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GPs
Working Abroad:
How to Keep a UK’s GMC License to Practice
If
you are working abroad for more than a year you
could be asked to give up your UK GMC license to practice in
the UK,
and worse still you would lose your position on the NHS GP performers'
list unless you followed
the
rules below. Alas, as you go to the bottom of this blog changes in 2018 could make it more difficult, despite
various
NHS announcements
to encourge doctors to come home or come to the UK.
You may be aware that that overseas
practice, that means anywhere
where there is no UK NHS, is seen by some as a career break, which of
course is
nonsense as you are learning more than staying at home. This xenophobic
view,
that anything outside the NHS is beyond the pale, has coloured RCGP and
CoGPED
thinking. Even the Channel Islands and all British Overseas Territories
are
regarded as foreign by these institutions. The
GMC has been much more pragmatic, but we have to
worry about the interpretation
by RCGP and local health authorities. Bureaucrats look for
“rules”
from RCGP CoGPED
There are two linked issues. You
need to stay on the performers’ list so
you can go back into general practice on return to the UK.
Then you need to be
revalidated by the GMC to continue to have a licence to practice in the
UK.
The performers’ list requires that you work one day a year in
the UK as a GP and
do an annual appraisal, and being revalidated requires five appraisals
the last
few up to the new required standard. Various
localities may
attempt apply longer UK working rules incorrectly asserting
that recency of practice rules must be achieved by UK NHS practice
only.
When working abroad you do not want to burn your bridges, and need to
be able
to come back to the UK without having to retrain in an
expensive onesize-fits-all manner. Another
reason to keep a UK license is that that foreign registration
authorities and employers may not favour the GMC tag line
“registered, not
licensed to practice” when looking you up on the GMC
web site. The GMC is quite phlegmatic about giving up and
regaining the license to practice, and believes doctors should not be
fearful of doing so. I suspect the GMC fears being seen to
take
on the role of licensing doctors to practice overseas, but that
licensing is always the responsbility of
jurisdictions of the host country.
The GMC is not involved in
the performers' lists whose management is fragmented across the UK, so
we do we know
what the
retraining rules to get back onto GP performers' list.
The
main risk is coming off the performers lists with each area inventing
its own rules.
Retraining is a nonsense concept for those working
in primary care almost anywhere as so much is based on British
practice, espcially if working in Australia or New Zealand.
The
suggestion of retraining implies that you are not in contact with home,
that the jet aircraft, let alone the internet have not
been invented. Yes, at one time keeping
in contact with Blighty when overseas required letter, telegraph and
steamer ships.
To
remain on the performers' list one has to do one session
a year in UK. ALL
OTHER RULES have no basis. Even that one
session rule does
not seemed to be based on anything, for the original legislation, in
PCTs days,
referred to GPs being connected to an area, so perhaps living in PCT
area was
enough. It was
designed to pin
responsibility on one PCT to check that you had an appraisal. There are reasonable
expectations regarding
currency of practice set at 40 sessions a year for those working in
England and
Wales, but those rules do not state that the currency of work, those 40
sessions, have to be in the UK. You
can
have an appraisal based on one session in the UK a year. Do not let anyone tell you
that you have to
work 40 sessions a year in the UK.
Most
GPS abroad are working much more than that. NASGP
has some info
If
you have given up your UK license to practice, to get it
back, the retraining needed is here https://gprecruitment.hee.nhs.uk/Induction-Refresher
The RCGP has a blanket rule banning the use of the easier
sensible
portfolio route if you have been abroad more than five years no matter
where you have worked. This is at odds with
with GMC and GP Recruitment expectations of flexibility
according to needs. Beware of this trap.
www.rcgp.org.uk/training-exams/practice/the-induction-and-refresher-scheme-portfolio-route.aspx If
you have been abroad less than five years, and may yet come back to the
UK, do the portfolio route, much of which can be done abroad,
and
get back your license to practice and place on the performers list,
then keep up your license with regular appraisals.
I had
been working almost full
time overseas for seven
years, and was back in the UK regularly. I was
revalidated
after six years, and have my licence to practice
in the
UK for another five years. I am working again in London as if I never
left. I gained useful
experience working
overseas for UK practice, and like to think, as does my appraiser, that
my
overseas experience contributed to NHS practice. This may not work now
for such long spells now. Changes in May 2018
(see last
update below) means the GMC is expecting the data to
be UK
based, and the doctor to be working mainly in the UK . This
is a
huge backwards step, and I am puzzled that the GMC has taken this step,
which is not in line with GMCs earlier advice.
