General Medical Council Annual Report 2021 Trustees annual report and accounts for the year ended 31 December 2021
General Medical Council Annual Report 2021 Trustees annual report and accounts for the year ended 31 December 2021 Presented to Parliament pursuant to section 52A of the Medical Act 1983 as amended by The Health Care and Associated Professions (Miscellaneous Amendments) Order 2008 (SI No.1774).
14 Our annual report 2021 General Medical Council
About this report
Our trustees present this report and financial statement for the year ending 31 December 2021.
They confirm they have taken into account the Charity Commission’s public benefit guidance when reviewing our aims and objectives and have had regard to this guidance when exercising any powers or duties or when making a decision to which the guidance is relevant. The trustees are satisfied that at all times we have operated for public benefit and that the activities as described in this report and accounts fully meet the public benefit requirements and support our charitable purpose.
General Medical Council i
Contents
| Foreword from the Chair and Chief Executive | 01 | |
|---|---|---|
| Our role in the UK’s healthcare systems | 04 | |
| 2021 at a glance | 06 | |
| Delivering on our strategy | 21 | |
| Enabling professionals to provide safe care | 24 | |
| Developing a sustainable workforce | 33 | |
| Making every interaction matter | 44 | |
| Investing in our people | 48 | |
| Corporate social responsibility | 51 | |
| Our structure, governance, and management | 54 | |
| 2021 fnancial review | 65 | |
| Audit and Risk Committee report | 71 | |
| Independent auditors’ report to the trustees of the GMC | 76 | |
| Accounts 2021 | 81 | |
| Reference and administrative information | 114 | |
General Medical Council ii
Foreword
2021 continued to put our healthcare systems under severe strain. Two years into the COVID-19 pandemic, healthcare professionals were still delivering excellent care under exceptionally difficult circumstances. Some tragically lost their lives, and that loss is deeply felt.
We have seen health services and healthcare workers adapt and innovate rapidly to do the best they can for patients, and their compassion and dedication has been remarkable. But that has taken a toll on doctors’ health and well-being. The acute emergency of COVID-19 has now given way to a sustained pressure, and with that come new, longer-term challenges. Our 2021 The state of medical education and practice in the UK (SOMEP) report underlined this, with doctors telling us of increasing workloads, fatigue, and burnout, and 23% indicating that they intended to leave the profession.
For doctors to thrive and provide the best patient care, we need inclusive, supportive work environments and compassionate leadership that puts doctors’ well-being – and the positive effect it has on patient safety – to the fore. The advantages for patients are clear. Inclusive, communicative teams in which doctors are comfortable asking for help and expressing concerns provide the safest care and create environments where teams learn from mistakes. The GMC has a key role in working alongside employers and doctors to create those environments.
Much or our work in 2021 focused on providing that support at a difficult time for healthcare services across the UK.
In postgraduate training, we approved derogations to curricula so that doctors in training could progress safely and flexibly during the pandemic and, as part of our enhanced monitoring process, we took decisive action to protect patients and doctors in training, including working with health education authorities to remove trainees from training environments where necessary. In undergraduate education, we supported medical schools in making decisions about graduating students whose studies had been disrupted as a result of the pandemic, and continued the rollout of our proactive education quality assurance process to make sure schools maintain the quality of the training they offer even in challenging circumstances.
To reduce pressures on doctors and employers, we rescheduled revalidation submission dates, and worked with colleagues across the system to discuss how appraisals could be used to support doctors to think about and process their experiences of working through the pandemic. In addition, we have taken a flexible and proportionate approach to investigations, knowing that some employers, doctors, and other organisations may take longer to assist with our investigations during this pressurised time, meaning some cases could progress more slowly.
It was also important to us to reassure doctors that we know they are still working in exceptional circumstances. So, we issued updated guidance for decision makers on taking the current context into account when considering complaints. During the winter of 2021 we also launched a campaign of support, reassurance and recognition, in anticipation of seasonal pressures on our health services.
01 General Medical Council
Foreword
The pandemic also had an impact on our work to support the development of a more sustainable workforce. Enabling international medical graduates to join our health services is essential, and in 2020 this flow was heavily impacted by travel restrictions and social distancing. In order to address this, we opened a second clinical assessment centre, bringing testing capacity back to pre-pandemic levels so that more new doctors can join the UK medical workforce. As a result, over 10,000 international medical graduates joined the UK medical register in 2021.
While significant challenges remain, there are also opportunities that should be embraced. Our 2021 SOMEP report evidenced that supportive, collaborative cultures had improved across healthcare teams. We also saw our health services adapt and innovate rapidly. These are things we must learn from and build upon for the future: the benefits are clear, for both patients and doctors.
2021 was also the year in which we committed to targets to tackle racial inequalities in medicine, working with partners across healthcare services to lay foundations for improvements in fairness.
We know that doctors from ethnic minority backgrounds, or who qualified outside the UK, are significantly more likely to be referred to us by their employers, and that they also face barriers when it comes to medical education and training. Beyond the obvious need to address a situation that is fundamentally unfair, with just under 65% of new doctors identifying as being from a mixed, Black, or Asian ethnic minority background, our health services will not be able to retain the professionals they need, let alone enable
doctors to fulfil their potential and maximise their contribution, if we do not offer them the support and inclusivity they should rightly expect. We have identified two targets in this respect: we want to see the end of inequality in referrals by 2026 and in educational attainment by 2031.
These are ambitious targets, and we cannot achieve them alone, so we will continue to engage and work with employers, educators, and other stakeholders to deliver real change. As part of this work, we are also reviewing the fairness of our own processes.
As we look ahead, there are fundamental changes on the horizon for medical regulation.
We expect legislative reforms to empower us to be a more flexible and responsive regulator, one that can deal with complaints more quickly and reduce stress for everyone involved. We will also be able to streamline our registration processes to sustain a steady flow of new doctors into the UK’s healthcare systems. We will have new powers linked to education and training, so we can support medical professionals through their studies and career. In a historic move for medical regulation, legislative reforms will also bring two new professional groups under our regulatory umbrella: physician associates (PAs) and anaesthesia associates (AAs). PAs and AAs are pivotal to healthcare teams. Our planning to bring these groups under our regulation has been informed by productive engagement with PAs, AAs, and other healthcare professionals and we look forward to continuing to develop these relationships.
General Medical Council 02
Foreword
We also made further preparations to introduce a new assessment for doctors wishing to join the medical register – the Medical Licensing Assessment. Graduates who pass the assessment will have demonstrated they meet an agreed standard of proficiency – giving patients, employers, and fellow doctors greater confidence in their competence and their skills, wherever they trained. We must also look ahead to our review of Good medical practice , the core guidance that outlines the values, knowledge, and behaviours we expect from members of the profession. It underpins not only doctors’ practice, but also their education and training, and is at the heart of what it means to be a good doctor.
There is much to do towards recovery, renewal, and reform as we emerge from the most acute phase of the pandemic, but as this report sets out, we have made considerable progress in what was year one of our five-year corporate strategy.
Our role is to make sure medical professionals continue to be trained and supported to deliver the safest and most effective care to patients and the public. We are confident that we remain on course to play this role, working with doctors, employers, and educators to protect and promote patient safety across the UK.
Charlie Massey, Chief Executive
Professor Dame Carrie MacEwen, Chair
03 General Medical Council
Our role in the UK’s healthcare s stems y
We are the UK’s independent regulator of doctors. Our role is to protect the health, safety, and well-being of patients and the public. We do this by:
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promoting and maintaining professional standards for doctors
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overseeing UK medical education and training
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taking action when the safety of patients or the public’s confidence in doctors is at risk.
How we keep patients safe
Keeping patients safe and protecting public confidence in doctors is at the core of our work.
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We set the standards for doctors. Our standards define what makes a good doctor. They set out the professional values, knowledge, skills, and behaviours required of all doctors working in the UK. To develop our standards and guidance, we consult with patients, doctors, employers, and educators.
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We oversee all stages of doctors' undergraduate and postgraduate education and training in the UK. We make sure doctors get the education and training they need to deliver high-quality care throughout their careers. We do this by setting out the outcomes needed for graduates and by approving curricula for postgraduate education. We also monitor training environments to support safe, effective learning.
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We manage the UK medical register. We check doctors’ qualifications before they join the register. When necessary, we check their skills. We also check with medical schools or previous employers to find out if they have any concerns about a doctor’s ability to practise safely.
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We make sure doctors keep their knowledge and skills up to date. We do this through revalidation, a system that checks that all doctors have an annual appraisal and that they are following the standards we set. Revalidation is a fundamental part of clinical governance. It gives patients and the public assurance that doctors in the UK are part of a governed system. It also supports the identification and management of concerns at an early stage.
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We investigate and act on concerns about doctors. When someone raises a concern about a doctor with us, we assess whether it meets our threshold for investigation. If it does, we investigate. At the end of the investigation, we decide what action we need to take. This can include taking no action, issuing advice or a warning, or agreeing that the doctor will restrict their practice, retrain, or work under supervision. In some situations, we refer the case to the Medical Practitioners Tribunal Service (MPTS).
