RCoA response to government consultation on GMC legislative framework

The Royal College of Anaesthetists has responded to the Department of Health and Social Care consultation on reforms to the General Medical Council legislative framework.  

While we support some aspects of the proposed reforms, including measures designed to modernise the GMC and strengthen equality, diversity and inclusion, our response highlights several important concerns. These include the need for independent oversight, protection of the role of royal colleges in education, training and assessment, and clear differentiation between doctors and medical associate professionals.  

Our response represents the views of Council, informed by discussion with other groups within the College, including those of members who contacted us about the consultation.   

Summary points  

EDI and the role of royal colleges  

• We support the additional equality, diversity and inclusion (EDI) requirements in the Order. Regulatory bodies must maintain a proactive commitment to EDI to ensure the health system and GMC functions are open, inclusive and fair.
• Clearly setting out the role of professional bodies such as royal colleges in education, training and assessment would help strengthen confidence in the GMC’s decision-making and provide additional reassurance for patients and the public.   

GMC governance and independent oversight  

• Strong clinical representation on the proposed unitary board structure is essential for an organisation whose primary purpose is the regulation of doctors. We recommend the board should comprise at least fifty percent doctors.
• We do not support the removal of Privy Council approval for changes to GMC rules. Privy Council oversight provides an important layer of independent scrutiny and accountability.
• We do, however, support the Professional Standards Authority for Health and Social Care (PSA) being given more powers to compel information from the GMC where required.  

Overseas training programmes   

• We do not support the provisions in the Order for the GMC to be able to approve overseas undergraduate, foundation and postgraduate education and training programmes. While we are supportive of international partnerships where appropriate, approving overseas programmes seems incongruent with a UK regulator.  

Certificate of Completion of Training (CCT) 

• The legislation must explicitly preserve the CCT as a qualification for registered medical doctors who have successfully completed an approved postgraduate medical training programme. The CCT is a robust, internationally recognised and transferable qualification that enables doctors to practise autonomously at consultant or equivalent senior level.
• To minimise confusion, the Order should also recognise the role of the royal colleges in confirming and recommending appropriately qualified doctors for the award of a CCT. 

Professional registers  

• We do not support the creation of a single register for doctors, specialists and Physician Assistants (PAs) and Physician Assistants in Anaesthesia (PAAs). A single register risks increasing confusion about the distinct roles, responsibilities and training pathways of doctors and medical associate professionals.
• The Leng Review found that patients were often unclear whether they were being treated by a doctor or another healthcare professional. Consistent with those findings, we have advocated for separate registers: one for doctors and specialists, and another for PAs and PAAs. 

Professional titles  

• We recommend that anaesthetist and anaesthesiologist become protected titles to improve clarity for patients. We also support the proposal to change the title of anaesthesia associate to physician assistant in anaesthesia, in line with the recommendations of the Leng Review.  

Fitness to practise  

• We support the proposed grounds for action that would enable the GMC to investigate and take action where there is concern about a regulated professional’s fitness to practise.
• However, we do not support proposals for either the GMC or the PSA to have a right of appeal against decisions made by a fitness to practise panel. These provisions are inconsistent with the conclusions of previous reviews.