DOCTORS APPRAISAL CONSULTANCY APPRAISAL POLICY
INTRODUCTION & BACKGROUND
SCOPE OF THIS POLICY
MAIN PRINCIPLES OF APPRAISAL
APPRAISALS – THE REQUIREMENTS
CLINICAL GOVERNANCE EVIDENCE
GDPR COMPLIANCE AND PRIVACY
RECORDS AND CONFIDENTIALITY
DOCTORS IN DIFFICULTY
ROLES AND RESPONSIBILITIES
SELECTION, TRAINING, RETENTION AND REVIEW OF APPRAISERS
QUALITY ASSURANCE FOR APPRAISALS AND REVALIDATION
The purpose of this policy is to describe the policies and procedures followed by Doctors Appraisal Consultancy, ( DAC), relating to the provision of advice and support for UK doctors seeking appraisals, under the current regulations governing appraisals and revalidation. This is consistent with the NHS London recommendations that organisations include a clear succinct policy statement at the outset of their policy in line with good practice for all policies. This will be the guiding force for the work with linked documentation on the detailed process. This will state the purpose of appraisals and how DAC intends to operate, in order to support revalidation. In view of the fact that the process of revalidation remains subject to further development, this policy and its procedures will be reviewed as required to ensure it fulfils the requirements of compliance with best practice and guidance issued by the Department of Health (DH) and the General Medical Council (GMC).
INTRODUCTION & BACKGROUND
This policy document states DAC’s requirements and the approach to appraisals for Revalidation to ensure that licensed doctors remain up to date and fit to practise. Revalidation of licensed doctors will be required every five years and is based on comprehensive appraisals undertaken over that five year period. It is designed to improve the quality of patient care by ensuring that licensed doctors remain up to date and continue to be fit to practise:
- To confirm that licensed doctors practise in accordance with the GMC’s generic standards, Good Medical Practice
- For doctors on the specialist register and GP register, to confirm that they meet the standards appropriate for their specialty
- To identify, for further investigation and remediation, poor practice where local systems are not robust enough to do this or do not exist. All medical staff are expected to go through revalidation every five years. Primary Care organisations ( NHS Commissioning Boards) are responsible for recommendations on revalidation for doctors on Performers’ Lists. NHS Trusts are responsible for recommendations on revalidation for the doctors they employ either directly or through honorary contracts. Independent sector organisations are responsible for recommendation on revalidation for doctor they employ and/or those who practise through practising privileges for the majority of their clinical practice.
Legislation is now in place to ensure that revalidation applies to all licensed doctors. Current changes in the interpretation of the regulations relating to appraisal and revalidation are currently being monitored by DAC through its representation by its medical director at regular GMC/IHAS review meetings.
SCOPE OF THIS POLICY
The purpose of this policy is to outline the requirements and arrangements for conducting appraisals for UK doctors contracted with DAC, following direction by the General Medical Council and other relevant bodies. This policy is not exhaustive and is not intended to contain information on all aspects of Appraisal and Revalidation. Annual appraisal is a requirement, as part of revalidation, for all medical staff including: Clinical Fellows, Trust doctors, research fellows with clinical commitments, SAS grades on the old contract, and locums. The process of medical appraisal shall follow the method prescribed by the GMC and RST, which may be modified and updated from time to time.
This policy applies to all medical staff, who act as appraisers for DAC. DAC undertakes to allocate appraisals, for the appraisals to be undertaken, and for the provision of reports and other services to doctors , irrespective of age, disability, race, colour, nationality, ethnic origin, religion, gender, sexual orientation or marital status, domestic circumstances, social and employment status, HIV status, gender reassignment, political affiliation or trade union membership.
MAIN PRINCIPLES OF APPRAISAL
Appraisal is a supportive mechanism focusing on enhancing local systems of quality improvement. It is designed to recognise good performance, provide feedback, and assist in the identification of performance issues so they can be dealt with at an early stage. The appraiser will review various sources of supporting information with the doctor to gain a rounded impression of that doctor’s practice and inform a mutually agreed Personal Development Plan (PDP). Appraisal will identify doctors who are struggling to provide the supporting information that is needed to demonstrate achievement of generic and specialist standards. It will assist those doctors in identifying support and developmental needs at an early stage, before there is any question of concerns about patient safety.
Every doctor is responsible for ensuring that they are appraised annually on their whole practice, so will need to make arrangements to share information from each of their employers, including private practice, on an annual basis. Appraisals happen on an annual basis within each appraisal year. An appraisal is not considered to have been completed without timely sign off of a mutually agreed PDP (within a maximum of 28 days of the appraisal meeting). Revalidation will require a cumulative review of appraisals over a 5 year period.
