M4 - Chief Operating Officer’s Report` - GMC · 2018-03-14 · Council meeting, 23 February 2017...

Council meeting, 23 February 2017

Agenda item: M4

Report title: Chief Operating Officer’s Report

Report by: Susan Goldsmith, Chief Operating Officer, [email protected], 020 7189 5124

Action: To consider

Executive summary This report provides an update on our operational performance and Council priorities including the following items: Matters arising from the Performance and Resources Board in January 2017:

Revision to Corporate Reporting in 2017.

IS plan for 2017.

Digital Media Strategy update.

UK Medical Education Database.

Other operational matters arising:

MPTS Leadership.

Welsh Language Standards update.

International Association of Medical Regulatory Authorities (IAMRA).

GMC Services International Ltd.

Recommendations Council is asked to consider the report (and Annex A, Annex B, Annex C and Annex D).

mailto:[email protected]

Council meeting, 23 February 2017 M4 – Chief Operating Officer’s report

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Issue

1 This report provides an update on our operational performance, Council priorities and other operational matters arising.

Operational KPIs

2 All operational key performance indicators, at Annex A, were met up to the end of December 2016 other than the exception set out below.

2016 year-end financial position

3 The year-end operational surplus is £3.4 million compared to a forecast surplus of £2.5 million and a budgeted surplus of £334k. The change in forecast surplus is principally due to additional operational efficiencies created throughout quarter four of 2016 such as handling more legal work in-house, the implementation of Rule 4 reports reducing costs more than forecast; as well as lower volume of performance assessments than expected. The surplus figure includes a pension top-up payment of £2.4m made in December.

4 Separately, the Change Programme was under budget by £1.65 million at the end of 2016, driven by factors including lower than expected redundancy costs; additional staff savings through staff leaving earlier than planned; and the contingency set aside in the budget not being required. Further detail can be found at Annex B

Council Priorities

5 As of December 2016, the majority of Council priority work has a green status other than the exception set out below. A summary of the position and more detail on exceptions is at Annex A.

Red – ‘Council priority 5: Credentialing’

The overall status for the credentialing project is red, due to progress currently being limited by available resource because of competing priorities such as the Standards for Curricula and Assessment Review, and the Flexibility of Training Review. The forecast for the next reporting period is amber, which reflects that plans are in place to secure the required resource level. Further information is available on page A21 of Annex A.

6 A number of activities have now completed within the planned timescales for delivery. These include key elements of the Change Programme, delivery of our Standards App, and Data Strategy projects. More detail at Annex A.


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Operational risk reporting

7 The GMC’s approach to risk in decision-making is outlined in Annex D along with the current Corporate Risk Register. We have closed two operational risks following the successful implementation of the EU Recognition of Professional Qualifications Directive. We have also closed the risk in relation to our response to the industrial action by doctors in training in England in 2016. We continue to lead on the review of Flexibility in Postgraduate Training as part of our response to this agenda. Our work in this area, and other issues arising in relation to training environments, are regularly monitored at a corporate level to ensure we respond appropriately.

Performance and Resources Board meeting updates

8 The Performance and Resources Board met on 24 January 2017 and:

a Agreed Revisions to Corporate Performance Reporting in 2017. The main purpose of the revisions is to provide Council and the Executive with more focused and relevant information about our corporate projects and Council priorities. This includes enhancing the reporting of progress to include full consideration of original business case and expected benefits, in addition to timeliness, and the improvement of exception reporting.

b Considered and approved the IS plan for 2017 that comprises of 104 projects from all areas of the business. The plan represents £5.1m of budgeted capital spend with major elements including our Digital Media Strategy; Standards App Phase 2; continued investment in Data Strategy; UK Medical Education Database (UKMED) and infrastructure projects to improve the security of our data and systems.

c Approved the year two plan for further developments on the Digital Media Strategy (DMS). This includes migrating and updating website content and a new website launch in Q3 2017. A high level plan for website delivery has been developed and new governance and reporting requirements agreed with PRB for ongoing monitoring.

d Considered the update on the delivery of the 2017 UK Medical Education Database (UKMED) programme including the updated terms of reference for external advisory groups to reflect a new ‘business-as-usual’ (BAU) operating model. In addition, the Board noted that data contributors agreed to the BAU model and re-signed data sharing agreements (DSAs). New agreements are being signed with medical royal colleges to include national exam data in the database from next year. In 2017 we will also undertake further work with healthcare workforce planners to understand the data needed to more fully understand how doctors move in and out of training.


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Other operational matters arising

MPTS new leadership update

9 Dame Caroline Swift has now taken up her position as Chair of the MPTS as of 1 January 2017. We have also appointed as interim Assistant Director of the MPTS (Lyndy Geddes) to support transition and maintain oversight of operational delivery. The process for a permanent appointment to lead the operational aspects of the MPTS will be completed by the end of Q2.

Welsh Standards Update

10 The Welsh Language Standards consultation, to which we responded in November 2016, has been paused to allow further analysis of responses. The Minister for Welsh Language has been advised that a new set of standards should be developed specifically for the professional regulatory bodies, which we welcome.

11 Although we await formal confirmation, we understand that these proposed standards would exclude at the outset most of the operational standards about which we had concerns in the original consultation and focus on more proportionate policy and service delivery standards which potentially have a positive impact on the uptake of Welsh.

12 The Minister’s announcement on 5 January 2016 stated that he will be reviewing the 2011 Welsh Language Measure, however this will not have an impact on the development and application of standards as the review will focus on the legislative framework within which the standards are applied. I have therefore postponed my planned meeting with the Welsh Language Commissioner until later in the year with the view that the process of drafting the new standards will be underway.

International Association of Medical Regulatory Authorities (IAMRA)

13 In September 2016, at the Members General Assembly of the IAMRA, I was successfully elected to the IAMRA Management Committee as the European Member-at-Large for a term of four years. In January 2017, I participated in a Strategic Planning Meeting of the 2016-2018 Management Committee, which set the ambitions and objectives for the Association over the next two years. Our continued involvement at this international level helps to ensure that the GMC continues to have a close involvement and relationship with the wider international regulatory community.

14 One of the key activities IAMRA will undertake in 2017 is the GMC hosting of the fourth IAMRA Symposium on ‘continued competency’ (known as revalidation in the UK) on 5-6 October 2017 in London. Planning is underway for the event, whose


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theme has been agreed as ‘Continued competence systems: measuring their value and impact’. We are expecting to host up to 100 delegates from medical regulatory authorities across the globe.

GMC Services International

15 We have completed the incorporation of GMC Services International (GMCSI) Limited as a trading subsidiary of the GMC as agreed at Council on 14 December 2016. Investment in the subsidiary will be overseen by the GMC Investment Sub-Committee. GMCSI is currently developing its business plan and an operational framework, which will formalise the operational relationship and cost sharing arrangements with the GMC.

16 Appointments to the GMCSI Board, including independent members, are currently being made. I, along with Paul Buckley, GMC Director of Strategy and Communications, will sit on the Board to ensure GMC executive oversight and management of operational dependencies between GMCSI and the wider organisation. Council members Michael Farthing and Steven Burnett will also sit on the Board with Jim McKillop acting as interim Independent Chair. We have initiated a process to recruit two Independent Board members. In April we will present to Council a full overview of the governance arrangements relating to GMCSI, including an Operating Framework governing the relationship and interface between GMCSI and the GMC.

M4 - Annex A Council Priority Report

Data accurate as of 24.01.2017

M4 – Chief Operating Officer’s Report


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Council Priorities Previous Period

Current period

Delivery Risk

Trend

Next period

1 Implementation of the Change Programme All items to are complete - Pensions, People: Redundancy, recruitment,

knowledge transfer and Accommodation and extension of new ways of working, GMC services are all complete.

G G N/A N/A

2 Taking forward legislative reform / the legislative programme arising from the Law Commissions’ report

All items on track: S60 Reforms; ISG Phase 3; Legislative Reform - Engage and influence key stakeholders to press for alternate routes for legislative reform including Section 60 Orders.

G G G

3 Understand the context in which doctors practise

All items on track or complete: The Implementation of Confidentiality Project is on track. Promoting Professionalism event programme in 2016; Hold Regional KIG Dinners in England in 2016; Organise and host UKAF meetings in Northern Ireland / Wales / Scotland; Standards App are all complete

G G G

4 Medical Licensing Assessment All items on track: Medical Licensing Assessment G G G

5 Revalidation review All items on track: Revalidation operations; Evaluation of Revalidation;

Skills & competency testing for doctors without a prescribed connection; Review of revalidation.

R G G

6 Respond to the Shape of Training review Most items on track: Credentialing (a lack of resources and competing

priorities means the current period has a red rating); Generic Professional Capabilities is on track.

G R A

7 Fairness and proportionality

All items on track: Interim Orders Tribunal Research (now reporting as green from amber due to resource being secured); Deliver the E&D strategy 2014-17; Differential Attainment – Research; Standards for Curricula and Assessment.

G G G

8 Supporting doctors, patients and relatives involved in fitness to practise investigations

All items on track: Monitor & TDA Information Sharing; Vulnerable Doctors project G G G

9 Communications strategy and engagement All items on track or complete: Digital media strategy on track.

Communications and Engagement Work 2016; Board Engagement through 2016 are complete

G G G

10 Develop the Register and deliver Data Strategy Phase 2

All items on track or complete: LRMP development is on track; DS1 Unstructured qualitative data; DS2 Common & core dashboard development; DS3 Sharing GMC data externally; DS4 Organisational approach to key data capture AR are complete.

G G G

11 Speeding up fitness to practise procedures All items on track: FtP Operations on track; Provisional Enquiries roll-out /

further piloting G G G


A1


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Key to RAG ratings

Progress

Cost

Resource

Overall RAG status

Green - Project on track compared with initial time scales Amber - Change to project time scales but without overall change to end deadline Red - Change to overall end deadline Complete / cancelled

Green - Project cost within 5% tolerance of original cost Amber – Project cost is under / over spending by between 5% - 10% Red – Project cost is under / over spending by more than 10% Complete / cancelled

Green – Relevant skillsets and FTE resource secured to deliver the project Amber – Relevant skillsets and FTE resource are not secured / being secured but this will not impact on the project delivery overall Red – Relevant skillsets and FTE resource are not secured / being secured but this will impact on the project delivery overall Complete / cancelled

Green – 3 greens or 2 greens + 1 amber Amber – 3 ambers or 1 green + 2 ambers Red – Any combination with a red for the progress or resource RAG or the cost RAG has an overspend of £50k or more Complete / cancelled

As part of continuous improvements to our reporting processes, we have recently made a change to the way we report on costs for projects. The usual criteria for reporting on project costs remain in place (as above) with a slight change to the reporting of overall status: • Where there is an overspend of £50k or more, this will change the overall RAG status to red. In addition, all Council priority and Change Programme projects will now be re-forecast on a monthly basis instead of quarterly. This approach will allow us to report more accurately on project costs, while highlighting only those areas which need genuine attention - a more proportionate and risk-based approach.



