Revalidation of doctors, or how to spot the bad apples

Wouldn’t it be great if we could spot the bad apples before we consume them? Or even better: before they become bad? In recent years medical regulators around the world have been exploring ways to identify doctors who are performing poorly.

In the UK all apples are tested once a year via a process called revalidation. But some have said it will not detect poor doctors; its main purpose is to gain patients’ trust. Others say it is meant to demonstrate what good apples look like. But one thing is for sure: Revalidation is labour-intensive and expensive.

“There is indeed an additional time cost,” said GP Dr Paresh Dawda in Australian Family Physican. “The appraisal meeting was usually 3 hours in length, and on average it took another 5 or 6 hours to collate the evidence and complete the forms, which is in keeping with an average of 9 hours found in the revalidation pilots.”

Then there are the training, time and wages of the appraisers, usually doctors too, the administrative staff, extra regulation, log books, documents, IT… Revalidation has become an enormous enterprise, costing £97M ($186M) a year, mainly because of added pressures on doctors’ time.

It seems logical that, before a country embarks on an operation like this, the problem it is trying to solve has been defined and the solution is effective.

So what’s the problem?

According to the Medical Board of Australia, evidence from Canada shows that 1.5% of doctors are not good enough. The Board has translated this figure to Australia, and thinks that over 1,350 doctors could be performing unsatisfactorily. Other research indicates that just 3% of doctors are the source of 49% of complaints.

“Where is the evidence that further regulation is needed?

Several safety mechanisms are already in place: At the moment Australian doctors must meet the Medical Board’s mandatory registration standards, including for recency of practice and continuing professional development. Doctors can be subjected to random compliance audits.

Although a majority of Australian doctors seems to support competence checks, there are serious questions about the UK-style revalidation process.

Revalidation screenshot
Screenshot: Example of questions UK doctors have to answer during the revalidation process.

AMA(WA)’s GP Dr Steve Wilson in this blog post: “Where is the evidence that further regulation is needed, which will be preventative and ultimately beneficial to the profession and the community?”

“Will it address those who fail to practise to agreed levels, and is that a sign of ‘impairment’ or more about personal style, lack of time, adequate remuneration, or lack of care, training, experience, sheer demand and workforce numbers?”

At a conference in 2013 Medical Board of Australia Chair, Dr Flynn admitted that ‘the problem that a revalidation-style system would help solve was not yet defined’.

But Dr Flynn questioned the current continuous professional education system: “Can you assure me that everyone who has done your CPD program is actually competent and practising at a reasonable standard? (…) My sense is that, for most CPD programs, they don’t do that, or at least, not to a high enough level of certainty.”

After meeting Dr Flynn in 2013, the RACGP stated in Australian Doctor magazine: “The meeting provided an opportunity for the college to discuss the strength of our current QI & CPD program, and the necessity of adding yet another mechanism to identify underperforming doctors, when processes are already in place – such as the medical boards, health quality and complaints boards and indemnity insurers.”

What’s the Medical Board up to?

“We started a conversation about revalidation in Australia in 2012,” said Dr Joanna Flynn in last week’s media release, “as part of our commitment to making sure doctors in Australia maintain the skills to provide safe and ethical care to patients throughout their working lives.”

The board has asked the University of Plymouth to answer some questions on revalidation. At first glance this seems a sensible approach.

Dr Flynn: “We have commissioned this research to find out what is working well internationally, what is in place in comparable health care systems, and what principles the Board should consider in developing revalidation in Australia. (…) this research will help make sure that the decisions the Board makes in future about revalidation are effective, evidence-based and practical.”

The aim of the project is to:

  • establish the existing evidence base for the validity of revalidation or similar in countries comparable to Australia
  • identify best practice and any gaps in knowledge for revalidation processes
  • establish the validity evidence for revalidation’s effectiveness in supporting safe practice
  • develop a range of models for the Australian context for the Board to consider.