The MPTS is independent in its decision making and operates separately from the investigatory role of the GMC. It produces its own separate annual report.
General Medical Council 04
Our role in the UK's healthcare systems
Our performance
Every year, the Professional Standards Authority assesses our performance as a regulator across our four core functions: education and training, registration, guidance and standards, and fitness to practise.
Its latest annual assessment confirmed that we successfully met all 18 of its Standards of Good Regulation in 2020–2021. This means we are performing to a high standard as a regulator. It also reflects the commitment we make in our work to standards such as:
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transparency
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public protection
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equality, diversity, and inclusion
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timeliness.
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General standards
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out 5 of 5 Registration out 4 of 4
Guidance and standards Education and training out out 2 of 2 2 of 2 Fitness to practise Total standards met out out 5 of 5 18of 18
05 General Medical Council
2021 at a glance IJ General Medical Council 06
2021 at a glance The medical register
All figures as of 31 December 2021 (or 2020) unless otherwise specified. Visit GMC Data explorer to learn more about doctors’ education and practice in the UK.
Total doctors on the register[*]
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335,596 +4.4% 350,449
2020 % change 2021
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Where they graduated
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59.7%
209,024
had a UK primary
medical qualification .
37,003
10.5%
graduated in the European
Economic Area (EEA) or in
Switzerland .
29.8%
104,422
had a qualification from
the rest of the world .
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- Including doctors with temporary emergency registration (TER) – see pages 10 and 37 for more information.
07 General Medical Council
2021 at a glance
Doctors on the register by location[*]
Doctors on the register by ethnicity
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97,241
(29.7%) Asian or
Asian British
264,344
(75.4%) were
based in England. 18,426
(5.3%) Black or
Black British
8,672
(2.5%) of mixed
background
180,542
(51.6%) white
8,396 (2.4%)
were based in 25,650
Northern Ireland.
(7.3%) were based
13,341 in Scotland.
17,246
(3.8%) were
based in Wales. (4.9%) other
ethnic groups
38,718 (11.1%)
were based outside the 28,322
UK or did not provide us (8%) did not
with enough information provide
to establish their location. information on
their ethnicity
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-
The derived location of registered doctors is calculated using the following hierarchy:
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where they work based on NHS practice history data
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their training location based on the National Training Survey
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the location of their designated body
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their registered address.
Registered doctors located in the Channel Islands and the Isle of Man are included in the figures referring to England.
General Medical Council 08
2021 at a glance
Doctors on the register by gender
| Men | Women | ||
|---|---|---|---|
| UK | 53.3% | 46.7% | |
| England | 52.5% | 47.5% | |
| Northern Ireland | 49.2% | 50.8% | |
| Scotland | 47.9% | 52.1% | |
| Wales | 55% | 45% |
Total doctors on the GP Register[*] Up from 2020 ( 77,659 ) 2.6 % 79,685 ................................................................................................... 64,676 (81.2%) were residing in England . 3,284 (4.1%) were residing in Wales . 2,204 (2.8%) were residing in Northern Ireland . 2,064 (2.6%) either were located outside the UK or did not provide 7,457 (9.4%) were residing in Scotland . us with enough information to establish their location. Total doctors on the Specialist Register[*] Up from 2020 ( 104,383 ) 2.5 % 107,009 ................................................................................................... 80,920 (75.6%) were residing in England . 4,136 (3.9%) were residing in Wales . 2,577 (2.4%) were residing in Northern Ireland . 11,046 (10.3%) either were located outside the UK or did not provide 8,330 (7.8%) were residing in Scotland . us with enough information to establish their location.
- Including doctors with temporary emergency registration (TER) – see pages 10 and 37 for more information.
09 General Medical Council
2021 at a glance
Temporary emergency registration
As part of its response to the COVID-19 pandemic, in 2020 the UK Government asked us to give temporary emergency registration (TER) to doctors who had left the register in recent years. A number of these doctors played a valuable role in patient care and vaccine rollout during the pandemic. The UK Government has since asked regulators to close TER in September 2022.*
As of 31 December 2021, 22,718 doctors on our register held TER with a licence to practise.
That is
10.2% fewer than at the same date in 2020.
TER doctors by where they graduated
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15,575 had a UK primary
medical qualification .
68.5%
22.3%
9.2%
2,082 had graduated in the EEA
or in Switzerland .
5,061 had a qualification from the
rest of the world .
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5,061 had a qualification from the
rest of the world .
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TER doctors by location
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18,642 656
(82%) were residing (2.9%) were residing
in England . in Northern Ireland .
201 2,194 1,025
(0.9%) were based outside the UK or did not provide (9.7%) were residing (4.5%) were
us with enough information to establish their location. in Scotland . residing in Wales .
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- For more information on temporary emergency registration, see page 37.
General Medical Council 10
2021 at a glance
In 2021, we granted:
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7,377 2,591 10,009
(36.9%) were (13%) were from (50.1%) were
19,977
from doctors doctors who from doctors with
applications for first
with a UK PMQ . graduated a qualification
entry to the register.
in the EEA or in from the rest of
Switzerland . the world .
That is up
13.7 %
from 2020 - ( 17,234 ).
.........................
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2,299 191 836 (69.1%) were (5.8%) were (25.1%) were 3,326 from doctors from doctors from doctors with applications to join the with a UK PMQ . who graduated a qualification GP Register. in the EEA or in from the rest of Switzerland . the world . That is up 10.7 % from 2020 ( 2,970 ).*
2,959 680 974 (64.1%) were (14.8%) were (21.1%) were 4,613 from doctors from doctors from doctors with applications to join the with a UK PMQ . who graduated a qualification Specialist Register. in the EEA or in from the rest of Switzerland . the world . That is down 3.1 % from 2020 ( 4,755 ).*
11 General Medical Council
2021 at a glance
Professional and linguistic assessments board (PLAB)
Doctors who graduate outside the UK, the EEA, or Switzerland usually need to take our Professional and Linguistic Assessments Board (PLAB) test in order to join the UK medical register.* The test is taken in two parts (PLAB 1, delivered in assessment centres around the world, and PLAB 2, undertaken in one of our testing centres in Manchester).
PLAB 2
PLAB 1
PLAB 1 PLAB 2 In 2020 and 2021 our capacity to deliver PLAB 1 tests around the world was severely impacted due to the rise in COVID-19 cases across the globe. In many cases we were forced to cancel testing due to local restrictions and in the interest of safety. This resulted in 10,431 8,648 candidates took PLAB 1 in 2021, a very similar number to 2020 (10,601). increase on 2020 (3,654). We appreciate that the challenges with the delivery of PLAB 1 have been frustrating for candidates. We have been working hard to increase the availability of PLAB 1 places, and hope that the vaccine rollout will allow us to welcome more doctors to UK practice soon.
In 2021 we made significant investments to increase PLAB 2 examination capacity following the pandemic, including the creation of a second PLAB 2 circuit in Manchester.[†]
candidates taking PLAB 2 in 2021, a 136.7% increase on 2020 (3,654).
- Exceptions to this include international medical graduates joining the register based on being sponsored by healthcare organisations, or based on postgraduate qualifications. In both these cases, doctors must still provide evidence of their competence and skills. For more information on the different routes to join the register, see www.gmc-uk.org/registration-and-licensing/join-the-register/before-you-apply/evidence-to-support-your-application.
- See page 37 for more information.
General Medical Council 12
2021 at a glance
Setting and maintaining standards
Revalidation
Every licensed doctor who practises medicine in the UK must prove they are meeting our standards every five years through a process called revalidation. Revalidation supports doctors to develop their practice, drives improvements in clinical governance, and gives patients confidence that doctors are fit to practise.
As part of our response to the pandemic, in 2020 and 2021 we postponed revalidation submission dates for around 60,000 doctors, helping healthcare settings cope with system pressures by making sure doctors could spend as much time as possible providing care.
In 2021 we received 65,893 recommendations for revalidation.
55,488 of the recommendations were submitted by designated bodies located in England .
were submitted by designated 2,100 bodies located in Northern Ireland .
were submitted by designated 5,125 bodies located in Scotland .
3,035 were submitted by designated bodies located in Wales .[*]
53,322 doctors were revalidated in 2021.[†]
44,778 were located in England . 1,580 were located in Northern Ireland . 4,152 were located in Scotland . 2,327 were located in Wales . 485 either were based outside the UK or did not provide us with enough information to establish their location.
We made decisions on 98.2% of the total recommendations we received in 2021 within 5 working days from when we received them, exceeding our target of 95%.
We approved deferral of 11,041 revalidation submission dates for 11,041 doctors.
We withdrew the licences of 398 398 doctors on our register.[‡]
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The remaining 145 are not associated to a specific location as they are the result of administrative processes necessary to consolidate data.
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Depending on where they work, single doctors can receive more than one recommendation.