CLINICAL GOVERNANCE EVIDENCE
The doctors contracted by DAC must ensure, where appropriate that effective and supported systems of clinical governance arrangements are available to enable doctors’ CPD. It is also essential that’s the appraiser ensures that the appraisal process covers the entire scope of practice of the appraisee. Doctors acting as appraisers must also ensure that the doctors who they appraise be able to monitor their practice through performance information, including clinical indicators relating to patient outcomes, through feedback from patients and colleagues etc. It is the responsibility of the doctor contracted by DAC to ensure that the appraisal is conducted in a manner that ensure appropriate evidence is provided by the appraise, and where this is not complied with, appropriate reference to this made in the appraisal form output statements.
GDPR COMPLIANCE & PRIVACY
RECORDS AND CONFIDENTIALITY
The detail of discussions during the appraisal interview would generally be considered to be confidential to the appraisee and appraiser. However within the context of appraisal for revalidation, the appraiser will be reporting to the Responsible Officer on the general outcomes of their appraisals. Therefore the appraiser will need to escalate any concerns about performance that arise during the appraisal discussion, in line with the GMC’s relevant policies and guidelines. The responsible officer has the right to see the detail of the appraisal of any doctor who has a prescribed connection to the RO / DB who has contracted with DAC for provision of appraisal services. This should be in an appropriate form to allow the RO to ascertain that he/she is satisfied that the doctor meets the standards for a recommendation on revalidation. The appraiser and the appraisee will need to retain copies of the appraisal documentation over a five year period. It is a condition of this agreement that the appraiser contracted with DAC keeps the appraisal copy in an appropriate secure place, such as on a single ‘secure server’ rather than on a computer. The appraisee should retain and add to their supporting documentation in an appraisal folder.
DOCTORS IN DIFFICULTY
The appraisal process has been introduced so that patient safety is paramount. In the event that the appraisal process indicates that a doctor is ‘in difficulty’, the DAC appraiser must escalate this to the relevant RO without delay, who will deal with the issues in accordance with the DB’s relevant policies and guidelines. It is accepted that organisations need to deal with performance issues as they arise, and not to wait until the appraisal. It may be appropriate to delay an appraisal under such circumstances, but a doctor’s appraisal for revalidation has to take place annually within the financial year. If during the appraisal process, it comes to the attention of the DAC contracted appraiser that there are serious practice concerns about the appraisee’s fitness to practice, then the GMC and the relevant RO must be notified without delay, a copy of any written report, or record of relevant discussions, being provided to the Medical Director of DAC.
The Doctors Appraisal Consultancy is committed to high standards of ethical, moral and legal business conduct. In line with this commitment, and Doctors Appraisal Consultancy’s commitment to open communication, this policy aims to provide an avenue for employees and directors to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing. This whistleblowing policy is intended to cover protections for you if you raise concerns regarding Doctors Appraisal Consultancy such as concerns regarding:
- Incorrect financial reporting;
- Unlawful activity; activities that are not in line with Doctors Appraisal Consultancy policy, including the Code of Business Conduct; or activities, which otherwise amount to serious improper conduct.
- Safeguards Harassment or Victimization – Harassment or victimization for reporting concerns under this policy will not be tolerated.
- Confidentiality – Every effort will be made to treat the complainant’s identity with appropriate regard for confidentiality.
- Anonymous Allegations – This policy encourages employees to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will be explored appropriately, but consideration will be given to: The seriousness of the issue raised; The credibility of the concern; and The likelihood of confirming the allegation from attributable sources.
- Bad Faith Allegations – Allegations in bad faith may result in disciplinary action.
Procedure: 1. Process for Raising a Concern Reporting- The whistleblowing procedure is intended to be used for serious and sensitive issues. Such concerns, including those relating to financial reporting, unethical or illegal conduct, may be reported directly to Doctors Appraisal Consultancy Medical Director.
Timing – The earlier a concern is expressed, the easier it is to take action. Evidence – Although the employee is not expected to prove the truth of an allegation, the employee should be able to demonstrate to the person contacted that the report is being made in good faith.
Procedure: 2. How the Report of Concern will be Handled The action taken by Doctors Appraisal Consultancy in response to a report of concern under this policy will depend on the nature of the concern. The Doctors Appraisal Consultancy Board of Directors shall receive information on each report of concern and follow-up information on actions taken.