It seems to me the research questions are broad and several steps are taken at once. For example: ‘Establishing the evidence for revalidation’ and ‘developing a range of revalidation models’ are entirely separate processes.

It appears the Medical Board has already made up its mind. The research findings will be considered by the Board in the second half of 2015. I am certainly looking forward to the results and conclusions, as well details about cost and setup of the study.

The Camera revalidation research website of the University of Plymouth doesn’t give any answers away: “The research team is currently undertaking an ambitious programme of research involving three interlinking studies to explore and understand revalidation in all its complexity.”

Putting the cart before the horse

The question is of course: Is revalidation the right solution? Are there other options? One could argue that this should have been considered before spending tax dollars on an overseas research project.

Professor Breen, from the Department of Forensic Medicine at the Monash University in Melbourne, said in the Medical Journal of Australia: “There is little to support the idea of simply transposing the UK system to Australia. Despite some local failures of medical regulation and hospital governance, there has been no widespread loss of faith of the community either in its doctors or in the regulatory system.”

“Is there a problem with medical registration in Australia that needs attention, and, if so, what should be done to fix the problem?

“The Medical Board of Australia would be wiser to start afresh by asking and answering two questions — namely, is there a problem with medical registration in Australia that needs attention, and, if so, what should be done to fix the problem?

“The medical profession in the UK appears to have accepted revalidation, albeit reluctantly, as representing the price to be paid for maintaining the existence of the GMC and for regaining public trust after a series of regulatory failures.”

“It has been claimed that revalidation will not reliably detect poorly performing doctors, and many commentators have pointed out that revalidation would not have identified Dr Harold Shipman.”

Immediate past president of the AMA, GP Dr Steve Hambleton had second thoughts too. In MJA Insight he said: “We need to make sure we maintain our currency and continue to improve health outcomes, but in terms of value for money, making everybody go through a 5-yearly process of 360-degree evaluation is not needed in the Australian health system.”

Both Professor Breen and Dr Hambleton suggested there are better ways to deal with the bad apples. Database analysis could be one solution. Other options are targeted revalidation and a revamp of the existing CPD program and accreditation. Some have argued that the focus should be on the workplace, not just on health professionals.

Journalist Paul Smith from Australian Doctor magazine was, as usual, spot on when he wrote: “(Doctors) may argue that targeted revalidation has greater merit than what they may see as carpet-bombing the entire profession.”

Red-tape stress

“Recently I cried at work,” posted Dr Adrienne Garner on the BMA blog. “Why? Because the evening before I’d been notified that my appraisal, submitted after hours of work, had been unsubmitted by my appraiser as it was ‘not sufficient for revalidation.”

“I was gutted. My mind churned with a mixture of thoughts ranging from anger to fear, through frustration and disappointment. Sleep had been impossible.”

“Under revalidation appraisals became a form of policing the profession.

Many studies show that doctors are more likely to experience psychological distress and suicidal thoughts than the general community, and there is a high rate of burnout. Pastoral care and self-reflection are important. But when they are part of a policed regulatory framework, they become a stressor in itself – which defeats the purpose.

Former Coventry GP Dr Gaurev Tewary, now working in Australia, posted on a social media platform: “I was an appraiser in the UK. My overall impression is this: Appraisals used to be fun and interesting and mainly pastoral. You did them to help people and I enjoyed supporting the profession. Under revalidation it became a form of policing the profession.”

About 5,000 doctors a year are considering to leave the UK, and many come to Australia. Bureaucracy is one of the reasons they emigrate. We must become better at dealing with bad apples, but healthcare is already a highly regulated industry and the last thing we need here in Australia is more regulation, red tape and stressed-out doctors.

I hope the Medical Board will work with the colleges and the AMA to explore better options.


8 thoughts on “Revalidation of doctors, or how to spot the bad apples

  • The average doctor seems to be performing at higher levels of competence, patient satisfaction, and efficiency, than the average bureaucrat.

