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Produced by Mr Declan Flanagan. Responsible Officer Rayvathi John, Revalidation support manager Michael Ferguson Revalidation Administrator Emral Jarrold, acting Revalidation Support Manager 1 Version: 0 Version: 0 Annual Report for Medical Revalidation 2013- 2014

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Page 1: Moorfields Eye Hospital NHS Foundation Trust | - … 5... · Web viewOf the 256 doctors the numbers of completed appraisals within the appraisal year 2013-2014 were 207 [80.9%]. This

Produced by

Mr Declan Flanagan. Responsible Officer

Rayvathi John, Revalidation support manager

Michael Ferguson Revalidation Administrator

Emral Jarrold, acting Revalidation Support Manager

1Version: 0Version: 0

Annual Report for Medical Revalidation 2013-2014

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Annual Board Report for Medical Revalidation

2013-2014

1. Executive summaryAs of the 31st March 2014, 256 doctors were attached to Moorfields Eye hospital for the purpose of revalidation. This is referred to as having a prescribed connection with the trust. It is relevant that the approximately 55 Specialist Registrars in the Trust do not have a prescribed connection with the Trust for appraisal and revalidation purposes. Annual appraisal of SpR’s [ARCP] is the responsibility of the London Deanery though Moorfields consultants who are clinical or educational supervisors have an active role in this process.

Of the 256 doctors the numbers of completed appraisals within the appraisal year 2013-2014 were 207 [80.9%]. This included all Consultants, SAS, Trust fellows, Locum and honorary doctors.

The Trust submitted a mandatory Revalidation Annual Organisational Audit (AOA) to NHS England [NHS E] covering the period April 2013 – March 2014. The Trust received comments on this audit in late July 2014 from NHS England. The report compares Moorfields performance with the rest of London. 80.9% of all Moorfields doctors had an appraisal with the reporting period. This compares with 79.5% for the rest of London and 83.8% for the whole of NHS England. See Appendix C for a breakdown of this data. The full organisational audit report from NHS England is available on request.

One hundred doctors have now been successfully revalidated by the Trust.

2. Purpose of the PaperAs part of the framework for quality assurance and for the purpose of revalidation, NHS England has requested this Annual Report to cover the period of 2013-2014 together with the compliance statement (Annex D). This follows the completion of the Annual organisation Audit (AOA) exercise which was submitted in May 2014.

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The paper is intended to provide assurance to the Board that, in line with a number of self- and external assessments during the course of the year, the trust is fulfilling all the requirements for revalidation.

3. Background

Medical Revalidation was launched nationwide in December 2012. The purpose of the implementation of Revalidation was to strengthen the way that doctors are regulated, with the aim of improving the quality of care provided to patients, improving patient safety and increasing public trust and confidence in the medical system. 

The trust has assigned a Responsible Officer, Declan Flanagan, Medical Director and Clinical Revalidation lead, Miss Alison Davis, Consultant Ophthalmologist to lead on the implementation and delivery of the Revalidation requirements. With effect from June 2014, Miss Poornima Rai, Locum Consultant Ophthalmologist has replaced Miss Davis as Clinical Revalidation lead.

Moorfields Eye Hospital has a statutory duty to support the Responsible Officer in discharging their duties under the Responsible Officer Regulations1 and it is expected that provider executive teams (Trust Management Board) will oversee compliance by:

monitoring the frequency and quality of medical appraisals in their organisations;

checking that there are effective systems in place for monitoring the conduct and performance of their doctors;

confirming that feedback from patients is sought periodically so that their views can inform the appraisal and revalidation process for their doctors; and

Ensuring that appropriate pre-employment background checks (including pre-engagement for Locums) are carried out to ensure that medical practitioners have qualifications and experience appropriate to the role undertaken.

1 The Medical Profession (Responsible Officers) Regulations, 2010 as amended in 2013’ and ‘The General Medical Council (Licence to Practise and Revalidation) Regulations Order of Council 2012’

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The trust submitted an annual Organisational Readiness Self-Assessment (ORSA) in May 2013; to The NHS Revalidation Support Team (RST). Under the RAG rating system (Red, Amber, Green) this report received a green rating. This rating reflected the efforts of the Revalidation team and progress made in implementing actions which had previously been identified earlier in the revalidation preparation process.