The key
is to stay on the performers list and continue with your
UK NHS appraisals until you have decided you are never going back to
the UK; then
you can give up appraisals and stop paying the GMC fee. Work in UK one
day a year.
Appraisals are good for you, and doing them
makes overseas CPD
requirements a
doddle.
Here are my
suggestions
- Do
not
voluntarily give up your license to practice when you have decided to
work abroad.
We do not know the potential difficulty in getting the
license back on your return but the main stumbling block is getting back back onto the preformers' list. Any
bureaucrat will find it is safer to
say no and interpret rules and opinions they see from any source
strictly, requiring retraining of some sort on return. It is
a huge risk giving up one’s license (hewnce place o nthe performers; list) Don’t, unless
never coming back.
- Health
Authorities do not need to know your future plans or where you plan to
work other than you do plan to do locums in your area so need to be on
the performers’ list. Stay on the list.
- When
resigning from your
partnership make sure you transfer from provider to performer on the
National GP performers' list. Under no
circumstances resign from the performers' list altogether.
You need to be on it to have an NHS GP appraisal and GMC responsible
officer. Some doctors have been told they MUST
resign. Do not resign
- Keep
up
your appraisals when working abroad. This is
essential. Appraisals are good for you anyway and make all
other country's CPD requirements very easy indeed. Other countries CPD
systems are more basic and can credit points on those from
your NHS
appraisal. You can add overseas data your appraisal folder,
or
clarity.co.uk profile. Alas since May 2018 the GMC advice is
that
the majority of this data has to come from UK practice, but this does not
seem active. This would make long
term working overseas working more problematic and prohibit overseas supersepcialists working in the UK.
- Make sure
you point out how up to date and in contact with UK practice you are
within the appraiasal folder .
- Check
with your appraiser that they
are happy with this; most will be delighted to have something
different. The data you collect will be from your overseas
work. You might have to pay for your appraisal
yourself. In your appraisal you need to outline how you are
keeping with UK practice, and how you new knowledge will be of use on
returning to the UK. You
can find other appraisers. InternationalSOS and others have their
appraisal system that will keep you licensed but may not keep you on
the performers’ list.
- When
you go
back to see your family every year, do a short locum, a few
days,
perhaps you do this at your old practice (charge them very little!) and
while there you can also have your appraisal in the UK. Zoom. Teams is useful
as well to do this, or split the appraisal between those and person to
person. Just one day's UK GP practice working (I would do more) and appraisal
keeps you on the performer's list. Revalidation follows on in the
normal way. Keep up with your appraisals at all
costs.
- The
other
expense is MDU/MPS with needs to be kept in place. Both have mechanisms very low insurance costs
for this situation. You do not need to keep up the full subs. Cheaper
now that NHS Indemnity for GPs has started (CNSGP).
December 2015
The
GMC in its Advice to local
GMC Responsible Officers fitted in with this line.
Its
statement below emphasises the
importance that the appraisal evidence and data is relevant for UK
practice;
which is quite easily done. It asked
ROs to consider the proportion of the appraisals that is
relevant to UK practice:
GMC Guidance for Responsible
officers: .
“2.3.2
Information from overseas practice or practice that does not require a
licence
Doctors may
practise in settings where they do not require a UK licence –
for instance, they may work abroad, or they may undertake
specific functions in the UK that do not legally require a
licence to practise.
Where this
is the case, it is at your (RO) discretion whether you consider
supporting information from these practice settings in making your
judgement. You should consider whether such information is material in
your evaluation of their fitness to practise, taking account of whether
it is demonstrably relevant to the doctor’s licensed UK
practice and the proportion of the doctor’s supporting
information that it represents.”
Beware
that SOME appraisal
teams in parts of England had been reading that to mean the proportion
of actual data
(360, complaints, PUNS,DENS, audits etc) has to come from the UK
practice,
and that would even exclude all overseas courses, even those with
international accreditation (ALS, ALSO etc). That
was quite incorrect (see below)
That interpretation would mean all doctors having to
work three
months a year in the UK to get all the required data; thus excluding
the
regular overseas returning super-specialists and most overseas
working. Forcing
months of UK work would be at odds with requirement only to work one
day a year
in the UK to remain on the performers' list.
