Revalidation Special

By Dr Paul Myers and Emma Davies / 01 Feb 2014

Dr Paul Myers summarises how aesthetic doctors can be prepared and meet the requirements for revalidation

On December 3 2012 the GMC introduced revalidation, marking a turning point for every practising doctor in the UK. For the first time, a doctor who was registered with the GMC could only continue to practise medicine under strict conditions, to which a time limit now applied. These new regulations were introduced following incidents such as the Shipman and Bristol Royal Infirmary heart scandals, in order to monitor doctors more closely. They were also designed to reassure the public as it is claimed that revalidation will reduce risks to patients.
The method requires every doctor to show that they are up-to-date, reflecting on their work, and practising according to Good Medical Practice Guidelines. Prior to this, a doctor practising with the UK registration could continue without supervision indefinitely and would only have their registration threatened if a complaint or problem came to the notice of the GMC. Now doctors have to be licensed as well as registered to provide clinical services in this country. The conditions of having a licence are dictated by the ‘Responsible Officer Regulations’. These state that doctors must have an annual appraisal, and must be assessed as to their fitness to practice once every five years in the revalidation process. No other country has such a rigorous method of controlling and assessing the medical competence of individual medical practitioners. 


The Medical Profession (Responsible Of- ficer) Regulations 2010 came into force on January 1st 2011. From that date, designated organisations were required to nominate or appoint a responsible officer with statutory functions relating to the evaluation of the fitness to practice and monitoring of the conduct and performance of doctors with whom the body had a connection. The following year, on December 3 2012, all UK doctors were obliged to follow the relicensing regulations. Some of the new regulations can be particularly challenging for independent sector doctors: those practising within the NHS have had a system of regular appraisals and clinical governance for some years, which has become part of the culture of practising within the health service. However, independent sector doctors may practise in isolation, and perhaps don’t have the administrative backup that is necessary for successful revalidation. Aesthetic doctors also experience specific problems with appraisal and revalidation, particularly the difficulty in collecting supporting information, such as quality improvement data and feedback.


The GMC have told all doctors the date they want to receive their first revalidation recommendation from the responsible officer (RO) of each designated body (DB). This is the ‘revalidation submission date’ or RSD. If you are not aware of your RSD, you should log in to the ‘GMC online’ section of the GMC website to see confirmation of your designated body, and crucially the designated body that you have told the GMC will provide your ‘route to revalidation’. Your DB is defined by your clinical practice and the organisation with which you are associated. Examples of DBs for aesthetic doctors could be a private hospital or clinic with which they are contracted, and which has DB, or the British College of Aesthetic Medicine (BCAM), which is a designated body in its own right, and provides a revalidation service.


The minimum requirements for doctors before they will be able to be revalidated are precisely defined by the GMC. Whichever organisation provides your annual appraisals and revalidates you, they all have to follow the regulations (found on the GMC website) and ensure that mandatory information has been provided.
On the revalidation date the responsible officer of the DB will look at all five of the previous appraisals, and based on the ‘output statements’ and the appraiser’s summaries, will decide whether to recommend relicensing to the GMC. The responsible officer also examines the information held about the doctor within the designated body, for example complaints or problems that have been encountered in the previous five years. In the first few years of this process not all doctors will have five consecutive appraisals, so the responsible officers will base their conclu- sions on fewer appraisals. 


 You must make sure: 

  •  You are participating in an annual appraisal process, which has ‘Good Medical Practice’ as its focus 
  •  You are linked to a designated body 
  •  You know your route to revalidation 
  •  The GMC have been notified of the name of your designated body 
  •  You are collecting the appropriate information you need to be relicensed such as CPD evidence, colleague and patient feedback, quality improvement documentation, significant events and review of complaints and compliments 


  •  If you cannot demonstrate that you are having an appraisal each year, there is a risk that the GMC will consider that you are not engaging with revalidation 
  •  If your GMC licence is removed it is an offence to practice medicine in the UK 
  •  There is a substantial difference between being licensed and being registered with the GMC 
  •  The GMC will bring forward your revalidation submission date if it thinks you are not engaging with revalidation 
  •  If you cannot find a responsible officer or suitable person to revalidate you, the only way you can keep your licence is through the GMC’s ‘Alternative Route’, which will involve a GMC written examination, and a clinical examination, as well as the annual appraisal obligation