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If a doctor does not fulfil the requirements of revalidation, provides fraudulent information, or fails to provide reasonably requested evidence, we can legally withdraw their licence. This process is different to that of being removed from the register, for example, following an MPTS hearing.
13 General Medical Council
2021 at a glance
Outreach
Our outreach teams delivered training on our standards to:
That is up 16,974 73.6% doctors in 527 from 2020 (9,776). sessions and
That is up 8,218 9.2% students in 71 from 2020 (7,529).[] sessions* across the UK.
Our standards enquiry team answered:
That is down 613 18.9% enquiries about from 2020 ( 756 ). our guidance.
Around 54% of the enquiries were from doctors (2020: 65%)
93% of the doctors and 93% of the students who attended one of our outreach workshops across the UK said their knowledge of the GMC’s role and standards improved .
84% of the doctors and 87% of the students who attended a session across the UK said it had improved their impression of the GMC .
12% were from others, 34% from including staff from members of professional organisations, the public students and the police (2020: 22%) (2020: 13%).
Our outreach teams also deliver workshops aimed at helping doctors who are new to UK practice adjust to working in the UK’s healthcare systems.
The team delivered 208 Welcome to UK Practice workshops in 2021, involving 6,471 doctors – up 72% from 2020 ( 3,762 ).[†]
Our employer liaison advisers held
Our employer liaison They also provided advisers held fitness to practise 1,284 advice in relation to meetings with 2,205 doctors. responsible officers.
- We have seen a smaller increase in student engagement due to the continued disruption in higher education caused by the ongoing pandemic.
† See page 31 for more information.
General Medical Council 14
2021 at a glance
Overseeing medical education and training
Quality assurance
We regulate all stages of a doctor’s undergraduate and postgraduate education and training in the UK. We set standards and expected outcomes, and we carry out quality assurance (QA) work to make sure standards are maintained.
Our undergraduate and postgraduate QA processes promote and encourage local management of concerns about the quality and safety of medical education and training.
At the onset of the pandemic in 2020, we had to suspend education QA visits temporarily for safety reasons. Later in the year, we were able to resume them virtually, and in 2021 we were able to significantly increase the number of visits.
In 2021 we carried out That is up 165 of the visits were in England . 6 of the visits were in Northern Ireland . 208 136% 24 of the visits were in Scotland . education QA visits. from 2020 ( 88 ). 13 of the visits were in Wales . 154 of them were QA visits to new medical schools, established medical schools, or clinical environments where medical education and training take place. 54 of them were enhanced monitoring visits , aimed at promoting the resolution of concerns about the quality of postgraduate training locally.
From our QA visits, we found: 19 areas of good practice or working well . 21 areas where our standards were met , but where we identified improvements that could be made. 18 areas that required improvement . [*] As a result of our enhanced 9 cases relating to postgraduate education were escalated to monitoring visits: our enhanced monitoring process . 10 enhanced monitoring cases escalated previously were resolved .
In order to make sure postgraduate training We also supported medical schools in making could continue even if affected by the decisions about graduating students whose pandemic, we worked with partners to apply studies had been disrupted as a result of some changes to curricula and exams. the pandemic. By the end of 2021, we had approved 80 derogations to training curricula and temporary changes to 114 examination components .
- Not all QA visits lead to specific findings like those listed here – in some cases nothing of significance is found, as nothing has changed since the previous visit, or nothing has been found worthy of particular note (ie. education and training are working as expected).
15 General Medical Council
2021 at a glance
Supporting the people we serve
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In 2021 our Corporate It also logged This is a
review team received This is a 6,543 100.9%
1,884 2.3% compliments . increase on
complaints about decrease on 2020 ( 3,257 ). []
our service. [] 2020 ( 1,928 ).
In 2021 our patient liaison service held 285 meetings with patients who had raised a concern with us.
of those who attended one of our patient meetings were
88%
satisfied or very satisfied with the patient meeting experience.
agreed or strongly agreed that patient liaison staff showed empathy
96%
for their situation.
agreed or strongly agreed that they were satisfied that their concerns had
92%
been understood during the meeting.
agreed or strongly agreed that the meetings helped them to understand what
95%
action the GMC could take.
Our contact centre answered The contact centre also handled
162,504 77% 65,178
calls and of the calls and emails we webchat sessions.
131,157 received were from doctors, and
emails or letters. 23%
from members of the public
and others.
......................
.................................... ....................................
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- This significant increase is also partially due to efforts we made to make sure colleagues consistently capture and record the compliments we receive.
General Medical Council 16
2021 at a glance
Investigating and acting on concerns
Concerns raised
concerns were raised with us in 2021. 9,074 62.7% 2.2% 4.2% 2.8% 28.2%
This represents a 7.2% increase on 2020 (8,468 concerns).
5,685 were raised in relation to incidents that happened in England . That is a similar percentage to 2020 (62%).
199 were raised in relation to incidents that happened in Northern Ireland – a slightly higher percentage than in 2020 (1.8%).
381 were raised in relation to incidents that happened in Scotland – a slightly lower percentage than in 2020 (4.9%). 253 were raised in relation to incidents that happened in Wales – around the same percentage as in 2020.
For 2,556 of them either there was no incident location specified, or they happened outside the UK – a similar percentage to 2020 (28.5%).
17 General Medical Council
2021 at a glance
Percentage of concerns raised by the public
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74.8% 2021
74.6% 2020
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72.2% 70.7% 50.3% 54.7% 70.6% 70.2% 60.9% 66.8% 84.4% 85.9%
Of the 9,074 concerns that were raised with us in 2021, 74.8% were raised by patients or members of the public. That is very similar to 2020 (74.6%).
The percentage of concerns relating to incidents that happened in England raised by the public was 72.2% (a slight increase from 70.7% in 2020).
In Northern Ireland , it was 50.3%, (a decrease from 54.7% in 2020).
In Scotland , it was 70.6%, (similar to 2020 - 70.2%).
In Wales , it was 60.9% (a decrease from 66.8% in 2020).
84.4% of the concerns we received with no location specified or having happened outside the UK were raised by the public (a slight decrease from 85.9% in 2020).
Investigations
Not all the concerns raised with us meet our threshold for an investigation. Sometimes a concern is best dealt with at a local level or by having a conversation with the doctor, or should be brought before another organisation. We only take action where we find there may be a risk to patient safety or to public confidence in doctors.
925
( 10.2% ) of the concerns we received in 2021 met our
214 That is a lower ( 23.1% ) referred to That is a lower percentage than in concerns raised by percentage than in 2020 ( 12.3% ). members of the public . 2020 ( 28.1% ).
statutory threshold for investigation .
General Medical Council 18
2021 at a glance
Outcomes of investigations
569 of the investigations we concluded in 55.2% 2021 were concluded with no action. In 257 cases we referred the case to the 24.9% Medical Practitioner Tribunal Service. 8.4% In 87 cases we issued warnings. 6.5% In 67 cases the doctor agreed undertakings. 5% In 51 cases we issued advice.
Provisional enquiries
In certain cases, we make provisional enquiries, where we look at information at an early stage of a case, to provide swifter resolution for patients and doctors. If the evidence shows there is no future risk to patients, and regulatory action is not required, we will not move to a full investigation. For cases where we have concerns about patient safety, we will carry out a full investigation.
490 382 ( 5.4% ) of the concerns That is a higher of these ( 78% ) referred That is a similar we received in 2021 percentage than in to concerns raised by percentage were considered under 2020 ( 4.9% ). members of the public. to 2020 ( 77.3% ). provisional enquiry . In In In 333 64 93 cases ( 68% ) we closed cases ( 13% ) we progressed cases ( 19% ) the provisional the provisional enquiry with the case to investigation . enquiry was still open as of no action . 31 December 2021.
19 General Medical Council
2021 at a glance
Outcomes of Medical Practitioners Tribunals Service tribunals
In 2021, the Medical Practitioners Tribunal Service held a total of 269 tribunals.
| 33.8% | In 91 of them, the tribunal suspended the doctor who had been referred to the tribunal. |
|---|---|
| 26.4% | In 71 cases the tribunal found no impairment. |
| 21.6% | In 58 cases the doctor was removed from the register. |
| 10.4% | In 28 cases, while the tribunal found no impairment, it issued a warning. |
| 5.2% | In 14 cases the doctor had conditions put on their practice. |
| 1.5% | In 4 cases doctors voluntarily removed themselves from the register. |
| 0.7% | In 2 cases the doctor’s practice was found to be impaired but no further action was taken. |
| 0.4% | In 1 case the doctor agreed to undertakings. |
Where we do not agree with the decisions In 2021 we made 10 appeals. That is 1 more made by a medical practitioner tribunal, than in 2020. 1 of the appeals we made was we can appeal them. successful, while for 9 of them, as of 31 December 2021, we did not yet have a decision.
General Medical Council 20
Delivering on our strategy
21 General Medical Council
Delivering on our strategy
Delivering on our strategy
2021 marked the first 12 months of our 2021–2025 strategy. The strategy is underpinned by our 2030 vision to be an ever more effective, relevant, and compassionate regulator – for patients, for the public, for professionals, and as an employer.