If a complaint requires escalating this should be directed to the Responsible officer of the Designated body to whom Doctors Appraisal Consultancy is connected.
Initial Inquiries – Initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should take. Some concerns may be resolved without the need for investigation. Further Information -The amount of contact between the complainant and the person or persons investigating the concern will depend on the nature of the issue and the clarity of information provided. Further information may be sought from or provided to the person reporting the concern.
ROLES AND RESPONSIBILITIES
The medical director of DAC will be responsible to ensure that all appraisals undertaken by doctors contracted with DAC are undertaken following the policy described here. The DAC contracted doctors themselves will have the responsibility of;
- Following the GMC guidelines for Good Medical Practice in their own medical practices.
- Follow the recommendation as and obligations described in this policy when undertaking appraisals.
- Keep up to date in their knowledge and skills regarding appraisals and revalidation, through education and training, as this applies to them providing a high quality service to DAC.
Note this policy governs he relationship between DAC as an organisation, and appraisers (doctors who are conducting appraisals) , who have been contracted to DAC. This includes Dr. Paul Myers, DAC medical director, who undertakes to comply with this policy. It is recognised that in those cases where there is a direct contractual relationship between a DB and the appraising doctor, (appraiser), for example when DAC has introduced the RO of the DB to the DAC appraiser, then the appraiser must comply with the appraisal policy of that DB. Generally the policies will cover similar areas, and be in concordance with one another, but in cases of uncertainty regarding policy wording the obligations of the policy of the DB in question, take precedence.
THE DAC APPRAISAL PROCESS
The GMC regulations call for a five-yearly demonstration of all doctors’ fitness to practise, to be based on information and evidence that should already be available to employing organisations, as it forms part of good clinical governance. While there is a clear connection between revalidation and appraisal, there are also differences. Revalidation concerns itself with a standard measured against the framework of the GMC’s guidance Good Medical Practice, while NHS appraisal takes, in addition to this, a broader look at a doctor’s work and service delivery. Medical appraisal differs fundamentally from appraisal in other settings due to its elemental link with external professional regulation and revalidation. Medical appraisals are based on a doctor’s performance as described in the GMC’s Good Medical Practice:
Areas covered by the appraisal:
- Quality of clinical care feedback including audits
- Feedback from patients
- Feedback from colleagues
- Complaints, clinical incidents and significant events
The Appraiser’s Obligations Appraisers having been referred from DAC will adhere to the DAC Revalidation & Appraisal Policy as follows :
- Organise all their appraisals within the appraisal timeframe
- Review appraisal documentation and evidence no less than 14 days before the appraisal interview takes place, identifying key areas for discussion
- Ensure all paperwork and electronic files are processed as required on completion of the appraisal interview, including the signing off of the PDP by both parties.
- Report on the outcome of their appraisals to the appropriate Responsible Officer. This should include a full summary statement of the appraisal, written against the designated bodies template for appraisal summaries, where this is available.
- Undertake appraisal training and attend period updates as required
- Take part in a performance review, including feedback on performance in their role.
- Organise for their own appraisal in a timely manner
- Ensure that they are up-to-date with respect to equality and diversity training.
- Ensure their statutory and mandatory periodic training is up to date.
The Appraisal Protocol
The Appraisal process comprises of five phases:
- Phase 1: Preparation work and information gathering by both appraiser and Appraisals for revalidation are made up of whole practice appraisal and therefore appraisees must provide information from all organisations that employ them. Appraisers should have information from the doctor’s previous years’ appraisal summaries and PDPs within the revalidation cycle available for their review.
- Phase 2: Appraisal discussion including a review of the previous year’s PDP
- Phase 3: Notification & return of the appraisal in electronic form to the Responsible Officer or their nominated deputy, including an agreed new PDP going forward. The appraisee is responsible for also keeping a copy of all their appraisal documentation including all supporting information, for the duration of the revalidation cycle. This information may need to be seen by the Level 2 Responsible Officer, by authorised external auditors of the appraisal process and by the GMC at their discretion.
- Phase 4: Review & reporting by the Level 2 Responsible Officer
- Phase 5: Issue of “Statement of satisfactory completion of appraisal” signed off by both parties within 28 days of the appraisal meeting
- Phase 6: annual appraisal completed.