A2

Operational KPIs



# Area BAU Operational KPIs [monthly] Nov Dec RAG for

Next period

Commentary

1 R&R Decision on 95% of all registration applications within 3 months 98% 97% G On track

2 R&R Decision on 95% of all revalidation recommendations within 5 days 97% 96% G On track

3 R&R 90% of calls answered within 15 seconds 96% 93% G On track

4 E&S Respond to 90% of ethical/standards enquiries within 21 working days 97% NA G On track

E&S Respond to 90% of ethical/standards enquiries within 15 working days* NA 90% G On track

5 E&S 80% of enhanced monitoring concerns where action plan is being adhered to 93% 92% G On track

6 E&S 90% of visits completed in within agreed timescales 100% 100% G On track

7 FtP Conclude 90% of fitness to practise cases within 12 months 94% 94% G On track

8 FtP Conclude or refer 90% of cases at investigation stage within 6 months 91% 95% G On track

9 FtP Conclude or refer 95% of cases at the investigation stage within 12 months 95% 97% G On track

10 FtP Commence 100% of IC hearings within two months of referral 100% No cases due

G On track

11 MPTS Commence 90% of tribunal hearings within nine months of referral 90% 94% G On track

12 MPTS Commence 100% of IOP hearings within 3 weeks of referral 100% 100% G On track

13 R&QA Rolling twelve month staff turnover within 8-15% 9.93 10.56% G On track

14 R&QA 2015/16 Income and expenditure [% variance] 5.1 2.9 N/A

At the end of December income was in line with budget. Demand for Professional and Linguistic Assessments Board (PLAB) tests has been higher than expectations, registration fees (mainly European Economic Area [EEA] and International Medical Graduate [IMG]) and Certificate of Completion of Training (CCT) applications have been higher than expected, offset by lower investment income and slightly lower Annual Retention Fee (ARF) income (due to natural variations in the timing of doctors joining and leaving the register). Expenditure was £3,010k under budget. Headcount was under budget in the first half of the year due to normal staff turnover and, in some cases, challenges in recruiting suitable replacement staff. Savings have been generated in MPTS linked to the section 60 implementation, and in FTP on legal reports, performance assessor training and external legal costs. The underspend has reduced due to the pension top up payment in December. In overall terms there is a surplus of £3,416k at the end of November against a budgeted surplus of £334k, which is a favourable variance for the GMC.

15 R&QA IS system availability [%] 100 100 G On track

16 S&C Monthly media score 18 251 NA



A4 * From December 2016 the SLA for responding to ethical enquiries changed from ’21’ to ’15’ working days. It was changed to bring it more in line with the rest of the organisation and because the team were managing the SLA over 90% of the time.

# Area BAU Operational KPIs [monthly] Nov Dec Next period Commentary

17 S&C Doctors and medical students surveyed who said they would change their practice as a result of attending a RLS or DO event [%] 66% This reflects the Q4 submission.

18 OCCE Respond to x% of corporate complaints within 10 working days N/A N/A N/A N/A Threshold for KPIs still to be determined – work ongoing in 2017 but will be reported to Council when completed at the end of Q1.



A5

# Area BAU Operational KPI [Annual] Previous period

Current period Commentary

19 S&C Percentage of policy influencing partners who agreed their engagement with us during 2016 had positive influence on their impression of the GMC as an organisation and a positive effect on their work and the work of their organisation.

90.9%2 N/A

The Tracking Survey for 2016 is planned to be published in March 2017.

20 S&C Level of confidence in the GMC’s regulation of doctors (from biennial tracking survey) N/A3 N/A

21 R&QA Staff engagement score³

22 S&C Award in Employers Network on Equality and Inclusion (annual) Silver Award N/A No application made in 2016.

23 S&C Inclusion in Stonewall Equality Index as ‘Top 250 Employer’ (annual) 285 N/A

We did not take part in the Stonewall Equality Index for 2016 as we are working on the recommendations of the last index report. We aim to do the index again in the future as a way of measuring progress.

Business As Usual – Operational KPIs (annual / biennial)

3. Staff engagement will be reported once per year as and when staff survey results are analysed



A6

Detailed Appendix

Data accurate as of 24.01.2017



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1) Implementation of the Change Programme Overall Priority Status

Previous Period

Current Period Trend Next period

G G PRIORITY COMPLETE

Linked Strategic Aim(s)

• Strategic aim 5: Work better together to improve our overall effectiveness, our responsiveness and the delivery of our regulatory functions.

Delivery Activities

Last Current Forecast

Iain McMillan

Project

BAU

Overall status last report

Progress Cost Resource Overall

Status Trend Forecast overall status

GMC Services G ACTIVITY COMPLETE

Summary comments Activities transferred to GMC Services International Ltd as of December 2016.



A8

10


Previous Period





Delivery Activities

Last Current Forecast

Andrew Bratt

Project

BAU




Pensions G ACTIVITY COMPLETE

Summary comments

The Pension Programme Board met on 16 January for the final Project Board. The project team have delivered the consultation with the membership and implementation of the pension scheme reforms within the agreed timeframes. There are a number of documentation requirements which will become business as usual (BAU). This includes ensuring Inside Info is updated once revised scheme booklet is received, ensuring all our internal documentation relating to the General Medical Council Staff Superannuation Scheme (GMCSS) updated and ensuring that the documentation issued by our pension scheme administrators is updated to reflect the changes. A post implementation review for the project is scheduled for 2017. All risks have now been closed.



A9

11


Previous Period





Delivery Activities

Progress Last Current Forecast

Andrew Bratt

Project

BAU




People: Redundancy, recruitment, knowledge transfer

G ACTIVITY COMPLETE

Summary comments

The project team met on 16 January 2017 for the final Project Board. The project team have delivered the consultation, transition and recruitment within the agreed timeframes. 79 staff have now left the GMC. There are 19 staff remaining who have been served notice or where notice is pending. This is in line with the transition schedule for the directorates. 92% of Change Programme recruitment is complete with the remaining 9 posts scheduled for recruitment in 2017. This remaining work will become business as usual (BAU). Finance have tracked the efficient savings from the project and presented these to the Project Board. A lessons learnt review for the HR team will be carried out in 2017. Feedback has already been captured from the Head of Sections (HoS) who delivered the changes in a recent meeting. All risks have now been closed or are captured within current risks on the HR risk log.



A10

12


Previous Period





Delivery Activities


Steve Jones

Project

BAU




Accommodation and extension of new ways of working

G ACTIVITY COMPLETE

Summary comments

The Accommodation Programme Board met on 16 January for its final board meeting. The accommodation project has been delivered on time in December 2016 and a verbal update was given at PRB on the 24 January 2017. In Manchester all desk restack and construction work has been completed. This involved 20 construction phases and some 800 individual staff moves. Soft seating, breakout areas and touchdown spaces are all in place. All GMC staff in Manchester are now consolidated at 3 Hardman Street with 40 staff having moved over from Centurion House. Similarly in London all construction work and staff moves were completed in December with all staff consolidated on the 2nd floor. All staff now are now in their final positions in each location. There will be some minor changes to layout as teams work in the newly configured areas but we are trying to have a 3 month window since completion to allow teams to try different ways of working and these changes will be addressed as part of business as usual (BAU) work in the Facilities section. A survey of construction works has been completed at both sites and the 12 month defects liability period will be managed as part of BAU. A strategy for the disposal of the first floor at 350 Euston Road has been agreed with property consultants Cushman & Wakefield, and Jones Lang LaSalle have now been engaged as joint agents. Two risks from the project risk register remain open, one relating to the risk of not being able to dispose of the first floor and on relating to VAT treatment of lease surrender/disposal payments. Both risks are to be monitored via the R&QA directorate risk register during monthly management and monitoring meetings. This project has now closed.

Click to go back to main table M4 – Chief Operating Officer’s Report


A11

13

2) Taking forward legislative reform/the legislative programme arising from the Law Commissions’ report

Overall Priority Status

Previous Period


G G G


• Strategic Aim 3: Improve the level of engagement and efficiency in the handling of complaints and concerns about patient safety. • Strategic Aim 5: Work better together to improve our overall effectiveness, our responsiveness and the delivery of our regulatory

functions.

Delivery Activities


Anthony Omo

Project

BAU




S60 Reforms G G G G G G

Summary comments

The final version of the report still pending. A draft report shows that there are no resulting actions for Fitness to Practise (FtP). For the MPTS, we are waiting for the final version of the report to be signed off before undertaking any action, but there is likely to be a few more months of reviewing and reporting the efficiency savings. An audit has been arranged for FtP to review the extent to which any impacts and benefits of the Section 60 programme implementation are being monitored, assessed and realised. The audit work will be complete in Q1 of 2017 and presented to Audit and Risk Committee (ARC) in March 2017.


Anthony Omo

Project

BAU




ISG Phase 3 G G G G G G

Summary comments

This is a project to explore the benefits of the organisation facilitating meetings between doctors and patients in cases where the patient has suffered serious harm. It is anticipated that such meetings would complement our existing complaint handling procedures rather than being an alternative to an existing sanction. During December the following activities took place: -Meeting held with Policy on 15/12/2016 to agree principles of preferred model to be recommended to Strategy and Policy Review Group (SPRG) at January 2017 meeting -Meeting held with Marketing Communications on 13/12/2016 to discuss equality and diversity issues and equality analysis -SPRG paper drafted and submitted to Policy for comments on 20/12/2016 -Risk log created -Scoping paper updated in light of comments from Policy. -Agreement reached with the GMC Research team they will do a literature review in house to see if restorative justice style meetings have been used successfully in other countries to facilitate meetings between patients and doctors



A12

14

2) Taking forward legislative reform/the legislative programme arising from the Law Commissions’ report


Previous Period


G G G


• Strategic Aim 3: Improve the level of engagement and efficiency in the handling of complaints and concerns about patient safety. • Strategic Aim 5: Work better together to improve our overall effectiveness, our responsiveness and the delivery of our regulatory

functions.

Delivery Activities


Paul Buckley

Project

BAU




Legislative reform

G G G G G G

Summary comments

We are awaiting confirmation of when the Department of Health (DH) will publish their consultation on Shape of Regulation . An action plan will be developed when it launches. A meeting was held with the DH on 14 December 2016 to discuss Section 60 order.



A13

15

3) Understand the context in which doctors practise


Previous Period


G G G


• Strategic aim 2: Help raise standards in medical education and practice.

Delivery Activities


Paul Buckley

Project

BAU




Promoting Professionalism event programme in 2016

G ACTIVITY COMPLETE

Summary comments Events have been delivered in Northern Ireland, Scotland and Manchester. The Medical Professionalism Matters report was published in December 2016.


Paul Buckley

Project

BAU




Hold Regional KIG Dinners in England in 2016

G ACTIVITY COMPLETE

Summary comments

In 2016 we held four regional seminars. The final regional seminar of the year was South East England held on 7 December, there were 10 external attendees, consisting mainly of medial directors and chief executives. The seminar went very well with attendees addressing issues of greater relevance to the GMC.



A14

16



Previous Period


G G G



Delivery Activities


Paul Buckley

Project

BAU




Organise and host UKAF meetings

G ACTIVITY COMPLETE

Summary comments All scheduled meetings took place during 2016. This activity is complete for 2016. UK Advisory Forums meetings have been scheduled for 2017.


Colin Melville

Project

BAU




Confidentiality project

G G G G G G

Summary comments

Council have approved the confidentially guidance. The project are making arrangements to finalise the guidance by working with the Publications Team who are carrying out activities such as proof reading. The team are preparing with Strategy & Communications (S&C) the stakeholder materials and staff briefings for launch in January 2017.



A15

17



Previous Period


G G G



Delivery Activities


Colin Melville

Project

BAU




Standards App G ACTIVITY COMPLETE

Summary comments

The app is fully released and the IS work has been handed over to the Enterprise systems team - the project is now closed. This project has been financed over two GMC fiscal years - the project cost over those years has been delivered to the original budget. The app was submitted to app stores 8 November 2016, for soft launch on 17 November 2016 and had a full launch on 6 December 2016.



