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The GMC introduced revalidation for all doctors in the UK in a staged process, from December 2012. This introduction of mandatory revalidation, in order for doctors to retain their license to practice, was pre-empted by the legal requirement of independent healthcare providers who are Designated Bodies under the regulations, to appoint or nominate a Responsible Officer to oversee the process of revalidation for doctors who are employed by or contract with those organizations.
The legal requirement to nominate or appoint a Responsible Officer arises from the Medical Profession (Responsible Officer) Regulations 2010 as amended. Under these Regulations a Responsible Officer can be nominated for to act for an organization where the person fulfils the requirements of being a Responsible Officer set out in the Regulations, the person has the capacity carryout the responsibilities required and there is no conflict of interest.
What We Can Do
What We Can Do Where an organization feels that is would be impracticable to appoint a Responsible Officer internally, MyResponsibleOfficer.org.uk will provide a named Responsible Officer who can be nominated by your organization to act for you. Under the Regulations the nomination is a personal appointment however, in addition, the support services provided by MyResponsibleOfficer.org.uk will enable the Responsible Officer, the organization, the appraiser and the individual doctor to work together gathering and sharing appropriate information to enable an efficient and cost effective system of achieving revalidation for doctors.
Underneath and to the left of this section you will see a series of key questions regarding status as a Designated Body and the need to appoint or nominate a Responsible Individual.
Key Questions & Answers!
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What are Designated Bodies?The Regulations state that certain organizations are de facto Designated Bodies. These are listed in Part 1 of the Schedule to the Regulations and include large organizations such as NHS trusts, PCTs, Health Boards and the armed forces. Other organizations, listed in Part 2 of the Schedule, who employ or contract doctors are also deemed to be Designated Bodies, if the have a Prescribed Connection with one or more doctors. These include organizations providing: Treatment of disease, disorder or injury by or under the supervision of a medical practitioner Surgical procedures (including pre and post operative care) undertaken by or under the supervision of a medical practitioner Diagnostic and screening procedures (subject to some exclusions) Medical slimming services including the prescribing of medications In practice, these organizations are usually smaller independent healthcare providers who are registered with the Care Quality Commission (CQC). If these organizations have a Prescribed Connection with one or more doctors, then they are deemed to be Designated Bodies.
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Who needs to appoint a Responsible Officer?All Designated Bodies, with one or two minor and technical exceptions such as the Department of Health (who must appoint two!), must nominate or appoint a Responsible Officer, except where Part 2 listed organisations do not have what is called a Prescribed Connection with one or more medical practitioners. So, the requirement to nominate or appoint a Responsible Officer includes organizations who are Designated Bodies under Part 2 of the Schedule (ie in practice, CQC registered organizations) - however, this only applies if and so long as the organization has a Prescribed Connection with one or more doctors.
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What is a Prescribed Connection?Every doctor in the UK is required to have ONE prescribed connection to a Designated Body. Prescribed Connections are defined and set out in the regulations in a very specific hierarchy which determines the priority and order in which they are considered. There is no flexibility in the regulations for doctors to choose their prescribed connection. Under the Regulations the doctor is automatically linked to the highest priority Designated Body in the list - this is their Prescribed Connection.
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What is the Order of Priority of Designated Bodies?The priority of Designated Bodies is defined in the Regulations as follows (highest priority FIRST): ​ Postgraduate Deanery (where the doctor is in training) (England) Primary Care Trusts (where the doctor is on the GP Medical Performers List) Designated Bodies – where the doctor is an employee of the Designated Body Designated Locum Agencies – where the doctor contracts with that agency Designated Bodies – where the doctor has practising privileges within the organization Named Faculties or Societies – Pharmaceutical, Occupational, Public Health or the Independent Doctors Federation (IDF). The arrangements for doctors who are not captured by the above have not yet been Determined. In practice – the doctor must start at number 1 and work down to number 6. The FIRST one in the list which applies to the doctor is, in law, the doctor’s Prescribed Connection – irrespective of whether one further down the list also applies.
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Who can be a Responsible Officer?To be nominated or appointed as a Responsible Officer a person must be a licensed medical practitioner and must have been a medical practitioner throughout the previous 5 years at the time of appointment. The Responsible Officer must also undergo appropriate training to carry out the role.
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What are the responsibilities of a Responsible Officer?Responsible Officers must ensure that medical practitioners undergo regular appraisal, they must also investigate concerns about doctor’s fitness to practise referring concerns to the GMC, monitor compliance with GMC terms or conditions imposed on doctors practise, make recommendations on doctor’s fitness to practise, maintain records of fitness to practise evaluations (including appraisals, investigations and assessments). The Responsible Officer must also, in relation to employment of doctors by Designated Bodies, ensure that doctors have the necessary qualifications and experience, have satisfactory references and ensure that the doctors are satisfactorily identified. In addition the Responsible Officer has ongoing responsibilities relating to monitoring conduct and performance, ensuring that action is taken in response to concerns about doctors including initiating investigations and where necessary requiring training, retraining or remediation activities.
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Is there a flowchart showing this?