May 2018
The guidance to Regional Officers
https://tinyurl.com/y85usps7
changes matters considerably, although may still be wriggle
room if you are working overseas.
The wording is now quite different from the guidance above.
"We (GMC)
expect doctors to collect their supporting information from the
practice that they undertake in the UK, unless there are exceptional
circumstances. For example a doctor in the military who is stationed
overseas.
Only in
exceptional circumstances would a doctor with supporting information
drawn wholly or substantively overseas from practice be able to
maintain their UK licence to practise.
If a doctor
is working overseas only sporadically, as well as undertaking UK
practice, there is no reason why they can’t collect and
reflect on some evidence from that practice as part of their appraisal.
You can use
your judgement to decide whether or not to accept supporting
information from practice that does not require a UK licence.
You may wish
to consider:
- the relevance of the supporting
information to the doctor’s licensed UK practice
- what proportion of the doctor’s
supporting information it represents
- whether it is material to your evaluation of
their fitness to practise.
If you (RO)
decide the supporting information from overseas practice is
not relevant, you should discuss with the doctor what alternative
information they need to provide."
The GMC guidance still make no concessions for
those working in British Overseas Territories.
It seems it may be possble to negotiate the R.O.
If you have data from UK practice to use that is relatively
recent, things may still be OK. However the default position
of
any officer, fearing being blamed for errors, will be to be
restrictive and offer no leaway.
Update September 2018
Registering and doing a few sessions with UK remote GP services such as
GP AT
HAND or Babylon
(there are new competitors entering this market) where you offer on
line consultations to UK patients, may convince
all that you never left UK practice. Location
in a different time zone may even help as you could offer out of hours
services. No doubt you will need UK indemnity.
Update
July 2017
It
seems from the feedback I have had that some regional officers and
appraising groups have been muddying the waters by applying various
other rules outside GMC requirements. GMC regional officers have no
role in maintaining the performers' list. The GMC has
recognised this meddlesome trend and in
the publication Taking
Revalidation Forward the GMC has the following
statement in Sir Kieth Pearsons recommendations (Appendix B)
8
The GMC should continue its work with partners to update guidance on
the supporting information required for appraisal for revalidation to
make clear what is mandatory (and why), what is sufficient, and where
flexibility exists. They should also ensure consistency and
compatibility across different sources of guidance.
9
Responsible officers should
make sure that the revalidation process for individual doctors is not
used to achieve local objectives that are not part of the requirements
specified by the GMC.
GMC Policy
Change?
The
GMC need not encourage GP to give up a license to
practice, which always means giving up a place on the performers'
list....the latter is far too risky. My
view is that the GMC should turn about, and further faciliate
GPs
gaining
experience
abroad, and then enable doctors to come back to UK
with ease,
providing doctors have kept up their appriasals. This May
2018 GMC has gone
backwards making it more difficult for GPs to return to
UK practice from overseas. I suspect this is due to lobbying
from
the Medical Education Industry here. This policy conflicts
with
statments made in the media: Guardain
encourage overseas doctors to come home.
2018
Goverment announced it will ease red tape for
Australians GPs coming to UK, It would be
odd if it is made easier for an Australian GP to come UK over than for
a UK trained GP to return!
Abolish
the Performers' lists.
The NHS has no place as an employer in licensing doctors as General
Practitioners,
which in effect is what the performers’ lists do. The role of registration
and definition of a specialist is properly carried
out by the GMC. No
other doctor group
has to undergo a double registration process, GMC and then also NHS. The performers' list is an
anachronism, a left
over from before there was GP training, let alone MRCGP. The
GMC should take over and abolish the
performers’ lists by registering GPs as specialists; catching
up
with most countries. GPs for example are registered as specialists in
Australia, so no need for a performers' list there. This is
being attempted, but is being delayed after first mooted in 2018.
https://fitnesstopractisenews.co.uk/specialist-status-for-gps-delayed/ It
not clear if this registration will remove the performer's list.
I fear GPs will still have to face double registration unlike all
other specialists.
Gerry
Bulger December 2023
Message
me at https://bulger.co.uk/message.htm
- Australia experience
- Indonesia
2010
- Thailand
2011
- Northern
Territories 2011
Learning points for doctors to australia
is here at
https://www.gerardbulger.com.au/doctors
To
get a password for that email me here
https://bulger.co.uk/message.htm
Dr
Gerard Bulger BSc MBBS DCH FRACGP FRCGP
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