4. Governance Arrangements and Quality AssuranceA revalidation group had already been established which was made up of the Medical Director, Clinical Revalidation Lead, Revalidation/HR Advisor and Recruitment/Revalidation Assistant. In addition the revalidation group is supported by Trust Audit team.

In October 2012 the Clinical Revalidation lead presented a paper to the Quality and Safety Committee with an update on the trust’s progress in ensuring readiness for Revalidation.

An audit was undertaken in March 2013 through our internal audit programme, KPMG, the outcomes of which has been presented to the Audit Committee in May 2013.

This audit identified the need to procure a centralised Revalidation Management System (RMS) to audit, monitor and capture accurate data for appraisal and revalidation. The Trust undertook an evaluation of commercially available RMS systems. A bespoke system from Premier IT was then purchased and has been in use since 1st April 2014. Training for the RMS was organised over 12 sessions of 1.30 hours per session. In addition support was also provided to cover the individual appraisal needs for doctors.

The audit also identified the need to confirm that if doctors worked for other institutions as well as Moorfields that evidence of this work was considered at their annual appraisal. Doctors are now required to produce this evidence. This evidence is usually in the form of a letter from the Chief Executive or Medical Director of the other institution.

In the past year the Trust introduced an electronic incident reporting system. This gives the Responsible Officer and individual doctor’s access to all incidents in which they have been named. There is a similar system for complaints.

An internal audit was conducted on the Model Appraisal Guide (MAG) by the revalidation group in 2013-2014 to ensure the quality assurance of appraisal. The aim of the audit was to determine whether the medical appraisal process was fit for purpose. In addition it also aimed to identify the number of doctors who had completed an appraisal between 1st December 2012 and 1st June 2013.

The outcomes of this Audit will be reported to the Trust Management Board in August 2014. The revalidation team will in the second cycle address the outcome of

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the audit which will be submitted to Audit team or Quality and safety committee in the last quarter of 2014-2015.

The Responsible Officer has discussed revalidation of doctors employed by Moorfields Dubai [MEHD]. The GMC have confirmed that as these doctors are responsible to the Medical Director of Moorfields Eye Hospital and as they work only for MEHD that they can be revalidated by the Moorfields Responsible Officer. The previous Medical Director received training in appraisal to GMC standards to support this process. Another consultant has recently been trained to fulfil this role until the new Medical Director is appointed. The Quality and Safety structure in MEHD recently been strengthened with the appointment of a Quality and Safety officer responsible for collection of clinical outcome data for clinical audits. This will strengthen the annual appraisal process. This officer has recently spent a week working with the Quality and Safety team in London to ensure that clinical quality assurance is performed to the same standard in MEHD as in London. A member of the Quality and Safety team will also spend a short period of time in MEHD in August 2014

The Revalidation and Quality & Safety team is providing support to ensure that all medical staff in the new Moorfields Croydon satellite have training in appraisal and clinical audit to ensure that they fulfil all the requirements for revalidation.

The Revalidation group are currently in the process of scheduling an Independent audit by a third party (yet to be agreed) to assess the quality assurance of the internal Revalidation process adopted by the trust. It is hoped that the findings of this audit will be presented to the Audit Committee by December 2014. In addition an internal audit is to be arranged to look at the appraisal process currently used by the trust.

Weekly meetings are undertaken within the Revalidation group to address any adhoc issues and concerns that may arise of the Revalidation and appraisal process.

The Trust Responsible Officer is appraised by an external appraiser nominated by NHS England and his Responsible Officer is Dr Andrew Mitchell of NHS England.

The Responsible Officer {RO] and the Trust Revalidation lead attend regular external Responsible Officer Network meetings with other RO’s, representatives from the GMC as well as NHS England.

a. Policy and Guidance

There is a Medical Revalidation and Appraisal policy as well as a Back on Track Policy in place these polices was ratified by the Board in March and October 2012

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respectively. These policies were drafted in accordance with the guidance issued by the GMC and NCAS. The Back on Track Policy was amended in May 2012 to reflect changes made by the GMC.

Doctors are able to access the polices under http://mehhome/resources/policies-procedures-and-guidelines/policies-and-procedures/

5. Medical Appraisal

a. Appraisal and Revalidation Performance DataFor 2013-2014, the Trust recorded that out of 256 doctors 207 appraisals were completed.