In this section of the report, we describe how we worked to achieve these goals in 2021 through various initiatives, in close collaboration with our partners.
Four main themes shape all our work:
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General Medical Council 22
Delivering on our strategy
Responding to the pandemic
Throughout the year, COVID-19 significantly impacted on our operations. As in 2020, much of our work in 2021 focused on supporting doctors, students, and employers at a particularly difficult time. As part of this:
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we introduced temporary emergency registration in 2020 for doctors who left the register in recent years. Many of these doctors, a number of whom remained active in 2021, played a valuable role in delivering patient care. Others provided vital support for the vaccination programme.
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we opened a new temporary clinical assessment centre to allow Professional and Linguistic Assessments Board tests to continue at pre-pandemic capacity, allowing more doctors to join the profession.
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we approved a number of temporary changes to education curricula to support safe and flexible progression for doctors in training.
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we supported medical schools in making decisions about graduating students whose studies had been disrupted as a result of the pandemic.
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we rescheduled revalidation dates to ease pressure on doctors and their employers.
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we issued a joint statement with other professional regulators, assuring health and social care staff that we understood and would consider the contextual challenges caused by the pandemic when making decisions about fitness to practise or revalidation.
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we introduced new guidance for decision makers in fitness to practise, taking into account the circumstances and challenges brought about by the pandemic.
Equality, diversity, and inclusion
The pandemic also highlighted longstanding inequalities, including the impacts of racial discrimination and disadvantage.
We are fostering equality, diversity, and inclusion (ED&I) in everything we do as a regulator and employer. Tackling discrimination and inequality is the right and fair thing to do. It is also vital to helping retain doctors working in the UK and to supporting high-quality patient care. So, we have embedded ED&I into each aim of our strategy.
Reflecting this, in February 2021 we committed to achieving specific targets to tackle racial inequalities. We want to eliminate inequalities in fitness to practise referrals by 2026 and in student attainment based on race or other factors linked to ethnicity by 2031. We cannot achieve these targets alone as improvement relies on wider, systemic change. So during 2021, we worked with different partners across the UK’s healthcare systems to start laying the base for these improvements.
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Delivering on our strategy
Enabling professionals to provide safe care
Research shows that healthcare professionals who work in supportive environments where well-being is a priority are better able to give patients safe, high-quality care. We work with partners to improve working environments and cultures, making them supportive, inclusive, and fair for medical professionals. As a result, patients will benefit from safer and better care and the profession will keep and attract more professionals. We also continue to work with patients and medical professionals to make sure our guidance remains relevant and effective and that it represents patients’ diverse needs. We addressed this aim in 2021 through a number of initiatives.
Updating our guidance
Reviewing Good medical practice
Good medical practice is the core guidance that all doctors working in the UK must follow. It shapes the way they care for patients by describing the values and behaviours they need to show.
We published the current version of Good medical practice in 2013. Since then, patients’ expectations and the way healthcare is delivered have changed. We are also preparing to take on the regulation of physician associates (PAs) and anaesthesia associates (AAs). So we are reviewing the guidance to make sure it meets patients’ needs and supports the medical professionals we regulate to provide safe, high-quality care. There are four main areas where we propose to update the guidance:
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patient-centred care, decision making, and communication with patients
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tackling bias and discrimination in the treatment of patients and professionals
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working effectively with colleagues
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leadership and organisational culture.
Since we started the review:
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we have invited doctors, patients, and other stakeholders to sign up to our community of interest. They will receive updates about the review and help to shape our work.
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we have undertaken scoping to develop an evidence base including: researching findings from recent reviews and public inquiries, gaining insights from PAs and AAs on the interim standards, and reviewing intelligence gathered from targeted engagements with stakeholders.
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we have commissioned research on how our guidance is currently used by doctors and other healthcare professionals.
To help with the review, we also set up an advisory forum. The forum acts as a sounding board for key decisions around the review and the changes we are planning to make. Its 12 members bring a wealth of expertise in areas such as medical ethics, patient care, multi-disciplinary working, and equality and diversity.
We expect to complete the review and publish a new version of Good medical practice in 2023. During 2022, we will consult with doctors, patients, employers, and other stakeholders in the UK’s healthcare systems. We have also commissioned an external behavioural insight specialist to research and engage with over 200 patients with experience of the healthcare system. Inputs from these activities will help us decide what changes we need to make.
General Medical Council 24
Delivering on our strategy
It is our ambition that the new edition of Good medical practice better reflect the needs and expectations of patients, service users, and carers and the context in which medical practitioners work. It will support professionals to work in partnership with the people they care for, and to navigate the challenges of delivering high-quality, person-centred care in a service under pressure. We will also strengthen duties around equality, diversity, and inclusion. We hope the changes will help make workplace culture safer and more responsive for patients, and our health services more inclusive, fair, civil, and compassionate for all.
Updates to our ethical hub
Our ethical hub is a collection of online resources exploring how to apply our guidance in practice. It focuses on areas which doctors often ask about or find challenging. The resources include case studies, decision tools, flowcharts, and videos. They are all designed to support doctors with common ethical scenarios, such as adult safeguarding, trans healthcare, and caring for people with learning disabilities.
In 2021, we made several changes to the hub. In particular:
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we updated the style of our menus, which has resulted in increased engagement with our learning materials
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we updated our Professional and Linguistic Assessments Board test guidance in light of the pandemic
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we published new content regarding identifying and tackling sexual misconduct
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we provided additional information on remote consultations
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we added more information about our upcoming regulation of PAs and AAs
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we improved our decision-making flowchart, complementing our updated guidance
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we updated our advice in relation to COVID-19, simplified the information available and added detailed information about vaccination.
In 2021, the hub pages maintained a high volume of visitors. Keeping the pages up to date has contributed to this retention rate. For example, during 2021, our COVID-19 hub saw a total of 78,153 page views, showing the importance of keeping our data accurate and regularly updated as a useful reference point for doctors aiming to provide safe, effective care.
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Delivering on our strategy
Prescribing
In February 2021, we published our updated Good practice in prescribing and managing medicines and devices guidance. The new guidance came into effect on 5 April 2021. We updated it after a call for evidence on remote consultations and prescribing that launched in 2019. We wanted to understand if our guidance was keeping pace with changes in this area. The new guidance also responds to the surge in remote consultations we saw in recent years. This rise has only been increased by the onset of the pandemic.
We received 75 responses to our consultation from individuals and organisations with experience in this field. These responses helped us to shape the update.
The guidance provides updated advice on both face-to-face and remote prescribing. It is vital that
the principles of good practice apply whether in a face-to-face or a remote setting. We also produced some common scenarios to support the guidance.
The updated guidance was received very positively. Five days after it was launched it had already been downloaded almost 5,000 times.
The new guidance helps prescribers to understand their responsibilities. In turn, this helps them to prescribe in a safe, informed way. It supports doctors who are navigating what for many has become a new reality of remote medicine, helping them maintain good patient care amid challenging circumstances.
General Medical Council 26
Delivering on our strategy
Working with partners to identify and address risks to patient safety
Maternity care
Maternity is a complex area of medicine that requires teamwork across disciplines. When things go wrong, the impact can be tragic. It is also an area that has markedly worse outcomes for women from ethnic minority backgrounds.
The issues and concerns in the UK’s maternity services are well documented and go back at least two decades – with several high-profile cases, various reviews and inquiries, reports from other regulators, maternity services featuring regularly in both national and regional joint services oversight groups, and various maternity-specific efforts nationally and locally.
There is a significant amount of work going on across providers, regulators, and others to understand and improve maternity care. We have been working with partners to understand and act on concerns and to help improve the culture in maternity departments.
Sharing data and insights
sharing our maternity data and insights to help identify risks early, increase cohesion between regulators, and address emerging issues. As part of this, we are currently working with the Nursing and Midwifery Council (NMC) and the Care Quality Commission (CQC) on a shared data platform to explore measures that might help identify struggling maternity departments.
Improving workplace cultures
Our outreach teams have been engaging with the National Health Service England/Improvement (NHSEI) Culture Working Group and regional perinatal oversight groups to shape and improve maternity culture. Our current focus is joint work with the NMC, Health Education England (HEE), and NHSEI to develop our guidance and deliver Professional Behaviour and Patient Safety (PBPS) sessions for targeted maternity units. The sessions can be delivered face to face or virtually, with content focusing on maternity care. We are now working with NMC and Regional Chief midwives to deliver PBPS sessions in all regions in England over 2022.
In collaboration with the NMC and Regional Chief Midwives, we have also been delivering joint regional events to maternity professionals, for example, on duty of candour.
Across UK healthcare, governments, providers, regulators, and others are committed to building, understanding, and acting on data and insights. We share that commitment and are taking an increasingly collaborative approach – including
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Delivering on our strategy
Monitoring and addressing emerging risks
We continue to engage with the National and Regional Joint Strategic Oversight Group (JSOG) framework in England. The framework provides a forum for healthcare regulators, NHS England, and NHS Improvement to share and discuss intelligence on emerging risks to patient safety and to develop common approaches to address them. The other partners in the framework include the Care Quality Commission, Health Education England, and the Nursing and Midwifery Council.