Emma Davies explains the proposed system of revalidation for aesthetic nurses 

Since 1995, registered nurses have been required by The Nursing and Midwifery Council (NMC) as part of The Code (NMC, 2008) to keep knowledge and skills up to date, recognise and work within the limits of their competency and take part in appropriate learning and practice activities to maintain and develop competence and performance. Post- registration education and practice (Prep) is a set of NMC standards and guidance designed to ensure nurses provide a high standard of practice and care. Prep standards are legal requirements which must be met in order for registration to be maintained. 


  1. A minimum of 450 hours practice in the previous three years. 
  2.  Undertake and record continuing professional development (CPD) over the three years prior to renewal of registration. This must constitute a minimum of 35 hours of learning activity relevant to practice.


At renewal of registration, nurses are required to sign a declaration that they have met the standards for Prep and may be required to submit evidence as part of NMC audit, (NMC, 2011).
In September 2013, The NMC met to decide upon a model for revalidation, “To increase public confidence that nurses and midwives remain capable of safe and effective practice”.
“The system of revalidation that we adopt must contribute to our core regulatory purpose, which is public protection. We aim to deliver a proportionate, risk- based and affordable system that will provide greater public confidence in the professionals regulated by the NMC. It is also important that revalidation raises standards of care and promotes a culture of continuous improvement amongst nurses and midwives.” (NMC, 2013)

The main difference between Prep and the proposed system of revalidation appears to be an additional requirement to use feedback, from service users, employers and colleagues, to review the way an individual works and confirmation from, “Someone well placed to comment on their continuing fitness to practice”. 
The NMC have consulted with a variety of stakeholders and now begin a six month public consultation to review and revise The Code (NMC, 2008), which sets out the standards of good nursing and midwifery practice, and how the proposed model of revalidation can be implemented in a variety of employment settings and scopes of practice. The new system is expected to launch in December, 2015. The consultation will run in two parts, the first will close on March 31, 2014. 

Nurses in aesthetic medicine work in a variety of ways; full time, part time, self- employed, alone, or as part of a team. 78% of BACN members work alone, 41% are self-employed, 82% work part time with 47% continuing to work in the NHS 100% have undertaken some form of
CPD (aesthetics specific) in the last 12 months, and 77% have undertaken more than three days in the last 12 months, far exceeding the NMC Standard. (BACN, 2013). We know there will be aesthetic nurses who do not access quality CPD activities and have had limited training, no supervision, mentoring or appraisal. Many of our members actively seek mentors and would welcome the opportunity to learn from their peers, but opportunities are very limited and there is currently no formal framework for mentoring, supervision or appraisal.
Developing and maintaining skills in this constantly evolving field requires considerable investment in both time and money. Treatments have become increasingly invasive and complex and the lack of regulation and the disconnect from the regulators in place gives us great cause for concern. As an organisation, the BACN has made a positive start in identifying the problems and constructively ensuring they are addressed either by us, or by the appointed regulator.
We have published ‘A Career and Competency Framework for Nurses in Aesthetic Medicine’, accredited by The RCN. The Framework recognises the evolving nature of aesthetic nursing and the need to provide clear guidance to help practitioners identify, evidence and develop competence. The practice of examination, supervision, assessment, appraisal and validation are key components. The document is designed as a practical and flexible tool, which can be useful in a number of ways. As a personal route map to benchmark current competency and identify personal training and learning needs, it provides suggestions for how competency may be evidenced and can be used with mentors, by educators, appraisers and employers. The main challenge and concern for nurses in aesthetic medicine is likely to be how they will access appropriate supervision, mentors and appraisal, if they are currently working alone. BCAM has been pro-active in organising Responsible Officers for appraisal and revalidation in line with GMC requirements. Currently, in nursing, there is no formal framework or accreditation/authority for appraisal. The BACN will be engaging with the NMC consultation in a constructive way and have been preparing to support members to manage any necessary change. 

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