Collation of data for audit and reporting during 2013-2014 has been a major challenge for the team in the absence of any IT Revalidation management system. Until the system is fully embedded, the Trust is currently monitoring the appraisal data using a manual process. Prior to the implementation of the Revalidation management system and during this report period, the Trust has used various systems to manage the appraisal and revalidation process. For example the doctors used a PDF version of the appraisal form called Model Appraisal guide (MAG) which after completion was stored either on the Trust appraisal system or on the individual’s local drive. The Trust was also engaged with 2 different providers for the purpose of obtaining colleague and patient feedback, which through a manual process were updated on an internal database (standard excel spreadsheet). This experience with different providers was helpful in deciding what comprehensive RMS to purchase. The spreadsheet also requires regular audit to ensure they are aligned with all current starters and leaver in the trust (which is sourced from the Trust HR system).

The manual process also relies heavily on the available resource (both internal and external) to update the information on a regular basis. This arrangement also, has a restricted functionality on producing details on appraisal information or being able to produce a report to identify reasons for incomplete appraisal, appraisals output not signed, etc.

The new revalidation management system in use since May 2014 will make it much easier to manage the appraisal process and audit the quality of the process.

See Extract from AOA report-Appendix A submitted to NHS England in May 2014 on the appraisal undertaken in the trust.

b. Appraisers

Additional appraisers have been recruited to ensure that each appraiser has a manageable workload. Training by accredited external providers has been provided for all new appraisers and refresher training for some of the existing trainers.

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As of March 2014, 46 trained appraisers were engaged in the process of Medical appraisal up to revalidation standard.

The trust also organised top-up training for existing appraisers on the 15 th October 2013 to 16th December 2013 and 23 appraisers in total attended these session. This training was organised to ensure the knowledge and skills remain up-to-date within the GMC’s requirement.

The trust has been continuously recruiting new Medical appraisers to balance the proportion of the appraiser and appraise ratio and ensure that the workload for each appraiser remains manageable.. Further training has been organised in July 2014 and although outside the period covered by this report a total of 56 appraisers have now been trained.

The revalidation group intends to set up an appraiser network to offer ongoing support to appraisers and the details of this network are yet to be finalised.

c. Access, security and confidentialityThe trust has an implemented framework of Information Governance to ensure all the information held on staff members are complaint with the Data protection and confidentiality, information security and information quality on an annual basis.

d. Clinical Governance The trust has an established team and system to record all incidents and complaints through Risk and safety team. The report and details are available if requested to all staff so that they are able to provide the data at the time of their appraisal.

The trust also has a dedicated Audit team to assist the doctors and contribute to their clinical performance by auditing to the revalidation standards.

Clinical Governance and Clinical Audit meetings are held on a regular basis to offer support, training and updates to doctors. This is to enhance their professional development and ensure compliance with the requirements of the trust and professional bodies.

There were 57 doctors that required Revalidation during the reporting year 2013-20414. 100% Revalidation Recommendations were completed on time and below is the split:Positive recommendations - 55

Deferrals requests - 2

Non engagement notifications –N/A

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Reasons for all missed or late recommendations-N/A

See Audit of revalidation recommendation-Appendix B

Although outside the period covered by this report a total of 102 doctors have now been revalidated as of 26th August 2014. 43 more have dates to revalidate by the end of March 2015.

6. Recruitment and engagement background checks The Trust has a dedicated Human Resources team to ensure the Recruitment and Pre-employment checks are in place before the employee commences with the Trust. These checks also ensure collection of revalidation information if appropriate from previous employers.

The Trust HR team ensures that all staff are only appointed to the post once the following pre-employment checks are undertaken.

Identity checkQualification checkOccupational Health ClearanceDBS3 recent referencesRight to work in the the UK

Information Governance Training

Name of last responsible officer

Reference from last responsible officerRevalidation due date

7. Monitoring Performance The performance of each clinical service is monitored against 3 core clinical outcomes which are benched marked against published external outcomes.Doctors are required to produce at least one audit annually to recognised standards of their clinical outcomes covering a key area of their practice for their appraisal.

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8. Responding to Concerns and Remediation The trust has a Back on Track policy which is based on the guidelines provided by GMC and National Clinical Assessment Service (NCAS). The guidelines from the policy are used when required when responding to concerns about a doctor or when remediating a doctor.

The trust used the Back on Track policy for guidance in January 2013 to help a doctor return in an honorary capacity and worked closely with the GMC to support the doctor. However upon advice of the GMC this doctor’s honorary contract was terminated.