A16

18

4) Medical Licensing Assessment Overall Priority Status

Previous Period


G G G



Delivery Activities


Colin Melville

Project

BAU




Medical Licensing Assessment

G G R G G G

Summary comments

The programme team continue to prepare for the public consultation by working with a range of GMC colleagues to develop consultation documents and build effective communications with key stakeholders. We have reworked the programme’s overall timetable to accommodate the revised consultation launch date. Assuming the consultation launches in early 2017, the programme can deliver on its agreed timescale. The underspend is due to the programme remaining in a formative stage and we continue to review the likely spend profile as part of 2017 budget management. Finance – actual variance value - £141,289 underspend, actual variance - 28.30%, Finance status – Red, Overall status – Green, as at Dec 2016



A17

19

5) Revalidation review Overall Priority Status

Previous Period


R G G


• Strategic aim 2: Help raise standards in medical education and practice

Delivery Activities


Una Lane

Project

BAU




Evaluation of revalidation

G G G G G G

Summary comments

We will receive the next interim report from UMbRELLA in January 2017. This will be a consolidated progress report, so will not be made public. This progress report may also be supported by a series of papers that contain interim findings. The overall project is on track and we expect the final report to be delivered in October 2017. This is earlier than expected as we were to receive this in January 2018; however we do still plan to publish the report in January 2018. We are monitoring progress of this through our monthly review meetings with UMbRELLA. During December 2016, the second targeted survey (to locums, specialty and associate specialist doctors, doctors working in the independent sector, and doctors without a connection for revalidation) was delivered to around 40,000 licensed doctors. At our monthly review meeting in December, UMbRELLA agreed to carry out early analysis of the survey responses from locums, in light of the recommendations about this group of doctors made by Sir Keith Pearson in his Review of Revalidation.


Una Lane

Project

BAU




Revalidation operations

G G G G G G

Summary comments

The team have met their published SLA. During the first six months of 2017, the team will be focusing on implementing the efficiencies identified in the continuous improvement project on operational processes, which was carried out in 2016. In the latter part of 2016, the team identified a trend showing an increase in the percentage of deferral recommendations. The overall number of recommendations received in 2016 declined, which was expected due to scheduling of revalidation dates. However, the number of deferral recommendations did not decline by a comparable volume. The team have undertaken some initial analysis of data, and are monitoring the issue to identify whether this is a long term trend. They also plan to carry out further detailed analysis to understand this trend better. We have a project in 2017 to add further granularity to the deferral statement and, in the fullness of time, this will also aid in our trend analysis.



A18

20


Previous Period


R G G



Delivery Activities


Una Lane

Project

BAU




Skills & competency testing for doctors without a prescribed connection

G G G G G G

Summary comments

The process for doctors being invited to undertake the revalidation assessment is now business as usual. All doctors who are required to sit the assessment have received notice, and will do so going forward. To date: Number of doctors booked onto the assessment – 29 Number of doctors sat the assessment – 55 Number of doctors who have met the required standard – 38 Number of doctors not met the standard - 17 Work continues on developing our guidance for doctors who do not meet the required standard in the assessment. Colleagues met on 17 January 2017 to agree and finalise the policy approach, with a view to publishing the guidance no later than March 2017. A paper will also be submitted to the Strategy and Policy Board in March 2017 to confirm the final position.



A19

21


Previous Period


R G G



Delivery Activities


Una Lane

Project

BAU




Review of Revalidation

R G G G G G

Summary comments

At the meeting on 14 December 2016, Council agreed to publish Sir Keith Pearson’s Review of Revalidation report on 13 January 2017. Our final response to the report has also been agreed and has been signed off for publication. All plans for the publication on 13 January 2017 are now finalised. At the Revalidation Advisory Board meeting on 10 January 2017, Sir Keith will present his report and they will begin to discuss how the recommendations can be taken forward. On 12 January 2017, Sir Keith will hold a press briefing. On publication day (13 January 2017), there will be news items, along with an online video and blog from Sir Keith to support the launch. Planning for implementation of the recommendations is now underway and is on the 2017 business plan.



A20

22

6) Respond to Shape of Training review Overall Priority Status

Previous Period


G R A



Delivery Activities


Colin Melville

Project

BAU




Credentialing G A G R R A

Summary comments

A scoping document for Phase 2 has been drafted. We are seeking a date with the Senior Management Team for agreement on this next phase of work. We are mapping potential credentials against our selection criteria for early adopters. External stakeholders, including the Chair of the UK Shape of Training Steering Group and potential early adopters continue to press for the introduction of regulated credentials. Progress has been delayed due to lack of level 4 support resource and the prioritisation of the Standards for Curricula Review and the Flexibility Review, to ensure that these projects will complete in the time they are committed to. Discussions about resourcing and supporting regulated credentials is ongoing. The next steps will be to get business case approved, finalise an action plan and set up an internal expert group to take this work forward, once additional resource has been secured.


Colin Melville

Project

BAU




Generic Professional Capabilities

G G G G G G

Summary comments

Working group met 12 January 2017 to discuss final points associated with Generic Professional Capabilities (GPC) guidance and plans for launch and positioning this with the key stakeholders groups. The next stage is to launch it in Spring 2017 as part of a series of interrelated reforms: including the new Standards for curricula and assessment (including guidance on assessment), new guidance on the approvals process and separate guidance to illustrate and assist colleges with implementation of the GPC framework.



A21

23

7) Fairness and proportionality Overall Priority Status

Previous Period


G G G


• Strategic aim 1: Make the best use of intelligence about doctors and the healthcare environment to ensure good standards and identify risks to patients.

Delivery Activities


Paul Buckley

Project

BAU




Interim Orders Tribunal Research

G G G G G G

Summary comments

Redaction work has completed and is currently being quality assured before transfer. University College London (UCL) decision makers are being trained on the 30th and 31st January. We expect 120 decisions to be retaken by end of Q1 2017.


Paul Buckley

Project

BAU




Deliver E&D Strategy 2014 - 17

G G G G G G

Summary comments

An update on the delivery of the strategy was provided to the Performance and Resources Board and Council in September. Milestone on track, next meeting of Programme Board will be in March 2017.



A22

24

7) Fairness and proportionality Overall Priority Status

Previous Period


G G G


• Strategic aim 1: Make the best use of intelligence about doctors and the healthcare environment to ensure good standards and identify risks to patients

• Strategic Aim 2: Help raise standards in medical education and practice

Delivery Activities


Colin Melville

Project

BAU




Differential Attainment - Research

G G G A G G

Summary comments

The current project lead will be leaving the team on 6 February 2017, recruitment is currently underway to replace the Differential Attainment Project Lead. The terms of reference for the new Equality and Diversity External Advisory Group was drafted and agreed by the project steering group. The first meeting is scheduled for 6 March 2017. Phase 2 – Fair Training Pathways for All research is on track for submission in March 2017. Three Local Education and Training Board (LETB)/Deaneries have been recruited to the Data Pack pilot (East Of England, London including Kent, Surrey and Sussex (KSS) and Scotland), with a mid-point review meeting scheduled for February 2017.




Colin Melville

Project

BAU




Standards for Curricula and Assessment

G G R A G G

Summary comments

We are in the process of finalising the standards and guidance and are drafting the papers for Strategy and Policy Board (SPB) and Council. Whilst the project is continuing to meet its milestones, significance time and resources have been shifted to supporting the GMC's review on flexibility. We will bring a package of documents to SPB and Council in February 2017 for endorsement and then aim to publish towards the end of April 2017. Finance – actual variance value - £14,633 underspend, actual variance - 83.19%, Finance status – Red, Overall status – Green, as at Dec 2016 A23

25

8) Supporting doctors, patients and relatives involved in fitness to practise investigations


Previous Period


G G G


• Strategic Aim 2: Help raise standards in medical education and practice • Strategic Aim 3: Improve the level of engagement and efficiency in the handling of complaints and concerns about patient safety. • Strategic Aim 5: Work better together to improve our overall effectiveness, our responsiveness and the delivery of our regulatory

functions

Delivery Activities


Anthony Omo

Project

BAU




Monitor & TDA Information Sharing

G A G G G G

Summary comments

Further delays from external partner have meant that an information sharing agreement is yet to be finalised with NHS Improvement. We continue to maintain contact with the Department of Health at Assistant Director level in order to establish meetings and a work schedule for 2017. Delay from external partners has been raised as a potential item for the Corporate Issues Log.


Anthony Omo

Project

BAU




Vulnerable Doctors

G G G G G G

Summary comments

This activity is progressing as planned, and the overall piece of work is on track for completion for the agreed date of Dec 2017/Jan 2018. A small number of short/medium term proposals are affected by the 2017 Siebel release being pushed back to September, but this will not affect the overall project end date. The short term workstreams - due for completion in December 2016 - have been implemented, with some agreed mop-up activity taking place in Q1 of 2017. The updated Responsible Officer thresholds guidance is going to Strategy and Policy Review Group on 16 January 2017 for approval. Work is underway to draft detailed project plans for the short/medium and medium/long term workstreams, with various actions already planned and completed by the workstream leads.



A24

26

9) Communications strategy and engagement Overall Priority Status

Previous Period


G G G


• Strategic aim 4: Work more closely with doctors, medical students and patients on the frontline of care

Delivery Activities


Paul Buckley

Project

BAU




Comms & Engagement work 2016

G ACTIVITY COMPLETE

Summary comments All activities complete for the year. Audience plans completed for Responsible Officers and medical students, further audience plans will be developed in 2017.


Paul Buckley

Project

BAU




Board engagement through 2016

G ACTIVITY COMPLETE

Summary comments Activity complete. The end of year report has been drafted and we are awaiting distribution.



A26

27

9) Communications strategy and engagement Overall Priority Status

Previous Period


G G G


• Strategic aim 4: Work more closely with doctors, medical students and patients on the frontline of care

Delivery Activities


Paul Buckley

Project

BAU




Digital Media Strategy

G G R G G G

Summary comments

Appointed Atmosphere with work to commence in December. Planning meetings with IS also commenced in earnest to plan the deliverables for the remainder of 2016 and set out the road map for 2017. New governance model to support year 2 of the Digital Media Strategy (DMS) being established to support the delivery of the web project. Workshops scheduled with directorates to plan out in more detail the key user journeys and content. Additional external support is in place to support the development of new content and to ensure the wider cultural ambitions of the DMS. Terms of reference phase 1 of the audit programme have been agreed. Handover to the new Marketing Communications team has largely been completed and the budget for 2016 is accounted for. The team focus is now on planning in 2017. Finance – actual variance value - £60,000 underspend, actual variance - 100%, Finance status – Red, Overall status – Green, as at Dec 2016



A27

28

10) Develop the Register and deliver Data Strategy Phase 2


Previous Period


G G G



Delivery Activities


Paul Buckley

Project

BAU




DS 1. Unstructured qualitative data

G ACTIVITY COMPLETE

Summary comments

The project has now completed and has been moved to business as usual (BAU) as of the end of December 2016. The Regional Liaison Service (RLS) pilot is ongoing and the Central Analytic Team (CAT) are reviewing options for evaluation in early 2017.


Paul Buckley

Project

BAU




DS 2. Common & core dashboard development

G ACTIVITY COMPLETE

Summary comments

The project has now completed and has been moved to business as usual (BAU) as of the end of December 2016. We are preparing the response to the Care Quality Commission (CQC) Q4 information request for their inspection using a tailored extract of the organisation dashboard. We discussed with the CQC to hold a review session in March 2017 to agree the format and mechanism for sharing the full extract of data in future after their current inspection schedule ends. In parallel, we have developed a dashboard to share with Responsible Officers through GMC Connect so they have oversight of the information being shared. This has been tested and is being refined before we roll this out in early 2017.



