The proposed introduction by the General Medical Council (GMC) of compulsory detailed assessment of doctors every five years, perhaps starting in November this year, is difficult for those not regularly working in clinical medicine to achieve. This revalidation will be necessary to maintain a licence to practise, and hence prescribe and administer prescription only medicines (POMS), which is the core of being a medical practitioner. Secondly, the GMC was obliged to follow European law on age discrimination, and this year introduced a £390 fee (now £410) for retired doctors to remain on the medical register, which is a blow to pensioners without medical income.
Compulsory revalidation in the form of evidence of continuing professional development with multi-source feedback, evidence of competence, etc., was proposed by the Chief Medical Officer (CMO), Sir Liam Donaldson (Medical Revalidation: principles and next steps. 2008), as a not wholly appropriate response to the Shipman enquiry. Nevertheless, revalidation will help to reassure patients that their usual doctor, whether practising in the NHS or privately, is competent. The CMO specifically recommended that a working party be set up to consider whether retired doctors should be allowed to prescribe from a restricted list of drugs. We as passengers would think this appropriate for active aircrews, but is it appropriate for retired doctors?
There is, for instance, precious little evidence that retired doctors have ever caused injury. So limited revalidation of limited professional activity would make sense. Could not a licence be given for retired doctors to prescribe from a limited list? The pharmacist can check from the GMC number of the practitioner on the script. Such prescriptions would be private, if the doctor was not working in an NHS institution.
But what about those retired doctors who wish to help patients in local emergencies, say at the roadside or in an aeroplane, or to prescribe safe and often continuing medicines for friends during a pandemic influenza outbreak, or as temporary appointments here and abroad undertaking philanthropic teaching or service? How will they be covered legally and for insurance if they are not licensed? Very few other countries impose blanket restrictions. We know we are wanted for helping out in pandemic flu as emergency legislation will cover us, but what about everything else? Will retired doctors be able to sit on panels, write legal reports, set medical examination questions, examine and teach undergraduates and postgraduates, or continue their part-time private practice? Many are worried about this potential abrupt severance of all their medical activities after a long career.
The licence fee has been an unexpected and painful blow to medical practitioners, for usually there is no medical income earned to offset the tax. A challenge by the BMA to its introduction was lost in the High Court in 2008. Could there be a reduced fee, perhaps based on medical income?
The Revalidation Working Party of the Department of Health, and the Royal Colleges have yet to complete their detailed and difficult work on methods for revalidation for practising doctors. We urge the GMC to put forward either rules for exemption for retired doctors, or at least a simpler form of revalidation. We suggest that retired doctors who wish to prescribe could be monitored through pharmacies.
We believe that if these proposed measures are compulsorily applied to retired doctors, then they will further disillusion the profession, and will reduce their ability to continue to help in treatment and education, but will not reduce errors or the standards of medicine that throughout their careers they have upheld. It will also be difficult to revalidate doctors who work outside clinical medicine, such as in management, industry or public health, without special arrangements that could be similarly tailored to retired doctors. Rumour has it that the timetable set out by the above Revalidation Working Party has slipped, so there is time for us to make our strong views on this known before it is too late.
What do others think?