    It seems to me that people vote with their feet. Patients in the UK are allocated to GPs and there is less choice. Here, patients can change doctor easily. Consultation times are generally longer as well.

    I feel a 4 year freeze on AHPRA registration fees and funding might concentrate their minds on the issues of determining their core business and attending to that.


  • These thoughts from a UK colleague:

    Revalidation – it is a very very very expensive notion to regulate doctors. Its aim was post Shipman to ensure all doctors were good boys and girls. But as we all know it is a blunt tool to find the criminal. Playing Cluedo would be quicker.

    So it is about state control through regulation dressed upon the notion that a) miscreants will be uncovered and b) tardy doctors will get caught out as not being up to date. That will never work.


    We have an Assistant Medical Director who is the responsible officer [RO]. Such a role accrues an additional premium to the RO in salary as well as converting all their management time to this role.
    There is a back office staff to be recruited as well – about 3 WTE secretarial types
    Then the software costs and maintenance. We are on our second system now – God knows the cost
    Then you have to have the revalidators and those who train them.
    Then the time of revalidation is all ticketyboo is about 2 hours. So that is x2 two hours consultant time – two for the victim and two for the inquisitor. Repeat per each consultant in the revalidation cycle.

    So 1-5 are additional costs that are permanent and so added to the management costs. They do not come from anywhere. Then there is the cost of the time the doctors have filling in the paperwork – if the system does not fall over or is under maintenance.

    So for the cost – what is the purpose that can be proven by evidence to have a beneficial effect?

    Answer – none. I reckon it costs in the region of several £tens of thousands a year per hospital to run; but there is no defined reason nor benefit. If averting criminality is the reason [post Shipman recommendation] it has failed.

    Of course the proponents will say it has worked as there has not been a Shipman thereafter. – The Hawthorne Effect. The incidence of Shipman like activity is so rare that within many revalidation cycles it will be undetectable as it does not exist.

    The correct benefit is to ensure doctors are up to date against training standards, education and issued guidance(s). This can best be served via the traditional annual appraisal CME CPD system that does not require an additional extra expensive meaningless revalidation process.

    It is a stressful expensive hobby for managers to tick a box.

    It detracts from patient care as doctors spend more time jumping through hoops (dont forget Aus doctors already complete CPD every triennium and practice revalidation and clinical privileges credentialling plus mandatory police checks)

    It lacks evidence base or proof of benefit


  • Also need to demonstrate evidence of harm.

    The UK North Staffs and Bristol Infirmary incidents were more about system failures than individual clinicians (indeed, the former incidents had more to do with managerial targets than clinical skills)

    Many people suggest that psychopaths like mass murderer Harold Shipman would not be detected by revalidation…in fact, such aberrant personalities are adept at concealment…he may well have been one of the appraisers!

    If we need standards (and I am all in favour of improving quality care…after all, 50% of doctors are below average – think about it), then we need to focus on

    systems to embed lifelong learning
    encourage audit and reporting of poor practice (which may be better directed at systems than individuals)
    ensure same standards apply to other professionals. I would start with politicians, health bureacurats and eliminate the practitioners of unproven woo …


  • At this point in time, AHPRA has 3 Professional groups – Osteopathy, Chiropractic, Chinese Herbal Medicine which have NO evidence base to support their craft. Some of these groups are bogus and indeed are vocal supporters of anti-vaccination (or anti-western medicine)..
    How is it AHPRA can turn a blind eye to this, whilst targeting medical profession? Whilst AHPRA continue to do this, then they have a credibility problem.

    Liked by 1 person

  • There are countries – surprise surprise – with nothing like re-validation, re-certification, re-accreditation… e.g. Germany, and I cannot see a real difference neither in quality nor in the degree of satisfaction amongst doctors and patients. Putting this pressure on doctors is not only a waste of money and resources but also pushes away “good doctors” from the actual job. It´s a lose-lose situation…


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