In 2021, we contributed to discussions at a national level on the quality of training and on leadership. At a regional level, we continued to work with other regulators and stakeholders to share data and intelligence. We also continued to oversee and address areas of emerging risk.
Engaging with doctors, students, and other partners to promote safe care
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Thank you both very much for such a fantastic workshop yesterday. The trainees were enthusiastic and learned a lot from the case scenarios and discussion.
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Training programme director
Our outreach teams and colleagues from our education quality assurance teams meet with doctors, students, employers, educators, and other partners in the UK’s healthcare systems to:
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improve understanding of our role and the support we offer
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promote and support excellence in medical education and practice
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identify and address risks to patients before harm occurs
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monitor the quality of medical education, working with partners to address challenges in training environments
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support employers in delivering revalidation, addressing and managing concerns about doctors, and strengthening training environments
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support the continuous development of local clinical governance systems to maintain and improve patient care.
In 2021, our regional and national liaison advisers held just under 600 interactive workshops, involving around 17,000 doctors and 8,200 students. The majority of the workshops were held online due to the ongoing pandemic. The ethical topics most frequently covered included decision making and consent, raising concerns, and confidentiality. Our employer liaison advisers also held over 1,200 meetings with responsible officers. In these meetings, they discussed our handbook for effective clinical governance for the medical profession and how it can help strengthen local systems. They also provided fitness to practise advice in relation to just over 2,200 doctors.
Our efforts in this area enable us to work with doctors and other partners to protect and promote patient safety in different ways. In the following pages are some examples of how our liaison advisers have responded to requests from our partners to contribute to their programmes of work.
General Medical Council 28
Delivering on our strategy
In England , we have done significant work to support doctors at the start of their career.
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We collaborated with NHS England, NHS Improvement, and HEE to design and implement the Midlands Charter. The charter aims to support doctors in training.
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We contributed to the design of NHS England’s standardised induction.
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Just the fact that you're reaching out to individual universities to hold sessions for students shows you really care.
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Student attending an outreach session
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We contributed to HEE’s returners induction pilot.
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We participated in NHS Professionals’ Doctors Gateway programme. The programme aims to help UK doctors who studied in the EU gain experience to develop a career in the UK.
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Great reminder that everyone is responsible for patient safety and that the standard you walk past is the standard you accept.
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Doctor attending an
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outreach session
In Northern Ireland , we provided educators and doctors in training with advice on ethical scenarios. We also provided information on our fitness to practise work. The work included:
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a session regarding student fitness to practise (FTP), attended by staff from both medical schools in Northern Ireland. The session helped academic staff understand how we make FTP decisions. It was a well-attended event and feedback was very positive.
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a session involving over 100 GPs in training. The session focused on raising and acting on concerns, and on appropriate use of social media. The training was well received, so we will continue to run it in 2022.
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Delivering on our strategy
In Scotland , we engaged with partners to promote our work on equality, diversity, and inclusion.
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We piloted a half-day workshop around the findings from Fair to refer? and our commitment to eliminate differentials in FTP referrals and in attainment. The workshop was hosted by the NHS Grampian Health Board. As part of it, participants discussed local case studies and how implementing recommendations could help address issues.
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Following concerns expressed in NHS Scotland North about the expectations on fulfilling the requirements of the Recognition and Approval of Trainers scheme during the pandemic, we ran a session to reassure trainers about our expectations regarding the scheme and how the GMC has sought to support them and trainees during the pandemic.
In Wales , we engaged with doctors in training around different topics.
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We ran tailored interactive sessions with GP trainees in the Bridgend GP Training Scheme network. The sessions focused on decision making and consent, remote consultations, addressing unprofessional behaviour, and the use of social media during lockdown. They also sought to clarify some aspects of our FTP work.
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We developed a bespoke induction programme for IMG doctors at Aneurin Bevan University Health Board. The pilot was a great success and had 100% positive feedback. We covered an introduction to the GMC, key guidance topics, professionalism, and common misconceptions about our work. We plan to run two full-day induction workshops for IMG doctors every year.
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We began work to better support specialty and associate staff doctors wishing to apply for a Certificate of Eligibility for Specialist Registration. Work is well underway to embed a supportive framework for those who apply.
Thank you so much for an excellent session. The comments were all very good and I am sure the attendees went away feeling they had gained a lot. I sure did!
- Assistant Medical Director
General Medical Council 30
Delivering on our strategy
Welcome to UK Practice
In 2020, we began running online versions of our free Welcome to UK Practice (WtUKP) workshops. As the disruption caused by the pandemic continued into 2021, we expanded this approach.
The workshops are aimed at doctors new to working in the UK. They are designed to help doctors adjust to working in the UK’s healthcare systems and are delivered by our regional liaison advisers, national office liaison advisers, and by GMC associates. They cover a range of possible ethical scenarios doctors might encounter. The sessions offer advice on how to tackle them and explain how to get support. They also provide insights into aspects of the different healthcare systems across the four countries of the UK and give participants a chance to meet other internationally qualified doctors starting their career in the UK.
The online workshops received consistently positive feedback and previous evaluations have confirmed they are effective in achieving their aims. Our long-term goal is to establish
a hybrid model of engagement, combining digital engagement with traditional face-to-face engagement. We will also work with partners to make the workshops an integral part of induction programmes across the four countries of the UK.
I am extremely happy with this warm welcome organised by GMC for the new overseas trained doctors. I greatly applaud this initiative which significantly brings down the anxiety and doubts of ‘fitting in' from the minds of these IMGs.
- Doctor attending WtUKP workshop
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Attendance at Welcome to UK Practice
workshops (2014–2021) 6,471
3,692 [3,762]
2,696
1,605 [1,766]
778
293
2015 2017 2019 2021
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I was a bit nervous before about joining the NHS; however, after today's workshop I feel at ease now that I know that there will always be help whenever I need it.
- Doctor attending WtUKP workshop
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Delivering on our strategy
Equality, diversity, and inclusion: fairer referrals
In February 2021, we committed to targets to tackle long-standing racial inequalities in the medical profession. One of these is to eliminate inequality in fitness to practise referrals based on race or place of primary medical qualification by 2026. So, we are promoting more supportive and inclusive environments to ensure fair treatment. Tackling discrimination and inequality is the right and fair thing to do. It is also vital to helping retain doctors working in the UK and to supporting high-quality patient care. Our research shows more inclusive environments have better patient satisfaction and outcomes.
We cannot achieve this target alone as it relies on wider cultural change. So, we are working closely with other organisations who share our aims. In particular, we are working with employers to make sure referral processes are fair and bias free. We will also work with regulators and partners across the UK’s healthcare systems to bring about change.
To meet our target on referrals, we will engage in activities that will vary over time. This is because we need to take into account changes in the working world. Flexibility in how we reach our target means that we can adapt our approach over time. In 2021:
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we met with responsible officers (ROs)[*] to explore how they are implementing the recommendations from our Fair to refer? research and to understand any barriers they are experiencing.
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we updated our employer referral form to help ROs make sure referrals are fair and appropriate. We also engaged in conversations with ROs about the form and the new questions about referrals it asks them to consider. We will review the insights from this work to identify best practice and work to embed it more widely.
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we worked to develop and improve our feedback process for ROs about the cases they referred to us. As part of this, we ran a workshop with them to explore ways of developing, recording, and sharing feedback.
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we contributed data to the Medical Workforce Race Equality Standard , led by NHS England. Our support focused on three key areas: revalidation recommendations, postgraduate training, and fitness to practise concerns. We will continue to support this work in future. We will promote its findings as a powerful tool in measuring and driving fairness in medicine.
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we significantly expanded the number of Welcome to UK Practice workshops available, reaching more doctors. The workshops are a valuable way to help doctors new to the UK adapt to working in the UK’s healthcare systems.
For more information about our work in this area and to see how it is progressing, see our Equality, diversity, and inclusion: Targets, progress, and priorities for 2022 report.
- A responsible officer is the senior clinician in an organisation who ensures that doctors continue to practise safely and are properly supported and managed in maintaining professional standards.
General Medical Council 32
Delivering on our strategy
Developing a sustainable workforce
Safe, effective, and responsive healthcare rests on the talent, commitment, and diversity of the people providing it. The long-standing shortage of healthcare professionals in the UK poses risks to patient care. It is also a threat to professionals’ well-being and progression. Our position allows us to help shape medical education and training in ways that can better support the development of medical students and professionals. We also make sure that entry to the medical register and progression through training is fair and flexible, meeting the needs of both patients and professionals.
In 2019, we agreed with the UK’s Department for Health and Social Care that we will also start to regulate physician associates and anaesthesia associates. We welcome this development and, while the legislation to allow this is being developed for approval by the UK's different legislatures, we made significant progress on this agenda in 2021.