A28

29



Previous Period


G G G



Delivery Activities


Paul Buckley

Project

BAU




DS 3. Sharing GMC data externally

G ACTVITY COMPLETE

Summary comments

The project has now completed and has been moved to business as usual (BAU) as of the end of December 2016. The Performance and Resources Board (PRB) have agreed to delay a decision on the external release of Agora until the end of Q1 2017. However, we have met the wider objective of sharing GMC data externally through the extract of the organisation dashboard with the CQC and development of an RO dashboard to roll out in early 2017, with extracts being provided directly in the interim. We have produced data for the Q3 request and are preparing data for the Q4 request. .


Paul Buckley

Project

BAU




DS 4. Organisational approach to key data capture

G ACTIVITY COMPLETE

Summary comments

The project has now completed and has been moved to business as usual (BAU) as of the end of December 2016. The Central Analytics Team (CAT) is in place. Ongoing work will be taken forward by the CAT as part of the Review of Data and Usage project that will be managed locally during 2017.



A29

30



Previous Period


G G G



Delivery Activities


Paul Buckley

Project

BAU




LRMP development

G G G A G G

Summary comments

The consultation launched on 5 July 2016 and closed on 7 October 2016. We have received 7700 responses. We produced an interim report highlighting key themes from the responses to Council in December. Council noted the feedback received so far and agreed that without prejudice to Council’s decision on the final outcome of the consultation, we should work with the Academy of Medical Royal Colleges to explore the practicality of adding additional scope of practice data to the medical register. There is otherwise a lack of support for options to develop the online medical register as outlined in our public consultation. This will impact on the scope of changes originally envisaged by the project. We will present a full report to Council in February 2017. The project is currently on track to complete remaining milestones on time albeit with delivery of final analysis report being extended due to the large number of responses received.



A30

31

11) Speeding up fitness to practise procedures


Previous Period


G G G


• Strategic Aim 3: Improve the level of engagement and efficiency in the handling of complaints and concerns about patient safety.

Delivery Activities


Anthony Omo

Project

BAU




FtP Operations G G G G G G

Summary comments All FtP SLA’s were met.


Anthony Omo

Project

BAU




Provisional Enquiries roll out

G G G G G G

Summary comments

The Single Clinical Incidents pilot has now been running for nearly five months. So far, a total of 77 enquiries have been considered for the pilot. 27 recommendations have been accepted and have been transferred to the Assurance Team to be monitored via Quality Assurance. Business as Usual (BAU) team is now continuing with the pilot and will flag any project support required during the pilot period. Business Transformation team maintaining an oversight of the work as it continues to develop with the BAU team.



A31


Chief Operating Officer’s Report

Annex B

2016 Income and Expenditure

Revenue Budget

1 The income and revenue expenditure figures at the end of December 2016 are:

Operational financial summary as at December

2016

Budget Jan - Dec

Actual Jan - Dec Variance

Budget Jan - Dec

Q3 Forecast Variance

£000 £000 £000 % £000 £000 £000 % Income Annual retention fees 94,787 94,267 (520) (1)% 94,787 94,105 (682) (1)% Registration fees 3,817 4,258 441 12% 3,817 4,163 346 9% PLAB fees 1,796 2,423 627 35% 1,796 2,393 597 33% Certification fees - CCT 2,474 2,670 196 8% 2,474 2,608 134 5% Certification fees - CESR/CEGPR 853 821 (32) (4)% 853 823 (30) (4)% Interest income 1,048 711 (337) (32)% 1,048 732 (316) (30)% Other income 1,370 1,067 (303) (22)% 1,370 975 (395) (29)%

Total Income 106,145 106,217 72 0% 106,145 105,799 (346) (0)% Expenditure by cost type Direct staffing costs 56,326 55,800 526 1% 56,326 55,871 455 1% Indirect staffing costs 3,598 3,068 530 15% 3,598 3,100 498 14% Office costs 5,887 5,181 706 12% 5,887 5,157 730 12% Accommodation costs 6,847 6,629 218 3% 6,847 6,608 239 3% Legal costs 5,141 4,744 397 8% 5,141 4,886 255 5% Professional fees 1,748 1,860 (112) (6)% 1,748 1,888 (140) (8)% Council & members costs 502 462 40 8% 502 462 40 8% Panel & assessment costs 15,900 14,097 1,803 11% 15,965 14,371 1,594 10% Depreciation 7,575 7,144 431 6% 7,575 7,263 312 4% New Initiatives Fund 250 207 43 17% 250 209 41 16% PSA Levy 736 698 38 5% 736 698 38 5% Consultancy 700 152 548 78% 700 83 617 88% Pension payment 0 2,400 (2,400) 0% 0 2,400 (2,400) 100% UKMLA 500 359 141 28% 500 356 144 29% Unallocated efficiency savings 101 0 101 0% 36 0 36 100% Total Expenditure 105,811 102,801 3,010 3% 105,811 103,352 2,459 2% Surplus/deficit 334 3,416 3,082 334 2,447 2,113

Council meeting, 23 February 2017 Agenda item M4 – Chief Operating Officer’s Report

B2

2 At the end of December there is an operational surplus of £3,416k, compared to a budgeted surplus for the period of £334k. Income is currently in line with budget and expenditure is 3% under budget.

Principal variances – operational income and expenditure

3 Annual Retention Fee (ARF) income is marginally under budget, reflecting normal variations in the timing of doctors joining and leaving the register compared to our budget assumptions.

4 Professional and Linguistic Assessments Board (PLAB) income is higher than budgeted

as there has been an increase in demand for both PLAB 1 and PLAB 2 tests. Income from new International Medical Graduate (IMG) registrations is higher than budget, most likely linked to the additional PLAB 2 tests earlier in the year. There has also been an increase in European Economic Area (EEA) applications. Certificate of Completion of Training (CCT) volumes are also higher than budgeted.

5 Interest income is under budget due to the delay in placing funds under management. 6 Direct staffing costs are under budget due to vacancies in the first half of the year,

and there have been savings in recruitment and travel costs.

7 Within office costs, savings have been made on stationery (following the contract retender) and IT support contracts. Savings have also been made in Fitness to Practise (FtP) and Registration & Revalidation through the greater use of e-communications.

8 Accommodation costs are under budget following successful rent negotiations on Hardman Street. Costs of hearing security and maintenance costs are also lower than budgeted to date. We also successfully applied for charity rate relief on car parking spaces at Hardman Street and St James’ Building.

9 Legal costs are lower than budget as more work, particularly Rule 12, has been handled by the in-house legal team rather than external lawyers. We are also under budget on barristers’ fees.

10 Panel & assessment costs are under budget as FtP have had a drive to reduce the volume of legal reports, and the volume of performance assessments is lower than budgeted. MPTS hearing costs are under budget: there were 123 additional hearing days due to longer average hearing lengths, but the costs were more than offset by savings on Legally Qualified Chair (LQC) work, reduced transcription costs and a reduction in the average expenses claimed by associates.

11 Depreciation is under budget due a difference between the forecast and actual capital spend in 2015, which has implications for 2016 depreciation charges.


B3

12 The Professional Standard Authority (PSA) levy is slightly lower than expected.

13 The pension top up payment of £2.4 million was made in December 2016.

14 Efficiency targets are held on a separate line initially and then reallocated to specific budget heads as projects are identified. Efficiency savings relating to the Section 60 Order have been incorporated in the MPTS budget. The actual level of efficiency savings is £1.94 million against a target of £0.5 million.

15 There were fewer bids to the new initiatives fund and the consultancy fund than budgeted.

Capital expenditure

16 In addition to our revenue expenditure on day to day operational business, the GMC incurs capital expenditure on major projects and assets that will generate benefits over a number of years. The standard accounting treatment is to spread capital costs over the lifetime of the asset, rather than accounting for the whole cost in the year of acquisition.

17 Capital expenditure to the end of December 2016 is:

Capital expenditure as at December 2016

Budget Jan - Dec

Actual Jan - Dec Variance

Budget Jan - Dec

Q3 Forecast Variance

£000 £000 £000 % £000 £000 £000 % IT projects 5,415 5,583 (168) (3)% 5,415 5,415 0 0% Accommodation projects 585 581 4 1% 585 585 0 0% Total 6,000 6,164 (164) (3)% 6,000 6,000 0 0%

18 IT costs were higher than budgeted due to additional demands in the year.


B4

Change Programme

19 Costs and savings relating to the relocation of work to Manchester and the pension reforms are separated from the operational budget as a standalone programme:

Reform Programme summary as at December

2016 Budget

Jan - Dec Actual

Jan - Dec Variance Budget

Jan - Dec Rolling

Forecast Variance £000 £000 £000 % £000 £000 £000 %

Pensions - Revenue costs 150 236 (86) (57)%

150 150 0 0%

People - Revenue costs 4,067 2,784 1,283 32%

4,067 3,297 770 19% People – Savings (1,440) (1,816) 376 26%

(1,440) (1,867) 427 30%

Accommodation - Revenue costs 757 646 111 15%

757 636 121 16%

Accommodation - Capital costs 2,210 2,241 (31) (1)%

2,210 2,170 40 2%

Revenue total 3,534 1,850 1,684 48%

3,534 2,216 1,318 37% Capital total 2,210 2,241 (31) (1)%

2,210 2,170 40 2%

Total 5,744 4,091 1,653 29% 5,744 4,386 1,358 24%

20 Pension costs relate to external advice on the reform of the pension scheme.

21 People revenue costs are under budget as the actual profile of redundancy and recruitment costs differs from our original budget assumptions. People savings have been achieved ahead of expectations as some at-risk staff left the GMC early, which also results in lower redundancy costs. Some dual running costs have been deferred to 2017, and some of the funds set aside as a contingency have not been required. Recruitment and training costs are also under budget.

22 Accommodation revenue costs are under budget following a change in approach to moving the data centre, and capital costs are broadly in line with budget.

Summary

23 The year-end operational surplus is £3.4 million compared to a forecast surplus of £2.5 million.



M4 – Annex C

Appeals and Judicial Reviews 1 The table below provides a summary of appeals and judicial reviews as at 13 January 2017:

Open cases carried forward

since last report

New cases Concluded cases

Outstanding cases

s.40 (Practitioner) Appeals

18 5 5 18

s.40A (GMC) Appeals

4 0 0 4

PSA Appeals 1 0 0 1

Judicial Reviews

5 3 4 4

IOP/IOT Challenges

2 0 1 1

Explanation of concluded cases

2 Appeals:

a 3 appeals dismissed.

b 1 appeal struck out.


C2

c 1 appeal successful.

3 Judicial Reviews:

a 3 permission refused.

b 1 dismissed (by consent).

4 GMC Appeals – 4 outstanding appeals.

5 PSA Appeals – no new appeals, 1 appeal outstanding.

6 IOP/IOT challenges – there is one outstanding IOT challenge; there have been no new IOT challenges since the last report.

Any new applications in the High Court challenging the imposition of interim orders since the last report with explanation; and total number of applications outstanding

7 The outstanding IOT challenge is listed for hearing on 14 February 2017.

New referrals by PSA to the High Court under Section 29 since the last report with explanation, and any applications outstanding

8 There have been no new PSA referrals since the previous report.

Any other litigation of particular note

9 We continue to deal with a range of other litigation, including cases before the Employment Tribunal, the Employment Appeals Tribunal and the Supreme Court.

10 The table below provides a detailed breakdown of outstanding Doctor (s.40) appeals as of 13 January 2017.

No Case Decision appealed Current status

1 Ab Appeal against Medical Practitioners Tribunal decision.

Hearing listed for 12/01/2017.

