THE ROLE OF THE GENERAL MEDICAL COUNCIL (GMC)

  1.  The GMC welcomes the opportunity to assist the Health Select Committee in its inquiry into patient and public involvement in the NHS. This submission provides information on the following:

(a)  Our statutory role as the regulator for medical practitioners registered in the United Kingdom.

(b)  Information on involvement of patients and the public in our work.

(c)  Information on how we further plan to engage with patients and the public.

  2.  The GMC's role in the regulation of doctors is defined in our statutory and charitable purposes: to protect, promote and maintain the health and safety of the public by ensuring proper standards in the practice of medicine. The law gives us four main functions under the Medical Act 1983.

(a)  Keeping up-to-date registers of qualified doctors.

(b)  Fostering good medical practice.

(c)  Promoting high standards of medical education.

(d)  Dealing firmly and fairly with doctors whose fitness to practise is in doubt.

  3.  Although we are not in a position to respond to all the issues raised in the Committee's terms of reference, this submission provides background to the key elements of our own PPI activities and the principles which underpin our work in this area. The challenge we face in involving patients and the public in the work of a regulatory body is somewhat different to that faced by a NHS body or commissioner of healthcare services who have a need to involve front line service users. However, the involvement of patients and the public in the development of regulation is critical if regulation is to be both effective, proportional and retain the confidence of the public. The lessons we have learnt through our experiences in involving patients and the public may be of interest to the Committee and with this in mind we have made a number of general comments about the issues raised by the Inquiry.

OUR EXPERIENCES OF PATIENT AND PUBLIC INVOLVEMENT

  4.  Effective engagement leads to better informed and therefore better designed policies and outcomes. However, good policies alone are not enough. For systems of healthcare and the regulation of healthcare professionals to be effective, they must command the confidence and support of patients and the public. Although surveys show that confidence in medical regulation remains high, only by engaging effectively with the public and demonstrating transparency and accountability can confidence be maintained in the longer term. [22]

  5.  Over recent years we have been striving to increase the level of patient and public engagement throughout our work. These initiatives have been wide ranging and offer opportunities for citizens, across the four nations of the UK, to input to our work. We have sought to take an innovative and proactive approach, recognising that PPI is relatively new in the field of healthcare regulation. Some of the examples of our work in this area are described below. Annex A also provides further examples of our activities during 2006.

Governance structures

  6.  In our recent response to the Department of Health's consultation on the future of healthcare professional regulation we proposed a package of reforms which we believe, if implemented, would help to deliver improved patient safety and can command confidence in medical regulation. At the heart of these proposals are changes in the governance of the GMC. We have argued that for the GMC to command the confidence and support of all interest groups, it is critical that not only must we remain independent from the government as the dominant provider of healthcare, but also be independent of dominance by any single group. To this end we have proposed changing the composition of our Council, removing the current medical majority and having an equal representation of lay and professional members. Membership of the new Council would consist of representatives from all our key interest groups. Our response to the Department of Health's consultation also confirms our long standing belief that confidence in the GMC, and medical regulation as a whole, would be enhanced if we were to be accountable to Parliament.

Fitness to practise

  7.  We have, over recent years, enhanced lay input and decision making into our disciplinary proceedings. No fitness to practise decision is made without lay involvement. In those cases that culminate in a hearing, the fitness to practise panel will normally comprise three to five panellists. In addition to the chairman, who may be medical or non-medical, there must be at least one medical and one non-medical panellist on each panel.

Citizens' jury

  8.  In November 2005, we held a Citizens' Jury to consider a range of standards and ethics issues relevant to children and young people. This was the first such use of this approach by a UK health or social care regulator. The Jury, comprising 15 individuals from a cross-section of society, met for four days in London and took "evidence" from a range of "witnesses", engaging with children's charities, the police, lawyers, social workers, nurses, doctors, child protection experts and children themselves. The Jury provided valuable insight into how the various competing priorities, such as child protection and confidentiality, should be assessed. The Jury's report, available at http://www.gmc-uk.org/guidance/Jury—Report—19—Jan—2006.pdf, has been used in the development of our guidance on treatment for children. Taking this work forward, we have now issued a consultation on the draft guidance.