The Annual Appraisal Cycle All UK doctors will require an annual appraisal to support their application to be relicensed. DAC believes that, irrespective of the doctor’s revalidation date, or the date of their initial first appraisal, this is interpreted as meaning that any given the doctor should be able to provide evidence of an appraisal within any given 12 month period. Following this, each doctor should have their appraisal within 12 months of their last appraisal., through the five year cycle. Preparing for appraisal It is essential that adequate time is allocated for preparation, both for the appraiser and appraisee. Preparation time and time for carrying out the appraisal should take place during usual working hours; proper time should be included in the job plan of the appraiser for this purpose. Successful appraisal depends on both the parties giving their contribution some thought beforehand. Both parties should give themselves enough time to produce, exchange and consider any documents necessary for the appraisal – a few weeks rather than a few days in advance is best. Where, for whatever reason, a third party needs to contribute to an appraisal this should also be discussed and agreed well in advance. It is very important that the discussion, a vital component of appraisal, is planned in diaries well ahead and protected. Ad hoc arrangements will fail to properly support either the appraisee, or the appraiser. Appraisal for revalidation requires that annual appraisals are carried out and signed off in year, in line with the organisation’s own appraisal cycle. Therefore, the timing, location and people involved in the appraisal need to be discussed and confirmed at least six weeks beforehand.
There are certain circumstances when a planned appraisal can be deferred, for example in the event of the doctor’s maternity leave or prolonged sickness absence. The responsible officer of the designated body must be informed in such a situation. Otherwise appraisals must continue. For example in the event of the doctor going through GMC fitness to practice procedures, then their revalidation recommendation is put on hold, but annual appraisals for revalidation will still be required.
The revised documentation will form part of the overall process but while completing the documents is an important facet of appraisal, as it provides a written agreement and encourages consistency, dialogue between individuals and the exchange of views is equally important. Every doctor being appraised should prepare an appraisal folder of all the documents (information, evidence and data) which will help inform the appraisal process, and this can and should be updated as necessary. The documentation should represent their whole practice and include information from each of their employers. The documentation should continue to allow access to the original documents in the folder in a structured way, record what the appraisal process concluded from them and, finally what action was agreed as the outcome following discussion (PDP). What goes into the folder will, for the most part, be available from clinical governance activity, and other existing sources. Consultants and Specialty Doctors on the new contract will also use information from the job planning process. Doctors need to consider which documents they need to collect for the appraisal process. It is recommended that wherever possible all the above information is retained electronically within secure systems. As part of revalidation, employers may need to make more information available to appraisers, and to ensure that appraisers are fully trained in the interpretation of this information. Annual appraisal documentation will need to be stored securely over the five year revalidation cycle.
SELECTION, TRAINING, RETENTION AND REVIEW OF APPRAISERS
The process for the selection of appraisers will ensure that doctors with the appropriate expertise, skills and commitment are selected for this role. DAC will scope the number of appraisals that will be needed and ensure there is a sufficient pool of trained appraisers within the organisation to carry out these appraisals. There will be a database of appraisers that will be maintained by the DAC medical director and his team. The selection and training of new appraisers will be carried out as and when required. National guidelines will be followed regarding curriculum and approved training. Currently the minimum training requirement to be enrolled as an appraiser through DAC is through pre-existing training by an accepted organisation providing appraisal services such as the NHSCB, the Independent Doctors Federation, or the British College of Aesthetic Medicine. It is recommended that, to ensure fairness, equity and to mitigate against conflicts of interest, an appraisee will not be appraised by the same appraiser for more than three appraisal cycles. Medical staff with appraiser responsibilities will have this included in their own appraisal to ensure their competence and performance is satisfactory. The team of appraisers will have periodic meetings to ensure consistent standards are maintained. Appraisers must declare any conflicts of interest with their appraise, such as a personal or family relationship.
SKYPE ONLINE VIDEO-CONFERENCE APPRAISALS
Over the 12 months to 2015 a consensus view from a number of responsible officers and senior appraisers contributed to these guidelines for the use of either skype or google ‘hangouts’ to support online appraisals.
- While the default process for DAC appraisals are face to face consultations, it is accepted by both the GMC and NHS England that remote videoconference appraisals can be provided under current regulations. Indication for this would usually be for geographical issues, although other circumstances can be justified, and this should be assessed on a case-by-case basis.
- The appraiser must be satisfied that they have identified the appraisee doctor accurately, for example by reviewing appropriate ID evidence such as passport or driving licenses.
- The DAC appraisal planned to use video conferencing processes must be approval by the DAC senior clinical lead before being completed.