2 Abd Appeal against Medical Practitioners Tribunal decision.

Awaiting hearing date.


C3


3 Ade Appeal against Medical Practitioners Tribunal Service


4 Al Appeal against Medical Practitioners Tribunal decision.


5 B Appeal against Medical Practitioners Tribunal decision.


6 Ca Appeal against Medical Practitioners Tribunal Sanction.

Awaiting indication from Appellant as to whether he wishes to proceed.

7 Cha Appeal against Medical Practitioners Tribunal decision.


8 Cho Appeal against Medical Practitioners Tribunal decision.

Hearing date vacated. Appeal stayed for an initial period of 3 months to determine whether the Appellant will be permitted to appeal to the Court of Appeal against the original conviction.

9 E Appeal against Medical Practitioners Tribunal decision.


10 I Appeal against Medical Practitioners Tribunal decision.


11 M Appeal against Medical Practitioners Tribunal decision.


12 N Appeal against Medical Practitioners Tribunal decision.


13 Oy Appeal against Medical Practitioners Tribunal decision.



C4


14 R Appeal against Medical Practitioners Tribunal decision.


15 S Appeal against Medical Practitioners Tribunal decision.


16 Sh Appeal against Medical Practitioners Tribunal determination.


17 Sha Appeal against Medical Practitioners Tribunal decision.

Hearing listed for 29/03/2017 for two days.

18 V Appeal against Medical Practitioners Sanction.

Appeal remitted to High Court following GMC’s successful appeal to Court of Appeal against previous High Court decision to allow appeal. Awaiting listing for disposal hearing in the High Court.

11 The table below provides a detailed breakdown of outstanding GMC (s.40A) appeals as

of 13 January 2017.


1 J Appeal against Medical Practitioners Tribunal decision.

Hearing listed for 29-30/3/2017

2 C Appeal against Medical Practitioners Tribunal Service

Hearing listed for 9/3/2017

3 S Appeal against Medical Practitioners Tribunal Service


4 N Appeal against Medical Practitioners Tribunal decision.



C5

12 The table below provides a detailed breakdown of outstanding PSA (s.29) appeals as of 13 January 2017.


1 S Appeal against Medical Practitioners Tribunal decision.


13 The table below provides a detailed breakdown of outstanding Judicial Reviews as at 13 January 2017.

No Case Claim Current status

1 B Judicial Review against the GMC’s decision not to grant restoration to the register.

Permission was granted by the Court of Appeal for Dr Banerjee to appeal against the previous dismissal of her claim by the High Court. The hearing before the Court of Appeal is listed to be heard on either 14 or 15 February 2017.

2 I Judicial Review to challenge the GMC’s decision to restore the doctor’s name to the register.

The GMC has filed its Acknowledgment of Service and a decision on permission is currently awaited.

3 L Judicial Review against two decisions on the Medical Practitioners Tribunal determinations.

Permission was granted by the Court of Appeal for Dr Lee to appeal against the previous dismissal of her claim by the High Court. The hearing before the Court of Appeal is listed to be heard on either 16 or 17 October 2017

4 T Judicial Review of decision not to open an investigation.

Claim issued in Northern Ireland. Agents instructed. The GMC has filed its Acknowledgment of Service and a decision on permission is currently awaited.

Council seminar 23 February 2017


M4 – Annex D

Corporate Risk Register 1 Corporate risk register

2 Risk appetite statement

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Inherent business risks and how we manage them

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8

Del

iver

y pa

rtne

rs The flow of information between the GMC and other bodies who contribute to our overall impact in protecting patient safety is limited and harm is consequently caused to patients

P.BuckleyH

ighl

y lik

ely

Maj

or

Criti

cal

• GMC processes and systems have other relevant checks/controls

• Individual process controls exist around major interfaces

• Systems regulators: Care Quality Commission (CQC); Healthcare Inspectorate Wales; Healthcare Improvement Scotland; Regulation & Quality Improvement: Deaneries and LETBs Medical Royal Colleges Public protection agencies NHS agencies / employers

• Working closely with the Health and Social Care Regulators Forum to improve collaboration

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Council• Discussion at Council Seminar (tbc)

Performance and Resources Board• Update on UKMED and Data Strategy (Jan 2017)

Internal Audit• Data Strategy and Intelligence follow up (August 2016, green-amber) • Data Strategy Programme (February 2015, green)• Intelligence review (November 2015, amber)

-

9

Dat

a

Breach of the Data Protection Act (DPA) and/or Human Rights Act (HRA) may result in financial loss and/or reputational damage

N.Roberts

Hig

hly

likel

y

Maj

or

Criti

cal

• Certified to ISO 27001, IG Toolkit and the Payment Card Industry information security standard PCI DSS

• Certified to BSI10008 standard

• Information Security Working Group oversees controls

• Security incident reporting process in place

• All staff have performance objective to promote information security supported by mandatory training programme

Qui

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Information Security Working Group

Internal Audit• ISO27001 and BS10008 Review (September 2016, green) • Penetration testing (August 2016, green)• BSI10008/IS027001 review (September 2015, green-amber)• Penetration testing (August 2015 - no rating)

Other Assurance • Certified to ISO27001 assessed by BSI annually• Certified to payment card industry information standard toolkit• IG toolkit compliance – assessed by NHS Digital annually• Annual information security risk assessment • Programme of penetration testing performed by external third party

-

12

Exte

rnal

env

ironm

ent

Our response to emerging risks is untimely or inappropriate creating a perception or ineffective performance

P.Buckley

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• Understand and respond to political and health environment - skilled and resourced teams consider and manage developments in the external environment including: Regulation Policy (Horizon Scanning, Inquiries & Reviews); Media and Campaigns; Government, Parliament and Stakeholder Relations; Devolved Office (DO) and Intelligence Unit(s).

• Council membership, DO, Regional Liaison Service (RLS), Patient Safety Intelligence Forum (PSIF), and Advisory Forums provide insight across all UK countries and inform our work programme.

• Engagement programme of Chair and Chief Executive

• Performance monitoring and reporting

• Risk management framework - escalations

• Research agenda

• Refresh of policy and process for handling inquiries and reviews (Inquiries and Reviews Oversight Committee)

• Quarterly UK Advisory Fora (UKAF) meetings in the devolved countries

• Joint Working Information Group (JWIG), meeting of GMC colleagues who provide services within a geographical area across four countries

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Council• Chief Exec report to each meeting covers the external environment & strategic engagements• Paper on GMC Corporate Strategy 2018 - 2020 (Feb 2017) together with research report on The Future Operating Environment of Professional Medical Regulation

Performance & Resources Board• Emerging risks in this environment considered at each meeting• Weekly review in Directors meeting

Internal Audit• Risk maturity benchmarking effectiveness (January 2016, green)• Operational Risk Management (June 2015, green-amber)

Other Assurance • Professional Standards Authority (PSA) Performance Review 2014/15 Standards of good regulation met

Paper on horizon scanning being discussed with Chief Operating Officer (COO) and Directors in March 2017

ID Risk Controls in place to mitigate risk

Risk pre-controls

Func

tion

/ A

ctiv

ity

Owner

Strategic aim 1 - Making the best use of intelligence

CommentAssurance

Residual risk with controls in place

Council and/or Board Review

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Owner CommentAssurance



21

Legi

slat

ion

Mandatory reporting on whistleblowing concerns: Due to delays in the government sharing draft legislative framework and guidance we are delayed in preparing for implementation which may result in there being insufficient time to work with the Government to ensure that the wording of the legislation is workable and ultimately in a failure to comply with a legal duty to produce an annual report on whistleblowing issues from April 2017. The delay in systems changes means data recording will not be available to cover the whole reporting period for the first 12 months the duty is effective, damaging public confidence

A.Omo

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• Cross-directorate project board established to prepare for the new legal duty

• Policy staff liaising with government officials to monitor delays in circulating amended draft regulations for comment

• Cross-directorate impacting completed

• Review of capacity of existing IS intelligence tools to meet anticipated requirement

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Council • Regular updates via COO report

Strategy & Policy Board • Update on response to the independent review of whistleblowing March 2016, update via circulation in June 2016

• We are still waiting to receive draft guidance from (BEIS) to clarify requirements for system changes.

• We are developing a documented process and procedures (April 2017)

Next steps: • Prioritisation of IS resources to implement any system changes required to ensure legal compliance when the requirements are clear• Liaison with other regulators within health sector to establish a shared approach

22

Exte

rnal

env

ironm

ent

Continued stretched resources and finances in the health environment create the potential for increased patient safety incidents which could strategically impact the GMC’s role as the regulator upholding professional standards for doctors and trainees and create operational pressures on fitness to practise referrals and education monitoring services

S.Goldsmith

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• Monitoring and forecasting of Fitness to Practise case loads

• Monitoring of Centre for Workforce Information re NHS staff shortages and skills gaps, and other external sources of quantitative and qualitative data, through horizon scanning (Central Analytics Team)

• Ongoing engagement with Department of Health (England) (DH(E)), Health Education England, and other stakeholders

• Monitoring external environment

• Active engagement with doctors about potential situations which may put patients at risk

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Council• Fitness to Practise performance against Service Level Agreement (SLAs) reported to each Council through the COO report

Performance & Resources Board• Enhanced monitoring figures and fitness to practise caseload volumes reported to each meeting through the Operational Performance and Risk Review report• Media monitoring reported at each meeting

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2

Educ

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Our quality assurance processes do not support compliance with standards for education, training and curricula with a potential impact on patients and below expectation educational outcomes for doctors

C. Melville

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• Documented process and procedures to investigate and monitor concerns

• 'Checks' and thematic quality assurance enable short focussed visits to explore specific issues

• Trained and available staff and Associates

• Enhanced Monitoring Information Published on our website quarterly

• Relationships with other delivery partners

• Sharing of information across the organisation (PSIF and RLS, Employer Liaison Service (ELS) via Joint Working Intelligence Group)

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Council• Operational Key Performance Indicators (KPIs) reported each meeting

Performance & Resources Board• Enhanced monitoring activity volumes reviewed each meeting

Strategy & Policy Board• Report of the Education Quality Scrutiny Group (Oct 2015)

Patient Safety Intelligence Forum • Considers patient risk dimension at each meeting

Internal Audit• Enhanced Monitoring Audit (November 2016, amber-red)• Adoption of the new Standards in a regional QA visit review – phase 2 (September 2016, green-amber) • Adoption of new standards in regional QA visit (May 2016, green) • Review of regional quality assurance visits (July 2015, amber)

Other assurance• Professional Standards Authority (PSA) Performance Review 2014/15 Standards of good regulation met

-

4

Reva

lidat

ing

doct

ors

We revalidate an individual who is not fit to practise with an impact on patient safety and our reputation

U.Lane

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• Documented process and procedures

• Regular performance monitoring and reporting

• Trained and available staff

• Local clinical governance systems identify and address performance concerns

• Employer controls help protect patient safety

• Daily downloads of the register are sent to primary and secondary healthcare organisations

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Council• Operational KPIs reported each meeting

Performance & Resources Board • Activity volumes and service target performance reviewed each meeting

Internal Audit• Revalidation compliance review (November 2016, green-amber)

Other assurance• Shaping the future of medical revalidation - Autumn report (January 2016)• Professional Standards Authority (PSA) Performance Review 2014/15 Standards of good regulation met

-

7

Ethi

cal s

tand

ards

& g

uida

nce

Low awareness and use of our ethical guidance by doctors limits the impact on raising standards of medical practice with a consequent impact on patient care

C. Melville

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• Internal oversight group

• Established, documented proceduresPublic consultation used to develop and validate guidance


• Extensive outreach and engagement activities to promote ethical guidance

• Proactive communications strategy and website improvements

• Use of the digital strategy and new products to enhance doctors’ use of the guidance, including e-books (launched Feb 2016) and app (soft launch March 2016)

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Mod

erat

e

Low

Council• Council to summarise Standards issues and how to maximise impact of the guidance (June 2015)

Strategy & Policy Board• Regular updates during guidance development (ongoing)• Agreement to provide cosmetic guidance update (Feb 2016)

• Annual tracking survey 2015 indicates good awareness of our guidance

• Working with the Continuous Improvement team on Guidance development and capacity building project during 2016

Strategic aim 2 - Raising standards in medical education and practice

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Strategic aim 3 - Improving handling of complaints and concerns about patient safety

1

FtP

- in

vest

igat

ing

conc

erns

Application of key controls and processes lead us to reach the wrong conclusion in investigating a doctor’s fitness to practise with an impact on patient safety, registrants, witnesses and/or the reputation of the GMC

A.Omo

Qui

te li

kely

Maj

or

Criti

cal

• Documented process and procedures


• Trained and available staff (general)

• Training programme for decision makers

• Employer Liaison Advisor (ELA) engagement with Responsible Officers (ROs) ensures all relevant information is considered during investigations

• ELA engagement with ROs to help identify and manage concerns (pre-investigation)

• Reform agenda to drive process improvements


• English Language process introduced

• Dr meetings Pilot now live and business as usual (BAU)

• New Section 60 rules mean that the GMC can appeal against MPTS decisions.