Development of draft guidance on children and young people

  9.  In November 2006 we launched a consultation on new draft guidance for doctors about their role and responsibilities towards children and young people. We are keen to ensure that the consultation process is accessible to all, in particular children and young people. As such we have developed a website designed specially for children who wish to take part (www.gmc-uk.org/children). In addition to this, in partnership with the Teenage Cancer Trust and Rainbow Trust Children's Charity, we have launched a poster competition asking under 18s to submit a design which will be used for the front cover of the new guidance booklet. It is hoped that this consultation will successfully capture the opinions of all those involved in the treatment of children, including young people themselves.

Consultation on good medical practice

  10.  The GMC has undertaken a wide-ranging and innovative two year consultation as part of the review of Good Medical Practice, our core guidance to doctors which sets out the principles and values upon which good practice is founded. The consultation process included research on public attitudes, a large scale written consultation and a series of open public meetings. These meetings took place across the UK and used a series of fictional scenarios to help us investigate and assess public opinion. The resulting guidance, the changes to which include an emphasis on the importance of the doctor-patient partnership, has been well received. A copy of the guidance can be found at http://www.gmc-uk.org/guidance/good—medical—practice.

  11.  To raise awareness of the new edition of the guidance we also launched a national poster campaign. The aim of this campaign is to encourage employers and GP practices to display the posters in their waiting rooms and public areas so that the public can be informed about doctors' commitment to the principles of good practice in a relevant and accessible way. It will also highlight to doctors that the guidance has been updated and that they need to be aware of the professional obligations contained in it.

Development of the patient and public reference group

  12.  In 1999 we established our Patient and Public Reference Group which compromises representatives from patient and consumer organisations. The Group provides us with input from a patient perspective on the development of our policies. In 2006 we set out to add to the membership of the Group the voices of individual members of the public. The recruitment was open to all members of the public and was designed to encourage applications from those who had not previously been involved in healthcare or regulation. Annex B includes a description of the recruitment specification used as part of this process.

  13.  As a UK wide regulator, the GMC is committed to ensuring that we engage with patients and the public in all four countries of the United Kingdom. An example of this commitment is the development of country-specific patient leaflets and complaints forms to ensure that information provided to patients and their representatives take account of differing structures and complaints processes in the NHS across the UK.

Surveys

  14.  Since 2005 we have commissioned regular surveys designed to ascertain and understand public attitudes towards a range of issues facing the GMC and regulation. The results of these surveys have been fed into our policy development to help ensure that medical regulation meets the needs of society.

Joint health and social care regulators information leaflet

  15.  We recognise the importance of the patient and publics having access to clear and reliable information. Working with the 12 partner organisations, a public information leaflet has been developed and published. The leaflet, which was developed with the assistance of PPI Forum members, aims to provide the patient and publics with an easy to read guide to the work of health and social care regulators, how this impacts upon the patient's experience and importantly how to contact the appropriate organisation. A copy of the leaflet, which is also available in 12 languages, can be found at http://www.gmc-uk.org/publications/regulator.

Readers' panel

  16.  We have recently established a reader's panel to work with us on improving the way in which we communicate with patients and the public. The role of the Panel, which is drawn from a public recruitment exercise, is to give feedback on our communications so we can ensure that the information we are providing is accessible and easy to understand.

FUTURE PATIENT AND PUBLIC INVOLVEMENT DEVELOPMENTS

  17.  The work we have undertaken in recent years has significantly increased the patient and public input in the development of medical regulation. Going forward we are eager to build upon this progress. As part of this we are currently exploring the establishment of a Patient Panel, drawing upon the experiences of others such as Ofcom, National Institute of Clinical Excellence and Financial Services Authority. In developing our plans for such a scheme we are keen to investigate how local networks such as PPIFs as they currently are, and LINks in the future, might be involved, further assisting in bridging the national and local divide.

  18.  Mechanisms for improving the connections between organisations such as the GMC and patients and the public are very welcome and we look forward to the opportunity to work closely with the evolving system of local patient and public networks as it develops.

Hugh Simpson

General Medical Council

January 2007