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The Problem<\/strong><\/p>\n\n\n\n GPs are being split into differentiated and undifferentiated camps by NHSE.<\/strong><\/p>\n\n\n\n NHS England (NHSE) is using its funding of English GP appraisals to lever the GMC appraisal and revalidation process for its own ends. There is no legal framework for the NHSE policy of insiting that GPs remain “undifferentiated”<\/p>\n\n\n\n Many GPs are now going to be labelled low volume workers even when they are working full time, simply because their work is deemed differentiated. Not as NHSE wants, which is for GPs to remain as newly qualified undifferentiated general practictioner, as found working in English street practice.<\/p>\n\n\n\n According to NHSE, GPs can only remain undifferentiated if they do at least 40 sessions in an English general practice as a generalist every year. I wondered if this policy is designed to ease GP shortage should 1000’s of specialising doctors be forced to work back in street practice for their 40 sessions.<\/p>\n\n\n\n NHSE and GMC functions are being mixed up by NHSE, and then is presenting that muddle as if mandated by law or by the GMC. Policy and guidance is masquerading as regulation.<\/p>\n\n\n\n The terms at the heart of the problem<\/strong><\/p>\n\n\n\n NHSE has introduced (or at least put in operation) the term undifferentiate<\/strong>d GP in a way that carries consequences inside appraisal conversations and splits the profession. A differentiated is no longer a proper GP. My GMC R.O. says this has been mandated for many years but I met it for the first time this year (2026). I see that NHS guidance is of 2018 vintage.<\/p>\n\n\n\n In correspondence and discussions, the working definition presented to me is broadly:<\/p>\n\n\n\n That is an extraordinary shift. Low volume meant low volume. Now it can mean high volume, wrong type.<\/strong><\/p>\n\n\n\n NHSE argues that all GPs should remain as trained, as generalists in case they return to normal practice. Once on the performers’ list a GP can do anything, including return to street practice without much ado. NHSE considers that a risk. But the same risk applies to specialists changing their scope of work. If we plan to, or change our scope of work we change our CPD accordingly. Nobody need keep up skills they were never need to use. But NHSE insists on it for GPs, and only GPs.<\/p>\n\n\n\n My situation: the new-to-us policy that does not fit with reality<\/strong><\/p>\n\n\n\n My working pattern has not changed in 15 years. Yet for the first time I have been labelled a low-volume worker. I work part time as an APMS GP in prisons and I also do remote location work. The latter is deliberate as it is one of the few ways left to retain genuinely generalist skills that modern English practice rarely uses (e.g. minor surgery and maternity exposure). In this appraisal year I worked around 135 sessions in prisons<\/strong> and another 45 sessions as undifferentiated-plus GP work<\/strong> in the Falklands, where GMC registration is mandatory, plus a few sessions at my old NHSE practice grouping. <\/p>\n\n\n\n GMC accepts overseas evidence when a small part of appraisal and 100% where GMC registration is mandatory (Gibraltar and beyond). NHSE does not accept it, only accepting English time as evidence.<\/p>\n\n\n\n Under the NHSE thinking my work was to be treated as low volume because most of the work was considered differentiated prison work. The rest was not undertaken in England so would not be counted (despite GMC accepting that evidence).<\/p>\n\n\n\n NHSE seeks that we demonstrate maintenance of skills that are outside our real scope of practice, or else do remedial work listed in our appraisal documentation to become undifferentiated.<\/p>\n\n\n\n Using appraisal and revalidation to enforce local objectives<\/strong><\/p>\n\n\n\n In communications about this issue, the message was that if a GP does not comply with NHSE undifferentiated expectations the Responsible Officer may find it difficult to recommend revalidatio<\/strong>n. I cannot see how that can be the case as thr GMC’s core revalidation principle is scope-based: you must be up to date and fit to practise within your scope of practice<\/em>. It is not a requirement to demonstrate competence in skills you do not do, cannot do, and will not do. Ii is not a GMC requirement to be undifferentiated. The GMC R.O. could not ‘find it difficult’ when the GP is fulfilling all GMC requirements.<\/p>\n\n\n\n Appraisal is not the place to force doctors to remain undifferentiated. If a commissioner or employer wants a particular service profile, that is a contractual and workforce-planning issue, not something to be smuggled into revalidation.<\/p>\n\n\n\n What the law actually says (England)<\/strong><\/p>\n\n\n\n 1) The performers List law gives NHSE some leverage, but not for this<\/strong><\/p>\n\n\n\n My R.O. stated that as NHSE is paying for my appraisal it is entitled to make adjustments in line with its policies. Those regulations require that performers list practitioners participate in an appraisal system established by the Board (NHSE):<\/p>\n\n\n\n That is the legitimate place where NHSE can set process<\/em> expectations for performers list governance.<\/p>\n\n\n\n 2) The Responsible Officer framework<\/strong><\/p>\n\n\n\n The where you do most work rule sits in the Responsible Officer Regulations, not in GMC registration rules and not in performers list entry rules. See The Medical Profession (Responsible Officers) Regulations 2010, regulation 10<\/a> (prescribed connection).<\/p>\n\n\n\n 3) Revalidation is anchored in the Medical Act, and the GMC can set guidance, not NHSE<\/strong><\/p>\n\n\n\n Revalidation is a statutory process under the Medical Act 1983<\/a>. The GMC may publish guidance on information\/evidence required for revalidation under section 29G<\/a>. The GMC\u2019s 2012 regulations that implement the licence\/revalidation machinery are The General Medical Council (Licence to Practise and Revalidation) Regulations 2012 (SI 2012\/2685)<\/a>.<\/p>\n\n\n\n In other words: NHSE can create policies for its governance systems. The GMC sets revalidation requirements through its statutory framework and its guidance.<\/p>\n\n\n\n What the GMC itself says about local requirements vs revalidation<\/strong><\/p>\n\n\n\n This is where the clearest support comes from. Two GMC publications provided to me contain explicit statements that should stop local objectives being imported into revalidation decisions.<\/p>\n\n\n\n GMC, 2017: Update on implementation of Taking Revalidation Forward recommendations<\/strong><\/p>\n\n\n\n Source: Strategy and Policy Board meeting, 9 February 2017, Agenda item 7. Original GMC link:<\/p>\n\n\n\n\n
In England, the performers list framework is statutory. The enabling power is in the National Health Service Act 2006, section 91<\/a>. The current implementing instrument is The National Health Service (Performers Lists) (England) Regulations 2013 (SI 2013\/335)<\/a>.<\/p>\n\n\n\n\n