- The final (fifth) appraisal of any revalidation cycle must be face to face, and video conference processes should not be used in this situation. For the avoidance of doubt this means that no videoconference meeting is allowed if the doctors revalidation submission date is less than 12 months from the proposed appraisal meeting date.
- The appraiser is responsible to check the technology being used for the online appraisal and needs to ensure appropriate backup systems are in place, in the event of technical failures.
- If an online video conference has take place this should be specifically referred to in the appraisal output summary.
- If an on line appraisal takes place there should be arrangements such that both the appraiser and the appraisee (doctor) have access to the online appraisal form , which can be referred to and discussed in a similar manner as a standard face to face appraisal.
COMPLAINTS, INVESTIGATIONS AND FORMAL PROCEDURES
Both the appraiser and the appraisee need to recognise that as registered medical practitioners they must protect patients if they believe that a colleague’s health, conduct or performance is a potential risk to patient safety. If, as a result of the appraisal process, the appraiser believes that the activities of the appraisee are such as to put patients at risk, then the appraisal should be stopped and the matter referred to the relevant RO in line with the organisation’s policies immediately. It is understood that this would happen only on the rarest of occasions. If during the appraisal process there arises a complaint , for example regarding the quality of the appraisal, where the appraisee has a concern about their appraiser all the appraisal process, or the recording of the appraisal interview, the reporting to the RO, or any other concern or complaint that arises, this should be reported in writing to the DAC medical director, within 21 days of the completion of the appraisal. The complainant will receive an acknowledgement within a maximum of seven days of receipt of the complaint. The complaint will be investigated by the DAC director, and a report sent to the complainant within 28 days. In investigating a reported complaint all required responses will be sought , particularly from the RO, the appraisee, and the appraising doctor, as appropriate, prior to the completion of the report into the complaint. In a case where a complaint concerns regarding fitness to practice arise, then the GMC is notified immediately, without waiting for the outcome of the complaints procedure investigation. In the event that an Appraisee is under investigation or disciplinary hearing or subject to an impending investigation or disciplinary hearing then the Appraisee must inform the Appraiser prior to the appraisal meeting. The appraisal meeting shall continue but note must be made of this in the documentation. The information provided by the Appraisee will include compliments, ALL complaints from all locations in which the Appraisee works relating to the Appraisee, serious untoward incidents, any matters concerning criminal convictions, GMC or other concerns raised by other regulators (e.g. CQC).
QUALITY ASSURANCE FOR APPRAISALS AND REVALIDATION
The quality of appraisals and revalidation will be assured through regular reports to internal and external groups. DAC will maintain a database of appraisers with whom it is associated, confirming the numbers of appraisals completed across the organisation, any key themes that are emerging and recommendations for improving the process and quality (if relevant) for the following year in line with national guidance. It is a requirement that appraisees are asked for feedback on their experience of appraisal annually and the information obtained will be used to further develop appraisers’ performance.
In order to fully assess the DAC appraisal service the following QA processes will be developed and reported upon annually :
- Feedback from doctors having undertaken DAC appraisals (i.e. the appraisees)
- Feedback from DAC appraisers.
- Feedback from ROs to who DAC appraisals have been contracted.
- Assessment of Appraisers report including details of appraisal training
- Assessment of sample appraisal output statements
- Complaints and Concerns reported.
- Assuring the Quality of Medical Appraisal. http://www.appraisalsupport.nhs.uk/files2/Assuring_the_Quality_of_Medical_Appraisal .pdf
- Strengthening NHS Medical Appraisal to Support Revalidation in England A proposal paper for piloting from the NHS Revalidation Support Team http://www.revalidationsupport.nhs.uk/files/Strengthening%20Medical%20Appraisal%2 0to%20Support%20Revalidation%20in%20England.pdf
- Assuring the Quality of Training for Medical Appraisers. http://www.appraisalsupport.nhs.uk/files2/assuring_quality_training_medical_appraise rs1f.pdf
- Assuring the Quality of Medical Appraisals for Revalidation. http://www.revalidationsupport.nhs.uk/Assuring_the_Quality_of_Medical_Appraisal_fo r_Revalidation.pdf
Details of generic supporting information requirements are in:
Specific guidance on appropriate content for MSF.
http://www.gmc- uk.org/static/documents/content/Guidance_on_colleague_and_patient_questionnaires -low.pdf
Specialty-specific guidance on supporting information was published by the Academy of Medical Royal Colleges in June 2012: http://www.aomrc.org.uk/revalidation/revalidation-publications-and- documents/item/speciality-frameworks-and-speciality-guidance.html