• R4(4) Pilot also now BAU and being expanded to include single clinical incidents, so more investigation undertaken earlier in the process.

• Stream 2 process replaced by Notify Employer/Notify RO

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ikel

y

Maj

or

Sign

ifica

nt

Council• Operational KPIs reported each meeting• FtP Annual Statistics Report (June 2016)

Performance & Resources Board• Activity volumes and service target performance reviewed each meeting

Internal Audit• Implementation of Section 60 requirements (March 2016, green)• Decision-making compliance (September 2015, green-amber)

Other assurance• Professional Standards Authority (PSA) Performance Review 2014/15 Standards of good regulation met

5

Adju

dica

tion Patient safety is impacted and/or

reputational damage is caused by not providing an effective and timely adjudication process

L. Geddes

Qui

te li

kely

Maj

or

Criti

cal

• Documented process and procedures (Adjudication Manual)


• Trained and available staff (including MPTS induction)

• Panellist training and assessment (including Induction programme)

• S60 changes implemented to bring further assurance to MPTS process including binding case management decisions.

Unl

ikel

y

Min

or

Low

Council• MPTS formal report to Council (6 monthly)• Interim Order Panel service targets reported to each meeting

MPTS Advisory Committee• Quarterly reports to MPTS Advisory Committee

Internal Audit• S60 operational review (November 2016, green-amber) • Implementation of Section 60 requirements (March 2016 - green) • MPTS system compliance of QA arrangements (February 2015, green)

Other Assurance• Professional Standards Authority (PSA) Performance Review 2014/15 Standards of good regulation met

-

6

FtP

- sa

nctio

ns

Doctors under conditions or undertakings do not comply with their sanctions and patients are harmed as a consequence

A.Omo

Unl

ikel

y

Maj

or

Sign

ifica

nt

• Case Review Team - documented processes and skilled resources

• Sanctions are listed on the List of Registered Medical Practitioners

• Notification of overseas regulators (if required)

• Publication of public hearing minutes



• Continuing development of GMC/RO relationships

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y

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erat

e

Low

Internal Audit• Monitoring sanctions (September 2015, green-amber)


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10

Legi

slat

ion The UK and European

legislative frameworks in which we operate restricts our ability to deliver functions to full effect or efficiency

P.Buckley

Hig

hly

likel

y

Mod

erat

e

Criti

cal

• Domestic legislation - active engagement with DH(E) including over the use of s.60 orders to amend the Medical Act

• Chief Executive legislation group has been reformed to assist regulators to develop common positions around future shape of regulation

• European legislation - Skilled and resourced team to monitor and represent our interests at the European level and advise the organisation about any new EU developments. We continue to engage with EC officials, DH(E) and Business Innovation and Skills on the Recognition of Professional Qualifications engagement and implementation. We also convene the Alliance of UK Health Regulators on Europe and jointly coordinate the European Network of Medical Regulators on Europe to develop common positions when new European policy and legislative initiatives emerge and jointly engage with decision-makers, if required

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Strategy and Policy Board • EU Recognition of Professional Qualifications Directive (RPQ) update (Feb 2016) • Process of specialty recognition in the recognition Directive (May 2016)

Performance and Resources BoardUpdate on Internal Market Information System (Jan 2016)

Council• Chief Exec report - Legislative reform update• Chief Operating Officer's Report • Session on legislative reform (Feb 2016)

Council - Members Circular• Update on Law Commission Bill (March; April; June; July 2016)

The RPQ Directive was implemented by the UK government at the end of 2016 and the UK is now compliant with its provisions

Department of Health consultation on the future of professional regulation expected in Q1 2017. We continue to engage with the Department of Health about legislative reform

19

Exte

rnal

env

ironm

ent

Brexit: The impact of changes resulting from the European referendum are not yet clear, providing uncertainty as to the future implications of the GMC’s work.

P.Buckley

Qui

te li

kely

Maj

or

Criti

cal

• Establishment of cross-Directorate Brexit working group led by the European and International team to scope challenges and opportunities for the GMC; to define legislative priorities; and to review the potential impact on the legislation affecting our work

• Ongoing engagement planned with Governments and key stakeholders

• Active engagement with key influencers to influence post Brexit proposals for healthcare regulation and accountability.

• Programme of active engagement and influence with the HSC through 2017,including response to inquiry on impact of Brexit on the health sector

• Liaison with UK and European regulators to ensure influence and leadership of key networks is maintained

• Publication of analysis of licensed doctors with an EEA PMQ

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Council• Short discussion at Council on 29 September • Council sessions planned in Q1 2017 and Q3/Q4

Other• Health Select Committee (HSC) response shared with Council (October 2016)• Shared HSC submission with new Council members (December 2016)

The UK government is expected to trigger Article 50 and begin the process of EU withdrawal before the end of March 2017

On 3 November 2016, the High Court ruled that Parliament must vote on whether the UK can trigger Article 50. The government is appealing in the Supreme Court. A ruling is expected in January

A separate legal challenge through the Irish High Court contends Article 50 should be revocable once it is activated

20

Exte

rnal

env

ironm

ent

The GMC's regulatory effectiveness, credibility and reputation may erode over time if we don't keep abreast of widening political agendas in the devolved nations and England and adapt accordingly, as highlighted by the outcome from the EU referendum and national elections

P.Buckley

Qui

te li

kely

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erat

e

Sign

ifica

nt

• Understand and respond to political and health environment - skilled and resourced DO teams consider and manage developments in the external environment with consideration at regular four country strategic risk meeting • UK Advisory Forums• UK Regional dinners with key stakeholders • Full implementation of DO Review • Action plan developed to implement outcomes of Council seminar paper "The vote to leave the EU and regulating in a four country and international context" July 2016• Brexit internal working group set up

Quite likely M

inor

Low

Council• Regular milestone for Council review to be agreed

Performance and Resources Board• PRB agreement of risk September 2016

A review of effectiveness of UK advisory forums is planned for 2017

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3

Regi

ster

ing

doct

ors

We register an individual who is not properly qualified and/or fit to practise with an impact on patient safety and our reputation

U.Lane

Qui

te li

kely

Maj

or

Criti

cal

• Documented process and procedures: UK graduates EEA IMG Specialist and GP applications



• Information exchange with competent authorities informs our processes



Unl

ikel

y

Mod

erat

e

Low

Council• Operational KPIs reported each meeting

Performance & Resources Board• Activity volumes and service target performance reviewed each meeting

Strategy & Policy Board• Review & Appeal options - specialist apps (April 2016)

Internal Audit• Review of the adoption of changes arising from the new RPQ directive audit (November 2016, green-amber) • Adoption of Recognition Professional Qualification Directive 2013/55/EU (March 2016, green)• UK Graduate Application (May 2015, green) • Approved Practice spotcheck (November 2015)


-

13

Med

ia

Low awareness of our role and how we conduct our business leads to media coverage which damages our reputation

P.Buckley

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Skilled and resourced media team to handle media enquiries

• Communications activities to raise awareness of our role: ○ Co-ordinated campaign planning with policy directorates ○ News bulletins to stakeholders and key audiences in 4 countries ○ Proactive media and social media campaigns about our role

• Professional and active corporate presence on all main social media channels

• GMC processes and systems have other relevant checks/control: ○ Daily media monitoring ○ Social Media monitoring

• Governance - media principles agreed by Chair & Chief Executive

• Development of Media Strategy includes audience plans

Qui

te li

kely

Min

or

Low

Council• Receive daily media cuttings• Receive GMC press releases-Informal session on the work of the media team (April 2016)• Media performance reviewed at each Council

Performance & Resources Board• Media performance reviewed at each Board

Strategy & Policy Board• Relationships Review (Oct 2016)

Internal Audit• Writing with impact and tone of voice (July 2016, green-amber)

Other Assurance• Tracking Survey publication April 2015

Tracking survey was launched in Spring 2016 and will provide evidence of any change in doctors attitude towards our work. Final report received Jan 2017. Jan-March, period of internal engagement to reflect on results

Plans to publish results in March 2017

Strategic aim 4 - Working more closely with doctors, medical students and patients

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Strategic aim 5 - Working better together to improve our effectiveness in delivery of regulatory functions

11

Gov

erna

nce Our governance arrangements

may not enable the Trustees to discharge their accountabilities effectively

S.Jones

Hig

hly

likel

y

Maj

or

Criti

cal

• Governance arrangements in place including Council, executive and external engagement.

• Performance management system for members and staff

• Business planning & budget setting process

• Risk Management Framework

• Performance monitoring & reporting

• Policies and procedures

• Internal audit

• Council member training and annual appraisal in place

• Regular governance reviews

Unl

ikel

y

Mod

erat

e

Low

Council• CE and COO reports at each meeting• Review of performance data at each meeting• Report of the Audit and Risk Committee (December 2016)• Report of the Remuneration Committee (December 2016)• Report of the Performance & Resources Board (December 2015)• Report of the Strategy & Policy Board (December 2015)• Council forward work programme 2016 (December 2015)• Review of Council effectiveness (ongoing)

Internal Audit• Performance reporting to Council (September 2016, green)• Change programme risk management (June 2016, green)• Equality and diversity review (June 2016, green)• Risk benchmarking review (January 2016, green) • Operational risk management (June 2015, green-amber)• Review of whistleblowing arrangements spotcheck (March 2015)• Gifts and hospitality spotcheck (March 2015)• HR performance data reporting (February 2015, green)

Other Assurance• Four year scheduled review of Governance in 2017• External audit of financial accounts, 2016, 2015

-

14

Fina

ncia

l con

trol

s (f

raud

) an

d ex

pend

iture

Our anti fraud procedures and process may not prevent internal or external parties from committing fraud against the GMC resulting in monetary loss

N.Roberts

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Business planning & budget setting process to ensure funds are allocated appropriately

• Monthly management reporting and review

• Financial controls including delegated authorities by the PRB

• Fraud-control processes including policy, training, response plan, public interest disclosure policy and anti-fraud and corruption policy.

