Abuse of NHS Doctor’s Appraisal System

Some in the NHS  wish to use GP appraisals as a reference system, to check for suitability for a particular job by asking to GPs to send in their appraisal output data or “copy of appraisal”.  There are also administrators who wish to use doctor’s appraisals as a management tool for audit and performance in line with other work sectors’ appraisal systems.  The reply must be no to any request send copy of appraisal or appraisal summary to employers.  Doctors are already concerned about reflection in their appraisals after the Dr Hadiza Bawa-Garba case.  This new use as a reference tool would make matters much worse.

It was discovered in March 2021 that the GMC seemed to support the employers’ new stance  with a statement on GMC web site Appraisal documentation is confidential. When requested, doctors should share summary appraisal outcomes with the organisations where they work (in addition to their designated body) but they should not be expected to share their full appraisal portfolios on a routine basis.”    It turns out (March 2021) that the GMC now recognises that this wording is an error and will be changed.  The thrust of this essay remains true. I have been assured of this after representation to the GMC by the RCGP Revalidation team on my behalf.  My view is that, if anything, doctors could provide the appraisal statement which is a few tick boxes that in effect states that we have had an appraisal.  The statement is very different from the appraisal summary which is the detailed nub of the appraisal and should never be shared, nor should any other part.

Appraisals, if used as references by NHS Trusts, other employers or GP practices, will compromise the appraisal process and could break revalidation.  A salaried GP would certainly not want to share their appraisal  with their workplace and practice manager. Appraisers will start designing the appraisal output to reflect a new status as a reference for third parties to view, and not as the appraisal output is currently assumed to be; a confidential, reflective document, while appraisees will not mention serious issues.   

Below is the letter that started my concern I received after some months working via an agency.  I had worked in that area since 1993, and appraised locally.  I was licensed and revalidated:   

Hertfordshire Community NHS Trust   1st  August 2018                                                  Dear Dr Bulger   Re: Appraisal Output request for Gerard Bulger  As you will be aware the Responsible Officer regulations came into force in 2012. As the Deputy Responsible Officer for the Designated Body Hertfordshire Community NHS Trust (HCT), I am accountable for seeking regular assurance that Doctors who work for HCT in any capacity are up to date and fit to practice across their whole scope of work.  As such and in accordance with the HCT process Non Designated Body Doctors’ Governance Process’ approved in January 2017 by the Workforce and OD Committee, I kindly ask that you provide your last appraisal output form no later than 8th August 2018.As you will be aware the Responsible Officer regulations came into force in 2012. As the Deputy Responsible Officer for the Designated Body Hertfordshire Community NHS Trust (HCT), I am accountable for seeking regular assurance that Doctors who work for HCT in any capacity are up to date and fit to practice across their whole scope of work.”  

In March 2021 I got another request, a CQC inspired compliance list from another employer which included a demand for “copy of my appraisal”, as if standard and matter of fact.  My reply to both reply was no.  The employers can check references, my place on performers’ list (so therefore appraised) and can check I am licensed and revalidated on line.  The Trust or any other employer have no right to demand to see my appraisal output (which, as it happens is suitably glowing, so I should show it off); the  principle is that that appraisals are also private reflections.

West Herts Trust  tried to apply to NHS England for the appraisal data is if I was moving responsible officer that is moving area, using the RO to RO form (MPIT). NHS England’s response was robust and the request refused.  The data cannot be used by anyone other than the doctor’s one and ONLY responsible officer.  NHS England’s Programme Manager replied to me in 2018:” We would not consider sharing your appraisal documentation with any employer and it should not be used in the manner in which your organisation is suggesting. I am happy to write to them on behalf of your RO to confirm your fitness to practice and that you are fully engaged with the appraisal programme.  That is all..”

These requests are a nasty extension of the use of the appraisal system output as a reference and a management tool.  This is not appraisal’s purpose, which is about probity, reflection, developing a personal development plan for licensing and revalidation.  No doctor should volunteer to send their appraisal output to anyone outside their own Responsible Officer’s team.

West Herts implied in the letter that in effect a doctors could have more than one GMC responsible officer, so each Trust could view appraisals outputs. 

BMA: Responsible Officers (ROs) are the individuals within designated bodies who have overall responsibility for helping you with revalidation. A designated body is the organisation (likely to be your main employer) that will support you with your appraisal and revalidation.  You only have one designated body and one Responsible Officer irrespective of how many organisations you are contracted with or employed by. Only UK organisations can be designated bodies, because the legal rules that determine this – the Responsible Officer regulations – only cover the UK.

GMC: Taking Revalidation Forward  the GMC has the following statement in Sir Kieth Pearsons recommendations (Appendix B)
9 Responsible officers should make sure that the revalidation process for individual doctors is not used to achieve local objectives that are not part of the requirements specified by the GMC. 