9. Risk and Issues The recorded average medical appraisals undertaken within secondary care during 2013-14 is 80%. Moorfields for the same period has recorded 81% which is marginally above the NHS average for appraisal.

The Revalidation team are continually tasked with identifying those doctors who have not yet had their appraisals due to maternity leave, illness, appraisal dates not set and leave dates imminent. During the last quarter of 2013-2014, some such cases were identified and postponements of their revalidation or appraisal were agreed by the Responsible officer.

The Revalidation team identified that most of the doctors who had not yet identified an appraisal date were temporary or short term contract holders. These were mostly trust Fellows who are employed for approximately 1 year from outside UK and do not wish to undertake an appraisal or be revalidated as there are no implications for them to practise in their home country after the termination of contract.

The Trust employs over 90 Clinical Fellows. These are either UK ophthalmologists who have completed their SpR training or have come from abroad for further subspecialty training. The Revalidation team has stressed the importance of annual appraisal to GMC standards to this group and provided additional training and support for them.

Associate Specialists are recognised nationally as a group that have had a low rate of annual appraisal in the past. For this reason the Responsible Officer and the revalidation team have supported them in preparing for appraisal. In addition 2 Associate Specialists from Moorfields attended a training day for them run by the London Deanery.

Moorfields has a substantial number of consultants with research roles and responsibilities with the Institute of Ophthalmology and other institutions. They are required to have annual joint clinical and research appraisals with clinical and

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research appraisers. The Revalidation Management system is being modified to facilitate this.

The trust creates awareness of the requirements and support in place for annual appraisal and revalidation during medical induction. Continuous support is also offered to all staff particularly clinical fellows and associate specialists by their services and the Revalidation team to ensure that they are all appraised to revalidation standards.

Temporarily appointed fellows, i.e. those on fixed term contracts should be listed on the Trust risk register for the purpose of annual appraisal and revalidation.

10. Corrective Actions, Improvement Plan and Next StepsAs mentioned above within the Revalidation group there has been an appointment of a new Clinical Revalidation lead Mrs Poornima Rai, Locum Consultant Ophthalmologist commenced these additional duties in June 2014. The new RMS system Premier IT was introduced in April and went live in May 2014, appropriate training has and is continually being provided.

Future Plans

To continue to develop and improve the new RMS by introducing additional features to replace the current manual forms which are used (Clinical declaration of practice elsewhere and appraisal form) .

The Clinical Revalidation lead will identify ‘Revalidation representatives’ from individual services and satellites to ensure the smooth operation of revalidation within the service and address queries and support revalidation.

A new support network system for all trained appraisers will be created to keep appraisers up to date with changes in revalidation, RMS improvements. The objective of this network is also to ensure that appraisers are supported and offered assistance where needed.

Modify the RMS system to facilitate joint clinical and research appraisals for clinicians with research roles in the Institute of Ophthalmology and other research institutions.

All the doctors who have not had appraisals or who have missed appraisal dates have now been identified using the RMS system. This will allow close monitoring of the appraisal progress of all doctors and provision of support if nay doctors are missing their appraisals.

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11. Conclusion and recommendation

Medical Revalidation is now in its 2nd year of implementation. A robust supporting structure has been developed and implemented in Moorfields for all doctors. 57 doctors successfully revalidated in 2013 – 2014, and since the start, 100 doctors have been successfully revalidated. There were only two deferrals both for justifiable reasons.

A number of self-assessments, and an external audit, have shown that Moorfields has undertaken all the necessary action to fulfil its responsibilities for revalidation.

An action plan, overseen by Dr Poornima Rai, Revalidation Lead, and supported by a dedicated resource in the HR team, will ensure that Moorfields remains fully compliant with all aspects of revalidation.

Additional development needs have been identified to ensure that doctors continue to be supported to collect and provide evidence for their mandatory quinquennial revalidation. Section 10 describes these developments that are required over the next year.

This report will be reviewed by the higher level responsible officer, Dr Andrew Mitchell of NHS England, and discussed at the Moorfields Responsible Officer’s annual appraisal. The Trust board is asked to approve the ‘statement of compliance’ Annex D confirming that the organisation, as a designated body, is in compliance with the regulations.