• Oversight of Investment Policy by Investment Sub Committee

Unl

ikel

y

Mod

erat

e

Low

Council• Annual Report & Accounts 2015 (June 2016)• Fitness to Practise Annual Report 2015 (June 2016)• Financial performance reported as part of COO report each meeting

Audit & Risk Committee• Review of annual accounts (April 2016)

Performance & Resources Board• Financial performance reviewed at each meeting

Internal Audit• Contract management arrangements review (October 2016, amber) • Budget management and monitoring (October 2016, green)• Anti fraud arrangements (May 2016, green) • Financial controls review (October 2015, green) • Procurement review (March 2015, green)

Other Assurance• External audit of financial accounts 2016, 2015, 2014

-

15

Wor

k pr

ogra

mm

e de

liver

y

The volume and complexity of the programme of work we seek to undertake exceeds our capacity to successfully deliver

C. Massey(S.Goldsmith)

Qui

te li

kely

Maj

or

Criti

cal

• Business planning & budget setting process

• Risk Management (including risk escalation matrix incorporating SLA variation triggers)

• Monthly monitoring of delivery progress and reporting

• Centralised Corporate Business Planning team embed processes and systems across Directorates

• Trained and skilled staff in project management

• PPM methodology and reporting: update on risks and project delivery every two weeks via highlight reports with daily availability of progress for all including Portfolio Lead, Sponsor, Project Manager, PMO and COO

• Corporate Business Planning Manager stage gate reviews for all projects

Unl

ikel

y

Mod

erat

e

Low

Council• Delivery progress update as part of COO report at each meeting• 2017 Business Plan & Delivery (Dec 2016)

Performance & Resources Board• Business plan delivery reviewed at each meeting

Internal Audit• Programme Management Office spot check follow up (November 2016, green-amber)• Change Programme Risk Management (June 2016, green-amber)• Programme Management Office spot check (May 2016, green-amber)• Change Programme planning (March 2016, green-amber) • Operation risk management (June 2015, green-amber)

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16

Staf

fing

Difficulties in the recruitment and retention of staff with the required skills and experience may challenge our ability to deliver our functions effectively

N.RobertsQ

uite

like

ly

Maj

or

Criti

cal

• Talent and leadership programmes builds capacity

• Corporate record keeping systems and requirements enable central record for corporate memory

• Directors and ADs identify unique knowledge, skills and relationships to ensure suitable mechanisms in place to record/transfer

• Annual performance management cycle and learning and development function identify staff training needs and prioritise and support staff development as required

Unl

ikel

y

Mod

erat

e

Low

Council• Council receive an annual HR report

Council - Members Circular• Niall decision to step down (Jan 2016)• CE recruitment (April 2016)• Senior Staff Appointments/Changes (June; July)

Performance & Resources Board• Staffing volumes monitored at each meeting (including absenteeism, turnover, key staff changes)

Internal Audit• Review of induction planning (August, green)• HR appraisal review (June 2015, green-amber) • HR conducting annual review of succession planning

Other assurance• Internal checks are carried out on the quality of the performance management system throughout the year

-

17

Busi

ness

Con

tinui

ty

An external incident which effects our infrastructure and/or staffing levels may prevent us from delivering our key functions

N.Roberts

Qui

te li

kely

Maj

or

Criti

cal

• Business continuity plans in place including periodic testing - focussed on core business as usual areas to ensure patient safety protection

• Alternative routing procedures and systems in place to manage faults when they arise • Investment programme in resilience components to proactively avoid faults

• Testing of process recovery

• Information security processes protect against IS failures

Unl

ikel

y

Mod

erat

e

Low

Business Continuity Working Group - (2 monthly)

Annual report to PRB for review• Annual update from Business Continuity Working Group to PRB

Internal audit• Penetration testing (June 2016, no rating)• Business Continuity arrangements (August 2015, green) • Penetration testing (July 2015, no rating) -

18

Ope

ratio

n of

DB

pens

ion

sche

me

Adverse economic events create a significant deficit in the Defined Benefit (DB) Scheme which the employer needs to cover

N.Roberts

Qui

te li

kely

Maj

or

Criti

cal

• Maintaining adequate reserves

• Future liabilities restricted by scheme closure and benefits changes

• Full implementation of Trustees de-risking investment strategy

Unl

ikel

y

Mod

erat

e

Low

Internal audit• Trustees have the scheme audited on an annual basis.• The employer has access to actuarial advice

Other assurance• Ernst and Young provide independent advise on the investment strategy and fiduciary manager• Trustees have actuarial and investment advice investment

-

Current active risks and how we are reducing them

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1A

Util

isin

g da

ta

By not effectively sharing the information we hold throughout the organisation or broader health service, we could contribute to a risk to patient safety

P.Buckley

• Data Strategy

• Patient Safety Intelligence Forum

• Quality Architecture Project Group

• Quarterly surveillance groups consider risk with CQC

• Existing specialist data teams and Siebel analytics capability

• Regular (8 weekly) intelligence sharing meetings in place (Regional Information Forums)

• MoUs: Healthcare Inspectorate Wales, TDA and RQIA, Health Improvement Scotland -DO protocol for escalation processes - JWIG meeting brings together DOs, RLS, Revel & Education to share information.

• Existing employer controls to protect patient safety

• Systems regulators, professional regulators, professional bodies, education institutions actively overseeing patient safety

• Revision of escalation process and RLS operating model (June 2016)

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Central Analytics Team to be formed by February 2017 with responsibility for co-ordinating data sharing

Data Sharing manager developing policy tools for information sharing (Q3 2017)

Evaluation of data sharing agreements to be undertaken by CAT (TBC)

Performance & Resources Board • Resourcing the data strategy (June 2016)

Strategy & Policy Board• UKMed Data Warehouse (Feb 2016)

Council • Developing the online register of data sharing agreements (December 2016)• Chief Operating Officer's Report (June 2015; Sep 2015)

Data Strategy and Intelligence follow up (August 2016, green-amber) Intelligence review (Nov 2015, amber) Data Strategy Programme (Feb 2015, green)

-

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

12- External Environment

4A

Equa

lity

& D

iver

sity We do not comply

with our statutory obligations on Equality and Diversity and Human rights, leading to unfair outcomes

P.Buckley

• Equality & Diversity Strategy

• Directorate action plans

• Skilled and resourced team to promote E&D in our work

• Equality analysis undertaken as a component of major project activity

• Equality and diversity training for all staff and associates

• E&D Programme Board (chaired by COO)

• Audit of papers considered by SPB and Council, all found to be compliant

• Unconscious Bias training delivered to key staff involved in making decisions about doctors

• Internal audit found that we are broadly compliant and delivering our E&D Strategy

• Phase II Unconscious Bias training for staff and associates

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Develop guidance on culture and making fair decisions for MPTS and FtP decision makers (December 2016)

We are taking legal advice on whether we are compliant with Sections 15 and 22 of the Gender Recognition Act (GRA) 2004 in how we handle and share information about transgender patients in our FTP activities

Work on reasonable adjustments (ongoing, with workshop Oct 2016)

Joined AoMRC working group to develop guidance on making reasonable adjustments in high stakes exams

Strategy & Policy Board• Consider and update on 2016 plans & priorities (May 2016)

Council• Update via COO report (ongoing)• Seminar on Fairness & Proportionality (April 2016) • Update on implementation of our strategy (Sept 2016)

Education and Training Board• Will consider how to ensure reasonable adjustments within the continuum of medical education and training (Oct 2016)

E&D operationalisation (July 2016, green)

We are not consistent in our approach to making reasonable adjustments for people wanting to raise concerns with us - this is being raised with colleagues in FtP & IS.

Advice from counsel that we are compliant with Gender Recognition Act 2004

Internal workshop on reasonable adjustments took place

The Academy of Medical Royal Colleges has drafted new guidance on reasonable adjustments for GMC to review

GMC won legal challenge at Employment Tribunal on less than full time working

Unl

ikel

y

Mod

erat

e

Low 1-7

Corporate Risk that

Action Plan relates to

Comment(incl. external assurance where

relevant)

Further mitigating actions to be implemented

(with target date)

Risk target

Council and/or Board ReviewInternal Audit

coverageID Risk Owner

Fun

ctio

n /

Act

ivit

y Residual

Existing controls(incl. Local QA where relevant)

Strategic aim 1 - Making the best use of intelligence


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Corporate Risk that



relevant)


(with target date)

Risk target



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ctio

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Act

ivit

y Residual


10A

Med

ical

Lic

ensi

ng A

sses

smen

t

Our model for a Medical Licensing Assessment is not developed to be fit for the future, attract key interest support and able to be implemented within a reasonable timeframe with a impact on patient safety, medical students, new registrants and the reputation of the GMC with key interest groups and the public

C. Melville

• A formal project and project team has been established, with programme management and regular reporting arrangements

• Governance arrangements are in place with a Programme Board chaired by the COO providing leadership and oversight

• Regular engagement takes place with the Medical Schools Council and medical schools

• Regular engagement takes place with the Medical Schools Assessment Alliance

• Sufficient resource and budget allocated

• Comprehensive engagement plan to liaise with a range of key stakeholders including all UK administrations

• Appointment of Expert Reference Group meeting from October 2016

• Consultants appointed to review structure, governance and communications associated with the project (June - September 2016), programme manager appointed

• Appointment of Consultants to draft a detailed cost and impact analysis of a range of MLA options (June - October 2016)

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Review the outcomes for graduates (2017)

• A public consultation will launch in early 2017

• Pre-consultation engagement - discussions with key senior stakeholders (Jan 2017)

Council• Initial business case and agreement to develop proposals June 2015• Update report April 2015• Consultation paper - September 2016, paper re-circulated to Council Jan 2017

Strategy & Policy Board• Initial business case May 2015

Review planned 2017

Unl

ikel

y

Min

or

Low 12 - External

Environment

Strategic aim 2 - Raising standards in medical education and practice

2A

Rev

alid

atio

n

We lose support for revalidation from key interests groups which undermines revalidation and has an impact on patient safety, our resources and our reputation.

U.Lane

• Processes and systems in place are robust and maturing – for doctors with a connection and doctors without a connection. Guidance for managing and responding to information is clear, accessible and regularly reviewed.

• Introduction of the revalidation assessment for doctors without a connection (Jan 2016).

• Decision Review Group established to support organisation learning from appeals (Q4 2015).

Meetings and engagement:• Regular external meetings with key stakeholder organisations including; Care Quality Commission, Academy of Medical Royal Colleges, Association of Independent Healthcare Organisations, and the Responsible Officer Calibration and Operational Network (ongoing). • Patient Safety Intelligence Forum uses revalidation to identify concerns around, and mitigation for, local clinical governance issues.• Revalidation Advisory Board monitors views and experience of implementation.• Supporting and engaging Responsible Officers through ELA and Responsible Officer meetings, reference groups and bulletins to identify risks (opportunities/threats), issues and best practice.

Independent evaluations of revalidation published:• Evaluation of revalidation interim report (published Apr 2016.) • Manchester Business School interim report for DH evaluation (published Apr 2016)• Review of revalidation by Sir Keith Pearson (reporting to Council Dec 2016).

Publications to enhance guidance and understanding of revalidation:• Case studies and guidance on enhancing understanding of the role of patients and the public in revalidation (January 2016)• SOMEP 2014 and 2015 reports included positive findings on ‘The impact of revalidation on patient safety’.

