The Medical Profession (Miscellaneous Amendments) Order 2008

Introduction

We are supportive of the proposals set out in this consultation.

Specific comments

Question 1: Do you support the transferring of the statutory powers of the GMC Education Committee to the GMC from January 2009 when the new GMC Council will be established?

We are supportive of the transfer of the statutory powers of the GMC Education Committee to the GMC, however would caution that the expertise of the current committee members in this area must not be lost.

Question 2: Do you agree with the amendments to Part 3A of the Medical Act 1983, which will enable the GMC to begin work around revalidation, including issuing licences to practise in 2009?

We support the amendments made to Part 3A of the Medical Act 1983, which allows work to begin around revalidation and the issuing of licenses to practise.  We welcome the pilot studies that the GMC is running in relation to revalidation, and that the outcomes will be given careful consideration with possible updates to Part 3A of the Medical Act, if deemed necessary.

We would suggest that further information is provided on section 16 (c) as to how the decision of whether or not the local systems are robust enough will be made and by whom, is made.

Question 3: Do you agree with the amendment to the 2003 Order, which will reinstate the GMC’s previous power to allow late entry onto the Specialist Register in certain circumstances?

We are supportive of the proposal to reinstate the GMC’s power to allow late entry onto the Specialist Register in certain circumstances.  The change is consistent and will help those consultants who did not take advantage of the previous arrangements.

Equality Screening

We would suggest that there may be need for clarification in this area, in relation to consultants and Article 14(4), if the latter will apply to doctors not qualifying or being appointed to consultant posts in the UK.  There are also differences with doctors that have qualified or been appointed to consultant posts in the EU.

Comments on the draft order

We recognise that, being primary legislation, this is “high level” and that the detail will be set out in secondary legislation and guidance.  We would expect to be consulted on the secondary legislation and guidance before it is finalised.