Assuring the quality of medical education and training
As part of our role, we regulate all stages of a doctor’s undergraduate and postgraduate education and training in the UK. We set standards and expected outcomes and we carry out quality assurance work to make sure standards are maintained.
New schools and programmes
If an institution plans to open a new medical school, or an existing school plans to establish a new programme, we conduct quality assurance to ensure they meet our standards and outcomes.
In 2021:
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we visited five medical schools that were created in England as a result of the 2017 undergraduate expansion programme who had admitted their first students (Anglia Ruskin, Aston, Edge Hill, Kent Medway, and Sunderland).
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in Northern Ireland, Ulster University admitted its first students in August 2021. We quality assure the university’s programme in accordance with our new schools process and will continue to do so in the coming years.
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in Scotland, we are quality assuring ScotGem, a graduate entry programme delivered by the Universities of Dundee and St Andrews. The programme plans to graduate its first students in 2022.
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we also visited Brunel University, one of three new schools planning to admit students in 2022. We plan to visit Worcester (Three Counties) University and Chester University, who are expected to do the same.
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Delivering on our strategy
Proactive quality assurance
Our undergraduate and postgraduate quality assurance processes promote and encourage the local management of concerns about the quality and safety of medical education and training.
In 2021, we completed the rollout of our new proactive quality assurance process. The process covers both undergraduate and postgraduate education and training and is part of our efforts to make our regulation as proportionate as possible. As part of it, every established medical school will need to declare that it meets, or is working to meet, our standards for education and training. Completing the rollout means that all the 35 UK medical schools, plus any future schools, will participate in the process.
Despite the disruption caused by the pandemic, we were also able to continue to monitor the quality of postgraduate training environments, identifying and addressing challenges to the safety of patients and doctors in training where necessary. As part of this, in one case we worked with Health Education England to temporarily suspend training in an A&E department and related acute medical specialties at Weston General Hospital. The University Hospitals Bristol and Weston Trust NHS Foundation Trust has since been taking remedial action to address the situation.
Supporting students and medical schools
We also continued to support medical schools in making decisions about graduating students whose studies had been disrupted as a result of the pandemic. We encouraged the development of enhanced induction for graduates who were also
joining a service that faced many challenges in terms of backlogs and the ongoing pandemic. We are aware that the disruption to studies will affect students in later years and we will continue to work with medical schools to ensure that only those students who are safe to practise and who can meet GMC outcomes and standards can graduate as doctors.
Investing in medical education
Flexibility in training
Doctors have long told us that training opportunities were not flexible enough. For example, if a doctor wanted to switch specialties, they had to restart training from the beginning. This could be a frustrating experience. It was also not a constructive use of professional time. In some cases, doctors left the profession entirely rather than repeat years of training.
In 2021, after careful research, we introduced some changes to make training more flexible.
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Doctors who want to change specialty and become GPs can have some of their existing skills recognised so they do not have to repeat during training.
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We facilitated improved training options for doctors who work or train less than full time.
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We introduced further flexibility in curriculum development that we agreed with colleagues and the statutory education bodies to help support doctors’ progression during the pandemic. The changes will be ongoing for as long as training continues to be disrupted.
General Medical Council 34
Delivering on our strategy
These changes and others will allow doctors to progress and grow their skills more efficiently. Our work in this area will continue into the future as we support the development of a more sustainable workforce.
Credentialling
In 2021, our Council approved our updated credentials framework. Credentialling is a process through which we will recognise a doctor’s expertise in a specific area of practice. GMC credentials will provide a proportionate and flexible training solution to address changing patient needs and safety issues. They will be approved where there is a demonstrable need for recognised standards in an area of expert practice not otherwise certified through postgraduate training. They will also provide additional regulation in areas where this can help reduce risks to patient safety. We started introducing credentials in 2019, testing how well our existing postgraduate curricula approval process worked with five early credential adopter areas. These are:
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rural and remote medicine
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liaison psychiatry
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interventional neuroradiology (acute stroke)
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pain medicine
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cosmetic surgery.
The early adopters continued to progress through our approval processes in 2021 and we are now working with them on preparing for full implementation. The updated framework reflects their feedback. It also reflects further policy development and engagement since we started
working on the credentialling process. We aim to approve the first GMC credentials in 2022.
Equality, diversity, and inclusion: fairer education and training cultures
In February 2021, we committed to targets to tackle racial inequalities, including in medical education and training.
There is evidence that students from ethnic minorities face barriers in accessing important educational resources. This makes them more vulnerable to feeling less prepared and leads to poorer educational outcomes. These students, and doctors in training from ethnic minorities and/or with primary qualifications obtained outside the UK, also have different experiences of inclusivity than white students and doctors. Negative experiences in training and in the workplace affect well-being and performance and can ultimately affect patient safety. It is right and fair that students receive an equitable footing in their training experience, regardless of background or characteristic. So we want to end differentials in medical education and training based on ethnicity and primary qualification by 2031.
Achieving change in this complex area requires significant collaboration with multiple organisations and partners. There is recognition across the board of the collective need to act throughout healthcare if progress is to be made and, in line with this, we have adapted our ask of training institutions.
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Delivering on our strategy
Educators must have stronger governance and plans in place for providing inclusive, supportive environments while assuring themselves they are making improvements. Change is needed to policy and process throughout the whole system from entry into medical education, to access to support and learning opportunities, to the design of assessments. This is a challenge reflected in broader education and society and it will require close ongoing attention.
To pursue these objectives in 2021, we provided guidance to medical royal colleges and faculties and required them to submit evidence of work to make sure assessments reflect the diversity of the trainee and patient population and that appropriate support is provided to candidates to both prepare for or recover from a high-stakes examination fail. We also supported medical schools in their work to:
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review curricula and assessment materials to better represent patients’ and doctors’ diversity
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engage with students on their experiences of racism
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develop reporting tools for concerns relating to inequalities in the education journey
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make sure recruitment and selection processes are fair and represent diversity.
Medical schools provided us with examination outcomes data that will feed into our proactive quality assurance process (see page 34). We also shared updated data with postgraduate training organisations and supported them in analysing it. Training organisations are now required to submit annual action plans demonstrating how they are addressing the attainment gaps in their regions and meeting our standards.
We are committed to building evidence on the interventions that make a real-world difference to trainee outcomes. As part of this, we partnered with Health Education England and the Royal College of Psychiatrists to pilot an examination preparation training course and to formally evaluate its impact on examination outcomes for ethnic minority trainees. This initiative will continue through 2022, with 170 trainees taking part, and will provide essential evidence on which further initiatives can be built.
Systemic changes in medical education and training are complex and require adaptability. We will continue to capture learning from this work and the work of our partners on this agenda. We will also continuously review our approach based on that learning.
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Delivering on our strategy
Managing entry to the medical register
Our new clinical assessment centre
Around half of all doctors from outside the UK who want to practise medicine in the UK’s healthcare systems need to take our Professional and Linguistic Assessments Board (PLAB) test. The test is in two parts, a multi-choice examination (PLAB 1), and a clinical assessment (PLAB 2).
PLAB 2 is taken at a clinical assessment centre (CAC), located in Manchester. The examination allows us to test doctors' clinical competence through a series of scenarios. The practical scenarios reflect real-life situations that doctors may encounter during their work in the UK.
headquarters. We opened the new temporary CAC in June 2021. The new centre brings our total assessment capacity back to pre-COVID levels. This means we have been able to welcome more doctors from all over the world to sit their exam. In 2021, we examined 8,648 candidates across both our assessment centres. 3,283 of these attended the temporary centre. Overall, 6,043 candidates were successful and have since progressed to apply to join the register. These new doctors come at a time when the medical profession and our healthcare systems need as much support as possible.
Granting temporary emergency registration as part of the response to the pandemic
As part of the national response to the pandemic, in 2020 the UK Government asked us to give temporary emergency registration (TER) to doctors who left the register in recent years. Over 35,000 doctors who had stopped practising were given TER. As of the end of 2021, around 22,000 of them still held their temporary registration. Many of these doctors played a valuable role in delivering patient care. Others were of vital support for the vaccination programme. In 2021, we remained in regular contact with this group to make sure they understood they had been re-registered, and what this meant. Their registration was intended to last for the duration of the emergency, and the UK Government has asked regulators to close it in September 2022.
In 2020, our testing capacity for PLAB 2 was severely impacted by the social distancing measures required to combat the pandemic. To overcome this, we developed an additional, temporary assessment centre at our Manchester
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Delivering on our strategy
However, more than 1,100 doctors have since decided to return from TER to full registration. This means they will remain available for work in the future. There is great value in bringing back the talents and contribution of experienced professionals both in regard to patient safety and in terms of the wider healthcare community.
Medical Licensing Assessment
We are pleased to be working in collaboration with medical schools and other partners to introduce a new assessment – the Medical Licensing Assessment (MLA). It is set to launch in 2024.