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Continued senior management engagement with NHS England, Department of Health and other stakeholders around the future of responsible officer functions and potential legislative changes (ongoing)

Strategic evaluation (2018 - final report) Have initiated a review of current guidance for collating supporting information and plan to establish a working group with external stakeholders (project completion Q4 2017)/ DH (England) undertaking an evaluation of revalidation in England (Report early in 2017)

Recommendations from Sir Keith Pearson's Review of Revalidation to begin being implemented in 2017

Council:• Chief Operating Officers report - Performance against service targets and volumes of activity – fitness to practise, registration and revalidation• Strategic evaluation and MBS DH interim reportsRevalidation Assessment COO Report Feb 2016; Apr 2016 and June 2016)

Strategy & Policy Board• Report of the Revalidation Advisory Board (February 2015; July 2015; and Oct 2015)• Revalidation arrangements for doctors in our FTP processes (May 2015)• Revalidation assessment update (Oct 2015)• Report of the Strategy & Policy Board 2015 from Chief Exec - RAB, revalidation of FTP Strategic evaluation verbal updates (Feb and Mar 2016)

Performance & Resources Board:• Operational Performance and Risk Review ( January 2015; April 2015; and June 2015,Sep 2015; Nov 2015; Jan 2016; Mar 2016; April 2016; and Jun 2016)

12 - External Environment

Revalidation compliance review (November 2016, green-amber rating)

Revalidation Assessment first notices were sent in January, the first round of assessments took place in May and the first doctors to be revalidated was in June 2016 U

nlik

ely

Mod

erat

e

Low


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ct

Ass

essm

ent

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lihoo

d

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ct

Ass

essm

ent

Corporate Risk that



relevant)


(with target date)

Risk target



Fun

ctio

n /

Act

ivit

y Residual


14A

Wor

king

with

reg

ulat

ory

part

ners

In cases where there are high profile patient safety issues and potentially unsafe environments for doctors and doctors in training, there are challenges in working effectively and collaboratively with other regulatory partners causing an adverse reputational impact for the GMC

S. Goldsmith

• Information sharing agreement in place with CQC

• Working closely with the Health and Social Care Regulators Forum to improve collaboration

• Education enhanced monitoring process in place

• Internal processes to manage communications


Qui

te li

kely

Hig

h

Criti

cal

• Working towards information sharing agreements in other regulators including devolved nations

• We are currently undertaking a lessons learned exercise, including whether there are ways to improve our joint working with other regulators

Health and Social Care Regulators Forum have agreed actions and workstreams to improve collaboration across the system:

• Develop a shared escalation protocol• Influence existing structures and fora to support information sharing• Agree a process for defining and communicating roles and responsibilities• Improve the use of data and insight - GMC to set up working group and feedback on analysis of current practice• Develop a culture of proactively sharing information and briefings

Council• Acting Chief Executive's Report (June 2016), North Middlesex

Audit and Risk Committee• Verbal update from CEO (July 2016), North Middlesex

Case study report which explored the GMC’s engagement with North Middlesex University Hospital Trust (NMUHT) during the period January 2015 to September 2016 was discussed at PSIF in November 2016

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Risks 2 - Education QA, 8 - information flow between GMC and other bodies, 1A - information sharing internally and externally


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Corporate Risk that



relevant)


(with target date)

Risk target



Fun

ctio

n /

Act

ivit

y Residual


13A

Util

isin

g da

ta

Further historical abuse cases involving doctors come to light which call in to question the GMC’s actions at the time and impact on our reputation as a patient safety organisation

P.Buckley

Regular media monitoring of historic abuse cases

Internal Historic Abuse Inquiries Project Group to monitor and manage interactions with all inquiries and take forward internal review of historic abuse cases Q

uite

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• Review of historical child abuse cases to be undertaken, complete in 2017. Terms of Reference, methodology and new initiative fund bid have been agreed

• Scanning of bound volumes of historic fitness to practise cases dating back to 1945 has begun and will aim to complete by Q2 2017

The review will be overseen by the Historical Abuse Inquiries Project Group, and findings will be reported to Council in due course Q

uite

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Strategic aim 3 - Improving handling of complaints and concerns about patient safety


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Strategic aim 4 - Working more closely with doctors, medical students and patients

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The European Qualifications (Health and Social Care Professions) Regulations 2016 were laid in Parliament on 28 October 2016 and came into force on 18 November.

Review of the adoption of changes arising from the new RPQ directive audit (November 2016, green-amber)

Implementation and introduction of the EU RPQ (April 2016, green)

Council • Chief Exec's Report (June 2015; Sep 2015; Dec 2015)• Council session on EEA doctors (July 2015)• Chief Operating Officer's Report (Dec 2015)

SPB• Impact of EU RPQ on acceptable overseas qualifications and Guidance for Doctors considering T&O service provision (Dec 2015)

Audit and Risk CommitteeSession on RPQ risk (May 2015)

PRB• Update on the risks and the IMI Alert Mechanism (Nov 2015)

• Cross referencing data sources to identify doctors with temporary & occasional registration gaining full time employment or connection to a designated body (Jan 2016 onwards)

• ID checks conducted on all doctors prior to granting registration currently in place as an anti-fraud and security measure

• Post registration primary source verification completed on a risk based sample of EEA doctors qualifications

• English language competency requirements introduced and IELTS score increased (June 2014) and maintained following clarification of powers under revised RPQ Directive (Jan 2016).

Information and intelligence sharing:• Use of the EC Internal Market Information (IMI) system to transfer qualification and FTP information about doctors between EU regulators (introduced Jan 2016) • Corporate membership of the Alliance of UK Health Regulators in Europe (AURE) and European Network of Medical Competent Authorities (ENMCA)

Temporary and occasional registration:• This application route is now online with updated guidance - including criteria for 'temporary and occasional’ and 'establishment' in medical practice (Jan 2016)• Publicising features of T&O registration to employers through presentations (Apr to Dec 2015) and mailings to UK Chief Executives (Jan 2016)

• Licensed doctors who are established in the UK are required to revalidate (with the exception of T&O service providers) (Since Dec 2012)

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3 - Registering doctors

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We register an individual who is not properly qualified and/or unfit to practise owing to the limited checks we can conduct on EEA nationals under EU legislation, with an impact on patient safety and our reputation


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11A

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Due to the increased pressures on the business, the implementation of the corporate Change Programme may be delayed or inefficiently executed. This would lead to underachievement of the anticipated benefits of the programme

S. Goldsmith

• Existing financial control measures are robust –links to risk 14

• Corporate Business Planning and budgeting controls apply to BAU and the Change Programme combination – links to risk 15

• The high level governance structure for oversight of programme risks and delivery is well embedded in existing GMC structures (i.e. PRB, ARC and Council) – links to risk 11

• Workforce planning controls exist and have been tested with previous re-location challenges – links to risk 16

• Existing stakeholder engagement plans provide the platform for the Change Programme communications – links to risks 12 and 13

• External specialist input and scrutiny provided through Pension Trustee Board

• Change Programme Performance and Resources Board meetings to be established with full Project Management Support for oversight and performance reporting (December 2015)

•Overall Change Impact Assessment for the Change Programme to be developed (December 2015)

• Detailed risk analysis and individual project risk registers

• Communication strategy for Internal and external stakeholders in place

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• Ongoing lease negotiation advice sought from property advisers. Second property consultancy (Jones Lang LaSalle) engaged to work alongside Cushman & Wakefield

• Agreement on lease disposal strategy based on advice from property advisers completed

• Further analysis of risks across the programme to be undertaken to implement recommendations from audit of programme risk management in July 2016 (October 2016)

Change programme papers and presentations have been discussed at:

• Council away day (July), seminar and meetings (September, November and December 2016) • At every Council and Audit and Risk Committee a verbal progress update is given by the COO• At every PRB Change Board meeting there is a full update on each portfolio provided by the portfolio lead

Benefits realisation review in 2017

PMO follow up (Nov 2016, green-amber)Programme risk management (July 2016, green) PMO spot check (May 2016, green-amber) Change Programme initial implementation (March 2016, green-amber)

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14 - inadequate forecasting and financial control, 11- governance arrangements, 16- recruit, retain or manage transition of staff, 12-responding to emerging issues, 15- volume/complexity of programme and capacity to deliver.

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When GMC Services International Ltd develops opportunities beyond commercialising currently provided services, it may be restricted by the availability of appropriate resources required to deliver at the appropriate standard

S. Goldsmith

• Allocation of resources decisions made in context of 2016 and 2017 business planning• Incorporated as business as usual activity • Appointed lead for GMC Services in place• Governance model established• Proposal and business case for taking forward initial pilots (June 2016)• Review of options for capacity to bid and deliver, paper to COO (November 2016)

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nt• Regular updates to COO on projects - ongoing• GMC Services International Ltd monthly Supplier Forum to begin (Feb 2017)• GMC Services International Ltd Operational Framework to be agreed (February 2017)

• Monitored at each PRB Change Board meeting - Reporting to PRB in April 2016 and Council June 2016

• Council away day (July 2016), seminar and meetings (September 2016 and December 2016)

GMC Services review 2017

To note, the creation of GMC Services International Ltd was agreed by Council (December 2016)

GMC Services International Ltd was incorporated in December 2016

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Strategic aim 5 - Working better together to improve our effectiveness in delivery of regulatory functions

Council meeting 23 February 2017

Risk appetite statement

Introduction 1 The GMC is an independent organisation that helps to protect patients and improve

medical education and practice across the UK.

We decide which doctors are qualified to work here and we oversee UK medical education and training.

We set the standards that doctors need to follow, and make sure that they continue to meet these standards throughout their careers.

We take action to prevent a doctor from putting the safety of patients, or the public's confidence in doctors, at risk.

2 Every patient should receive a high standard of care. Our role is to help achieve that by working closely with doctors, their employers, patients and educators to make sure that the trust patients have in their doctors is fully justified.

Protecting patients underpins everything we do 3 Given our patient safety focus, we have a low risk appetite overall in relation to our

activities.

4 However, we also recognise that to function as a modern, outward-facing organisation working in a digital, 24/7 environment, and to respond successfully to the strategic and operational challenges described in our Corporate Strategy and annual business plans, we are exposed to and must accept a certain level of risk.

5 Risk is sometimes – wrongly - associated solely with taking action, the implication being that doing nothing avoids any risk. But often there is more risk in failing to respond or pre-empt an issue, even in circumstances of great uncertainty.

Why we consider risk in our decision-making 6 If we do not assess risk properly then we are more unlikely to achieve what we set

out to do. In seeking to embrace opportunities which have the potential benefit in the medium and longer term to strengthen patient and public protection, improve patients’ experience of medical care, enhance the learning environment for students

Council meeting 23 February 2017 M4 – Chief Operating Officer’s report

2

and trainees and improve standards of medical practice. It is therefore incumbent on us to carefully consider the risks which may impact on a successful outcome to achieve the benefits of taking a particular course of action.

7 An example of this is seizing the opportunity to develop and implement a data strategy as we believe in the longer term understanding the data and intelligence we and others in the health system hold, will support a more proportionate, risk based and targeted approach to future regulatory activities.

8 In developing our approach to the use of data we need to be mindful of all the risks but balance them with the goal of better protecting patients, guiding doctors, supporting medical education and reducing the burden of regulatory action.

How we balance risk and opportunity 9 We acknowledge that within our general approach to setting risk appetite, one size

does not fit all. To address this, we consider a number of factors in the opportunities and risks involved when making decisions for different activities and projects.

10 Considering the impact on a broad spectrum of factors provides a framework for us to map not only individual decisions but also to see the collective impact of several decisions. The outcome is then used to inform the resources and capacity we will need if we are to translate the decisions in to action.

11 We have shown this diagrammatically below.

M4 - Chief Operating Officer’s Report` - GMC · 2018-03-14 · Council meeting, 23 February 2017...

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