There are individuals within the NHS who view GP appraisals as a reference system, using them to assess a doctor’s suitability for particular roles by requesting GPs to submit their appraisal output data or a “copy of their appraisal.” Additionally, some administrators aim to utilise doctors’ appraisals as a management tool for audit and performance, aligning with appraisal systems in other work sectors.
Doctors should firmly refuse any requests to share a copy of their appraisal or appraisal summary with employers. Many doctors are already cautious about including reflections in their appraisals, especially after the Dr Hadiza Bawa-Garba case. Using appraisals as a reference tool would exacerbate these concerns significantly.
In March 2021, I discovered that the GMC appeared to support this new stance from employers. A statement on the GMC website read: “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 should not be expected to share their full appraisal portfolios on a routine basis.” However, the GMC later acknowledged that this wording was incorrect and replaced it with a fuller document, available here: GMC Information Sharing.
After representation to the GMC by the RCGP Revalidation team, I have been reassured that doctors are only required to provide evidence that they have had an appraisal. This can be done through the appraisal statement, which consists of a few tick-box lines with no detailed data. It merely confirms that an appraisal has taken place. This statement is entirely different from the appraisal summary, which contains the detailed content of the appraisal. The appraisal summary should not be shared, nor should any other part of the appraisal documentation.
If appraisals are used as references by NHS Trusts, other employers, or GP practices, this will undermine the appraisal process and potentially jeopardise revalidation. Doctors will avoid addressing challenges and will be unable to reflect in confidence. A salaried GP, for instance, would be highly reluctant to share their appraisal with their workplace or practice manager if workplace issues were involved. Appraisers may also begin tailoring their appraisal outputs to fit this new role as a reference for third parties, rather than as they are currently designed: confidential, reflective learning documents and private professional development plans.
Below is the letter that initially raised my concerns. It followed several months of working via an agency. I had worked in the area since 1993 and appraised locally. I was both 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 and data (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, frustrated by my refusal then tried to apply to NHS England for the appraisal data as if I was changing my GMC Responsible Officer (R.O), 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