LMC: “believes this is a gross misuse of the appraisal process and that there are no such requirements for outputs to go to new employers”

GPC: An employee should not be requesting this information and you do not need (nor should you) share it. All they need to know is that you are on the performers list (which you can only do it you are keeping up with appraisals and revalidation. 

During my time as an appraiser I assured my doctors that the appraisal process was confidential, and that the only person who may see it would be their one and only responsible officer and their appraiser.  A doctor has one, and only one GMC Responsible Officer, no matter how many employers he or she has.

We have understood that appraisal remains a formative and reflective process. The output has no pass or fail unless there are clinical risks found or the doctor is not engaging.  The purpose of appraisal is to demonstrate continued probity, learning and reflection to keep a license.  The doctor’s one R.O. can approve for revalidation after five years.

A Trust can check that a GP had had a recent appraisal, that he is licensed, revalidated and on the GP performer’s list.  Should a Trust need to know that a doctor is suitable for a particular job this is achieved by references and interview.  The appraisal data would be a poor way to do this.  To provide appraisal data to third parties is an extension of the appraisal and revalidation system beyond its scope and purpose.

GPs must refuse to send appraisal output demanded by employers. They have no right nor reason to see it. 

Gerry  Bulger



Covid: Bureaucracy blocked Clinicians working

Time to rage against most of the NHS? 10/01/2021

At the height of the second wave I was waiting for the call up to help in the overwhelmed hospitals or for the vaccination campaigns.    Not a word, not a single email.

Meanwhile my inbox was full of requests from Australian agencies offering up to $2,700 a day for Covid related work, in a country where, so far, Covid is pretty much under control.  I also remain on the Australian register, but I cannot get there unless I self-isolate at my expense in special hotels, and I would need a new visa.

Here in UK I did the in-house training for NHS Nightingale and its on-line modules, got the lanyard, ID card, staff number and T-shirt, but thankfully never needed.  I also other modules and the NHS “credentiality” checks for 111 primary care work. All that extra training is imposed on doctors as if they are not already in practice. It was designed for those coming out of retirement, and the rigid rules set place could not be changed for those already working and appraised.   A list of some of the stuff is here:  https://www.bbc.co.uk/news/uk-55516277

Most of so-called mandatory training modules such as anti-radicalisation are not even mandatory at all. Apart from some internal health and safety rules, there is no legislative or GMC requirement for the training modules. The “mandatory” aspect is an NHS urban myth that keeps many in employment.  Doctors must be professional and keep up to date.  We undergo annual appraisal and then revalidation to prove it. That alone is our training duty.  The NHS as invented the rest.  It may seem sensible that module to recognise allergic reactions.  But if any doctor does not know how to recognise or deal with that then we need to look seriously at the 10 years+ of medical training.  I very much doubt the Health Secretary’s vow to reduce this will have a lasting effect, as the culture to require this nonsense it too imbedded. https://www.bmj.com/content/372/bmj.n13

Did anybody in NHS other than Casualty and ITU staff in the NHS know there was a war on?   Could they not slash these requirements and call up trained doctors to help?

I was shocked and aghast attending “Pinnacle” and Covid Vaccine roll out on-line NHS Team Meeting seminar at the start of the vaccination programme.  Even the GPs leading it have got wrapped up in the bureaucracy of it and believed in it.  They should be in a rage.  Instead, their energy seemed to be directed to worrying about £10.00 fee for nursing home jabs.  Vaccinations centres as in GP hubs are being loaded with computers, printers and scanners and specialised software.  We all have computers in our pockets which can scan bar codes of all sorts, surely there is app for that would make that pile of kit redundant.   Less is more.

During that Team meeting it was clear that the hoops expected by the software and NHS minions were no longer necessary.  Previous anaphylaxis is not a contraindication, and no need to watch the patients for 15 minutes.

Sir John Bell has it bang on. “NHS could vaccinate UK against Covid in five days, says Oxford professor: Bureaucrats are blocking a rollout that could prevent many more deaths, according to Sir John Bell  https://www.theguardian.com/world/2021/jan/09/nhs-vaccinate-uk-covid-five-days-oxford-professor

Those working in Casualty and in ITU manage despite of the system. They pull in levers in Government and nothing happens, as the NHS system blocks and delays.  Time to rage against most of the NHS, not clap it. 

I carried on working elsewhere in the NHS part-time.



More of the pointless NHS Administration

Most of the boxes are NHS related 1993-2008

I have added back an archive of NHS Commissioning documents based in Hertfordshire, 1999-2008.

Perhaps someone will copy and paste some of the old documents for yet another new project, as all has been done before under different names.  Family health Authorities, Regional Health Authorities, Area Health Authorities. Primary Care Trusts. Practice Based Commissioning Groups, and now Clinical Commissioning Groups.  It’s pointless.

All NHS reforms do is play musical chairs.  No reform dares start on the basis that these functions are simply not needed. They are moved to different named bodies.

I have worked in Australia where these layers of NHS administration simply do not exist, despite the fact that Australia is considered to be over governed.


Part of the Achive