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Extract from AOA report-Appendix ASubmitted to NHS England on the year April 2013 – March 2014

ONLY DOCTORS WITH WHOM THE DESIGNATED BODY HAS A PRESCRIBED CONNECTION AS AT 31 MARCH 2014

Number of Doctors

Completed Appraisals

Percentage of appraisal undertaken

Consultants (permanent employed consultant medical staff including honorary contract holders, NHS, hospices, and government /other public body staff. Academics with honorary clinical contracts will usually have their responsible officer in the NHS trust where they perform their clinical work) 123 107 87%Staff grade, associate specialist, specialty doctor (permanent employed staff including hospital practitioners, clinical assistants who do not have a prescribed connection elsewhere, NHS, hospices, and government/other public body staff) 31 24 77%Temporary or short-term contract holders (temporary employed staff including locums who are directly employed, trust doctors, locums for service, clinical research fellows, trainees not on national training schemes, doctors with fixed-term employment contracts, etc) 91 69 76%Other doctors with a prescribed connection to this designated body (depending on the type of designated body, this category may include responsible officers, locum doctors, and members of faculties/professional bodies. It may also include some non-clinical management/leadership roles, research, civil service, doctors in wholly independent practice, other employed or contracted doctors not falling into the above categories, etc) 11 7 64% TOTAL The difference between the number of doctors and the number of completed appraisals is the number of missed or incomplete appraisal 256 207 81%

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Audit of revalidation recommendation-Appendix BRevalidation recommendations between 1 April 2013 to 31 March 2014Recommendations (inclusive deferrals) completed on time (within the GMC recommendation window)

57

Late recommendations (completed, but after the GMC recommendation window closed)

0

Missed recommendations (not completed) 0

TOTAL 57

Primary reason for all late/missed recommendations

For any late or missed recommendations only one primary reason must be identified

None

No responsible officer in post N/A

New starter/new prescribed connection established within 2 weeks of revalidation due date

N/A

New starter/new prescribed connection established more than 2 weeks from revalidation due date

N/A

Unaware the doctor had a prescribed connection N/A

Unaware of the doctor’s revalidation due date N/A

Administrative error N/A

Responsible officer error N/A

Inadequate resources or support for the responsible officer role

N/A

Other N/A

Describe other

TOTAL [sum of (late) + (missed)] 0

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Audit of concerns about a doctor’s practice- Appendix C

Concerns about a doctor’s practice High level

Medium level

Low level Total

Number of doctors with concerns about their practice in the last 12 monthsExplanatory note: Enter the total number of doctors with concerns in the last 12 months. It is recognised that there may be several types of concern but please record the primary concern

0 0 0 0

Capability concerns (as the primary category) in the last 12 months

0 0 0 0

Conduct concerns (as the primary category) in the last 12 months

0 0 3 3

Health concerns (as the primary category) in the last 12 months

0 0 0 0

Remediation/Reskilling/Retraining/RehabilitationNumbers of doctors with whom the designated body has a prescribed connection as at 31 March 2014 who have undergone formal remediation between 1 April 2013 and 31 March 2014

1

Other Actions/InterventionsLocal Actions:

Number of doctors who were suspended/excluded from practice between 1 April and 31 March:Explanatory note: All suspensions which have been commenced or completed between 1 April and 31 March should be included

0

Duration of suspension:Explanatory note: All suspensions which have been commenced or completed between 1 April and 31 March should be included

Less than 1 week1 week to 1 month1 – 3 months3 - 6 months6 - 12 months

0

Number of doctors who have had local restrictions placed on their practice in the last 12 months?

3

GMC Actions: Number of doctors who: Number

Were referred by the patients to GMC between 1 April and 31 March 1014

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Of these referral were not substantiated by the GMC and had no conditions placed on their practice, by the GMC or undertakings agreed with the GMC between 1 April and 31 March

9

Had their registration/licence suspended by the GMC between 1 April and 31 March

0

Were erased from the GMC register between 1 April and 31 March 0

National Clinical Assessment Service actions: 0

Number of doctors about whom NCAS has been contacted between 1 April and 31 March:

For advice 2

For investigation 0

For assessment 0

Number of NCAS investigations performed 0

Number of NCAS assessments performed 0

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Comparison of Moorfields Appraisal rates with rest of sector and NHS England Appendix D

2013/14 AOA indicator

SECTION 2: Appraisal

Your organisation’s

response

Same sector: Acute

hospital/secondary care

foundation trust

All

sectors:

Total DBs:

Your organisation’s response

No. of DBs in same sector and

(%) that said ‘Yes’

No. of DBs in ALL sectors and

(%) that said ‘Yes’

There is a medical appraisal policy, with core content which is compliant with national guidance, that has been

Yes 92 (90.2%) 590 (91.5%)

Number of doctors with whom the designated body has a prescribed connection on 31 March 2014 who

Your organisation’s response and (%)

calculated appraisal rate

Same sector appraisal

ALL sectors appraisal

Consultants 107 (87%) 87.1% 86.3%

Staff grade, associate specialist, speciality doctor

24 (77.4%) 78.2% 78.6%

Doctors on Performers Lists0 (0%) 100.0% 91.6%

Doctors with practising privileges0 (0%) 0.0% 74.2%

Temporary or short-term contract holders

69 (75.8%) 46.8% 53.9%

Other doctors with a prescribed connection

7 (63.6%) 51.3% 67.0%

Total number of doctors who had a completed annual appraisal

207 (80.9%) 79.5%

83.8%

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Statement of Compliance -Annex D

Designated Body Statement of Compliance

The Trust Management Board of Moorfields Eye Hospital has carried out and submitted an annual organisational audit (AOA) of its compliance with The Medical Profession (Responsible Officers) Regulations 2010 (as amended in 2013) and can confirm that:

1. A licensed medical practitioner with appropriate training and suitable capacity has been nominated or appointed as a responsible officer;

Comments: Yes

2. An accurate record of all licensed medical practitioners with a prescribed connection to the designated body is maintained;

Comments: Yes

3. There are sufficient numbers of trained appraisers to carry out annual medical appraisals for all licensed medical practitioners;

Comments: Yes 56 a ratio of 5-1 which exceeds the GMC guidance of 1-6

4. Medical appraisers participate in ongoing performance review and training / development activities, to include peer review and calibration of professional judgements (Quality Assurance of Medical Appraisers or equivalent);

Comments: Yes by feedback from appraises with refresher training provided by the Trust every few months [July 2014]

5. All licensed medical practitioners either have an annual appraisal in keeping with GMC requirements (MAG or equivalent) or, where this does not occur, there is full understanding of the reasons why and suitable action taken;

Comments: Yes. Some doctors retired completely from practice at the end of March 2014 so did not do an appraisal. A significant number of Clinical Fellows returned to their home countries in the reporting period. They no longer have licences to practice in the UK so did not have an appraisal. Some Clinical Fellows joined the Trust from abroad in the second half of this reporting period and had not yet had an appraisal by end of the reporting period. They can now be identified on the RMS system and will have an appraisal as will as all other doctors within one year of starting in the Trust.

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6. There are effective systems in place for monitoring the conduct and performance of all licensed medical practitioners, which includes [but is not limited to] monitoring: in-house training, clinical outcomes data, significant events, complaints, and feedback from patients and colleagues, ensuring that information about these is provided for doctors to include at their appraisal;

Comments: Yes. A significant improvement early in 2014 was the introduction of a electronic incident reporting system. This provides all doctors with a record of all incidents in which they have been named. This must be discussed at their appraisal. The Responsible Officer, the risk management team and the Revalidation team also have access to this data. This compliments a similar existing system for complaints in which doctors are named

7. There is a process established for responding to concerns about any licensed medical practitioners fitness to practise;

Comments: Yes

8. There is a process for obtaining and sharing information of note about any licensed medical practitioners’ fitness to practise between this organisation’s responsible officer and other responsible officers (or persons with appropriate governance responsibility) in other places where licensed medical practitioners work;

Comments: Yes, the form is referred to as F2 - Declaration of Other Clinical Practice and F3-Appraisal information

9. The appropriate pre-employment background checks (including pre-engagement for Locums) are carried out to ensure that all licenced medical practitioners have qualifications and experience appropriate to the work performed; and

Comments: Yes

10.A development plan is in place that addresses any identified weaknesses or gaps in compliance to the regulations.

Comments: See section 10 Corrective Actions, Improvement Plan and Next Steps

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Signed on behalf of the designated body

Name: _ _ _ _ _ _ _ _ _ _ _ Signed: _ _ _ _ _ _ _ _ _ _

[chief executive or chairman a board member (or executive if no board exists)]

Date: _ _ _ _ _ _ _ _ _ _

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