The assessment will test the core knowledge, skills, and behaviours of doctors wishing to practise in the UK. It will help make sure that the standards we set match patients’ needs and that doctors new to the register are well prepared to provide safe care. This will give patients, employers, and fellow doctors greater confidence in doctors new to practice, wherever they trained. It will also provide for better consistency and fairness between candidates. Finally, it will allow us to better monitor and approve the standard for entry to the profession over time.
All medical students who graduate from UK universities from the 2024–25 academic year will be required to pass the new assessment as part of their degree. Doctors from overseas who currently need to take our PLAB test to practise in the UK will also take the MLA instead once it has been introduced.
In 2021, we made significant progress towards the introduction of the new assessment.
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In March, we published Assuring readiness for practice: a framework for the MLA . The framework covers the content of the MLA and the requirements for its components.
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In June, our Council approved a proposal by all medical schools and the Medical Schools Council (MSC) for the Applied Knowledge Test (AKT) to be set centrally, overseen by the GMC, and delivered by each school locally to their students.
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We have since been working with schools and the MSC to oversee the design and development of the national AKT for medical schools.
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We have continued to engage extensively with staff in medical schools to help them prepare for the introduction of the MLA.
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We have continued our work to make the MLA a fair, robust, and high-quality assessment and to engage widely to inform our work, including with postgraduate training bodies and students.
a landmark moment in the
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history of medical education in the UK
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Professor Malcolm Reed, Lead Co-Chair of the Medical Schools Council, commenting on Council’s approval of the proposal made by medical schools and the MSC
General Medical Council 38
Delivering on our strategy
Post-Brexit registration routes
The Brexit transition period ended on 31 December 2020. As part of this, agreements between the UK and the EU on the mutual recognition of professional qualifications ended. This meant that graduates with EEA nationality wishing to practise as a doctor in the UK would no longer be entitled to automatic recognition of their qualifications in the UK.
To make sure doctors from EEA countries could continue to join the UK medical workforce, the UK Government introduced new legislation on 1 January 2021. This meant we needed to prepare and implement new registration routes based on assessing the qualifications doctors have rather than on routes to registration resting on nationality.
Through an extensive programme of work, we updated our systems, policies, and processes to prepare these for 1 January 2021. We launched communications in advance to give as much notice as possible and developed extensive guidance on how doctors can apply under the new arrangements. This has helped us assure continuity in the intake of new doctors from overseas at a time when our healthcare systems are under significant pressure.
Sharing insights about trends in the medical profession
As part of our role, we collect and share a significant amount of data to help improve patient safety and aid planning. We also carry out or commission analysis and research. This work helps to improve medical training, patient care, and workforce development.
In 2021:
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we released findings from our commissioned research into how employer induction can affect medical practice and patient care. The research revealed a huge difference in the quality of inductions.
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we published research into the impact and value of feedback for trainee doctors. The report highlighted the important link between feedback and well-being.
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we also published findings from research into how working in an FiY1 role affected new doctors’ practice. Different from Foundation Year 1 (FY1), interim Foundation Year 1 (FiY1) roles were created to allow final year medical students to be fast-tracked onto the frontline to help respond to the COVID-19 pandemic. The research concluded that FiY1 was a largely valuable experience that eased the transition into practice.
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we shared findings from commissioned research into how service changes impact doctors’ training. The findings illustrated how involving trainees in decisions about service changes can lead to better patient care.
If you would like to receive regular updates on our research work, sign up to our Research e-newsletter.
39 General Medical Council
Delivering on our strategy
The state of medical education and practice in the UK
In December, we published the 11th edition of our annual report into the state of medical education and practice in the UK. The report uses data and insights from the medical register, surveys, and other sources to provide a comprehensive picture of doctors’ experiences, as well as trends in the medical workforce and in medical education.
The 2021 report looked in particular at how the COVID-19 pandemic and the recovery affected doctors’ work and training. One of its conclusions was that despite the current pressures on the UK’s healthcare systems, now is the time to retain and embed positive changes to ways of working that were a key part of the initial response to COVID-19. Otherwise, the report warns, exhaustion and disillusionment will grow even more rapidly, blunting the effects of initiatives to boost recruitment.
The report also made for stark reading in relation to equality, diversity, and inclusion. For example, it outlined that:
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disabled doctors were almost twice as likely as non-disabled doctors to be dissatisfied, at a high risk of burnout, struggling with workload, and taking hard steps towards leaving the profession.
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doctors from ethnic minority backgrounds, particularly Asian/Asian-British doctors, were less likely to agree that they are supported by their immediate colleagues or are part of a supportive team.
We shared the report on our website and through the media, and the web pages containing the report were viewed over 7,000 times in the first week after release. Many of our partners released statements acknowledging the findings and the importance of the report in providing key insights into medical education and practice trends.
In particular:
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23% of doctors said they were planning to leave the profession, up from 19% in 2020. 7% of all doctors also said they had taken hard steps towards leaving the profession, up from 4% in 2020.
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over a third of doctors (35%) said they were considering reducing their contracted hours. Some doctors also felt it was not realistic to reduce their hours in the current climate, though they may have wanted to.
Completing the picture: why doctors leave the profession
As part of our research programme, we worked with Health Education England, the Department of Health (Northern Ireland), NHS Education for Scotland, and Health Education and Improvement Wales to understand the reasons why doctors leave the profession and what might encourage them to return. Over 13,000 doctors completed an online survey on this topic. All of them had practised in the UK within the last 15 years but were not practising at the time they responded to the survey.
General Medical Council 40
Delivering on our strategy
Key findings from the survey, available in our Completing the picture report, include:
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many doctors stopped practising in the UK for personal reasons, such as retirement. However, others left due to negative pressures such as burnout.
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a higher proportion of disabled doctors stopped practising in the UK than those who did not consider themselves as disabled.
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disabled doctors are more likely to report bullying as an important factor in leaving, and LGBTQ+ doctors more commonly indicated mental health issues as key.
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35% of the respondents wanted to return to practice in the UK, but only 23% thought it likely they would. However, the majority (59%) said they were both unlikely and unwilling to return.
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GPs showed higher levels of burnout and were reported as being less likely to return than other doctors.
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a small pool of countries account for a very large proportion of doctors moving abroad (eg Australia and New Zealand).
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improvements in areas like induction and providing up to date information on how to return could make a big difference in encouraging more doctors to return.
These findings suggest that well-led, supportive, and compassionate workplaces are vital in encouraging doctors and other healthcare professionals to stay in the profession.
This has been a useful barometer in our education reform work and will allow us to understand how we help support doctors who wish to return, as well as giving those thinking of leaving the profession the support to stay… - Professor Sheona MacLeod, Deputy Medical Director, Education Reform, HEE
National training survey
Our national training survey helps us to monitor and report on the quality of postgraduate medical education and training. It is the largest annual survey of doctors’ training in the UK. In the 2021 survey, we asked some questions about the continued impact of the COVID-19 pandemic on training. Over 63,000 doctors completed the survey. 76% of all trainees in the UK responded, and 32% of trainers. This is higher than in 2020, but still lower than our usual response rates. We believe this was due at least in part to the pressures and the disruption caused by the pandemic.
The survey helps us improve our quality assurance work in relation to education. It also improves the support we provide to trainers, trainees, and training environments across the UK.
For more information and to read the survey findings in detail, see the National Training Survey pages on our website.
41 General Medical Council
Delivering on our strategy
Regulating physician associates and anaesthesia associates
We have also begun work on how PAs and AAs will revalidate and are developing registration criteria for overseas-qualified practitioners.
Education
In 2019, we agreed with the UK’s Department for Health and Social Care (DHSC) that we will also start to regulate physician associates (PAs) and anaesthesia associates (AAs).
PAs and AAs are two of the medical associate professions (MAPs) working in UK healthcare. We are pleased to support the development of these valuable professionals, recognising the important role they play in the medical workforce. Regulation will help to increase the contribution PAs and AAs can make to UK healthcare, while keeping patients safe.
While the legislation that will enable us to bring these two professions under our regulation is being developed, we have made significant progress on several aspects of regulatory design.
Registration
We designed the processes that will bring the following groups of PAs/AAs onto the register:
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existing UK-based practitioners
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future PA/AA qualifiers from UK universities.
We published information about these processes on our website, so that future registrants can familiarise themselves with our expectations ahead of time. We will contact them nearer the start of regulation to let them know what we need from them to support their registration.
We have established a quality assurance (QA) process for UK PA and AA courses. All 37 current course providers have:
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engaged voluntarily in a baseline QA exercise
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completed a self-assessment against our published standards
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received initial feedback on strengths and areas for improvement.
We also developed high-level education outcomes for these professions. We worked with the Royal College of Physicians, Royal College of Anaesthetists, and others to create PA and AA curricula that are outcome-focused and meet our standards.
Professional standards
In October 2021, we published interim standards for the two associate professions. Good medical practice for PAs and AAs provides a framework for decision making to keep patients safe. We also produced accompanying case studies to set the standards in context. These standards will apply from when we begin regulating PAs and AAs until we publish new ethical guidance for all registrants, as part of our overall review of Good medical practice.
