job planning.
- Do you think there are any barriers stopping employers and contractors from carrying out their responsibilities?
Yes – economic problems within the NHS and in particular in acute care have seen SPA time being cut in established and new consultant job plans.The GMC has rightly highlighted the difficulties faced by some doctors, particularly those working less than full time, in fulfilling their CPD requirements and resulting in the use of their own time. There are also concerns about loss of SPA time in full time consultant contracts, which results in more time being spent doing clinical work and less time for CPD activities.
- Does the guidance provide sufficient information about the use of CPD to support revalidation? If not, what further information would be helpful?
Yes – but only in general terms. It will depend upon the skill of the appraiser to help the appraisee with their PDP and hence revalidation. The GMC should actively encourage doctors to follow their College guidance. - Do you think we have identified the most effective ways of embedding the guidance into local processes?
- Do you agree that there is a role for the GMC in bringing to doctors’ attention information about emerging trends or developments in medical practice and professionalism in order to help them reflect on their CPD needs?
To an extent this would be helpful. However, there is concern that medicine is evolving too quickly for the GMC to highlight emerging trends and developments in medical practice using the GMC database. Doctors should be able to identify areas in which they need to update their skills and knowledge as part of their reflective practice and through their Colleges and specialist societies. - Do you think that our proposals as a whole (the guidance, the plans for incorporating the guidance into local processes, and the proposals for bringing to doctors’ attention information which may be relevant to their CPD) will help recognition of doctors’ CPD needs?
Yes. - Are there any groups of doctors upon whom our proposals might have an adverse effect?
There are concerns about doctors who may spend a considerable part of their careers doing locum work. While this may be addressed by their need to have a Responsible Officer, there is a need to ensure that the locum agency also signs up to the principle of CPD. - Our report contains nine specific recommendations on the role of the GMC in regulating doctors’ CPD. Do you have any other comments on the conclusions of the review report and the report recommendations?
- Is there anything further we should be doing to regulate doctors’ CPD?
No.