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Delivering on our strategy
Fitness to practise
We expect PAs and AAs to be subject to revised fitness to practise processes eventually resulting from broader regulatory reforms that are currently underway. In the meantime, we have been liaising with the Faculty of Physician Associates and the Royal College of Physicians on handling concerns about the conduct of PAs on the voluntary register. We have met with counterparts to understand their approach and the nature of concerns raised and will offer our expertise in the year ahead.
Supporting the case for prescribing
The DHSC has begun work to extend appropriate prescribing responsibilities to PAs and AAs after our regulation begins. We are supportive of this step as it will maximise the contribution these professionals can make to patient care. We therefore contributed to discussions on the subject with relevant partners and offered our support to those working on defining the practical aspects of this important move.
To learn more about our work around PAs and AAs, join our community of interest, which is open to members of the public and those working in healthcare, or visit our online information hub.
43 General Medical Council
Delivering on our strategy
Making every interaction matter
Healthcare professionals and members of the public often come to us at a challenging time. We want to make sure they are met with empathy, fairness, and professionalism by all our colleagues. We are also committed to listening to, learning from, and acting on their feedback about our services, and to learning more about the challenges experienced by the profession through research. Below are some examples of our work towards these objectives in 2021.
Supporting patients and others who raise a concern with us
When a patient raises a concern with us, we review the information to see if we need to investigate. If we decide to investigate a concern, our patient liaison team contacts the patient to talk through what is going to happen and to answer any questions. Once we have finished our investigation, we offer another meeting to explain the outcome and any next steps.
- I was given time to voice any concerns and questions. I felt listened to and understood. I was given a full, clear explanation regarding the process that would take place.
Prior to the pandemic, our patient liaison meetings were generally held in our offices in Belfast, Cardiff, Edinburgh, London, and Manchester.
In 2021, the majority of the meetings were held by telephone due to the pandemic. At the end of the year, we also started offering online meetings, which were very positively received.
We held liaison meetings with 337 patients over the course of 2021. Feedback was very positive: 88% of meeting attendees said they were satisfied or very satisfied with the patient meeting experience.
We also improved the information available on our website for patients considering whether to raise a concern with us. Often, concerns are best raised locally first, and we have provided updated guidance on how to do this. We also provided more information on the types of concern we typically investigate and those we do not. We explain that we only investigate when we believe a doctor poses a serious risk to patients or has significantly or repeatedly failed to meet our standards. Since the new web pages were launched in May 2021, they have been viewed over 40,000 times.
----- Start of picture text -----
88 [%]
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88% of meeting atendees said they were satisfied or very satisfied with the patient meeting experience.
- Patient attending a patient liaison meeting
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Delivering on our strategy
Regulatory reform
Regulation exists to protect the public. However, the legislation that currently regulates our work has not kept up with changes to the UK’s healthcare system and society. In particular, it prevents us from adapting our processes as quickly as we would like in order to better support those we regulate to deliver great care.
The UK Government has proposed changes to the way that we and other healthcare regulators work. The changes will affect all areas of our work and processes. We welcome the opportunities the legislation will bring. Regulatory reform will help us respond more quickly and effectively. This means:
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dealing with complaints faster and more flexibly, reducing stress for all involved
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implementing more streamlined registration processes which will help the development of a more sustainable workforce
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exercising additional powers over monitoring education and training, allowing us to better support medical professionals through their studies and career.
These reforms will be key in enabling us to achieve the aims of our corporate strategy. We formally established a programme of work to support the changes in January 2021. From March to June last year, the Department of Health and Social Care consulted on high-level changes to healthcare regulators. Further Government consultation will need to take place once the drafting of this complex legislation is complete. Following that, the new legislation will be laid before the UK Parliament. If and when that is approved, we will
consult to seek views on the way to put changes in place. We will then begin to introduce these changes. We expect some to happen quickly, while others will need to be phased over several years.
Communication and engagement continue to be a vital part of our work on regulatory reform. We have regularly updated and engaged with our key audiences on this agenda, and we will continue to do so while this programme of change develops.
Fairer regulation
We want to make sure fairness is at the core of our approach. We also want to set an example of the behaviours we expect from others. So, we have committed to reviewing our processes to make sure they are free from bias and as transparent as possible.
In 2021, an employment tribunal ruled that a number of factors led to us making a decision that was racially discriminatory against a doctor, with reference to a case dating back to 2018. We have applied to appeal this ruling, and at the time of going to print with this report the appeal has not yet been held.
In any case, we are determined to make sure that every registrant is treated fairly, both by ourselves and by others.
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Delivering on our strategy
So, following previous research on the subject, we commissioned a fairness audit from the University of Edinburgh and Fieldfisher. The audit focused on how we make decisions regarding fitness to practise. The auditors found no evidence of bias in the way our decision makers interpreted our guidance. However, we are aware that further work is needed. The targets we set in relation to equality, diversity, and inclusion reflect this acknowledgement.
As part of our ongoing commitments, we are:
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future proofing our approach through regulatory reform: as we reform how we work as a regulator, we want to make sure fairness is central to all the changes we plan to introduce. We are doing this by engaging all our teams in understanding how to meet our equality goals and assessing how new regulatory processes could impact on equality and diversity. We will publish our equality analyses to be transparent with our stakeholders.
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improving our processes: we are systematically reviewing the decision points in our procedures to see if we can strengthen fairness controls. For example, through more or different training of our people, anonymisation of data, group decision making, and other quality assurance arrangements.
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investing in independent assurance: following the fairness audit mentioned above, we have commissioned an external review of how doctors experience our processes and of best practice in auditing for bias. We plan to use the review’s findings to develop and put in place routine fairness audits as part of our processes.
Four-country regulation
The Northern Ireland, Scotland, and Wales healthcare systems each have different and specific characteristics and needs to the healthcare system in England. In order to understand and address these needs and better serve patients and doctors in these contexts, we regularly engage with our partners and key interest groups in each of the UK’s devolved nations through our UK Advisory Forums.
Forum members include representatives from the relevant Departments of Health, medical leaders, medical education bodies, system and professional regulators, and patient representative organisations.
At twice-yearly meetings in each country, members have the opportunity to raise issues directly with our Chair and Chief Executive. The meetings allow us to discuss our priorities and seek views on policy development in collaboration with members in each country.
In 2021, discussions focused on our equality, diversity, and inclusion targets and on pressures on the medical profession. Members shared their insights on issues and initiatives to support doctors from ethnic minority backgrounds in each country. They also shared their reflections on the impact of the pandemic on the medical profession, highlighting aggression from the public towards healthcare staff and high levels of burnout, and what we can do collectively to support doctors’ psychological safety.
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Delivering on our strategy
Improving the user experience on our online portals
In August 2021, we introduced significant improvements to our secure online portals – GMC Online and GMC Connect.
GMC Online is our portal for doctors. They can use it to manage registration, carry out revalidation, pay fees, apply to take a Professional and Linguistic Assessments Board test, complete our national training surveys, and more.
GMC Connect is the system used to transfer data securely, both into and out of the organisation. The groups we share with include responsible officers, education organisations, legal organisations, and more. The improvements we
made to the systems include:
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a better experience accessing GMC Online on a phone or tablet
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a simpler login process
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easier password recovery
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the ability to link accounts for GMC Online and Connect, which means users need only one login for both platforms
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an updated design which is more consistent with the rest of our website.
The changes significantly improve the user experience for doctors and others with accounts and are part of continuing work we are doing to keep up with external developments and increasing demand for our services.
47 General Medical Council
Delivering on our strategy
Investing in our people
The majority of our colleagues tell us they find the GMC a great place to work. But we know that not everyone has the same experience. In 2021, our annual people survey showed that the percentage of colleagues who experience or witness bullying, harassment, or discrimination increased. We have zero tolerance for these behaviours and recognise we have more to do to ensure all colleagues are treated with respect and feel safe at work.
Equality, diversity, and inclusion programmes
We want to build a more diverse and inclusive organisation and a broader, more inclusive and diverse workforce where everyone can fulfil their potential through dedicated personal support. In line with this commitment, alongside our other equality, diversity, and inclusion (ED&I) targets, we have set ourselves targets in relation to improving staff representation and career progression for underrepresented ethnic groups in our workforce. By 2026, we want to reduce ethnicity-related differentials in relation to:
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recruitment and selection
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representation across staffing levels
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retention and progression
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employee engagement and inclusivity perceptions
To achieve these goals in 2021, we:
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briefed staff responsible for recruitment and selection on the targets we have set and how to achieve them
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embedded inclusivity into the core behaviours expected of all staff and integrated it into everyone’s objectives
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expanded our leadership development programmes to cover colleagues of all levels, including those who do not (yet) have direct reports
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launched a talent development programme aimed at colleagues from ethnic groups that are under-represented in our leadership roles
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launched a bespoke training programme focusing on fostering inclusion with around 430 colleagues in leadership positions expected to take the training in 2022
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developed new training on professional behaviours (see page 49), to be completed by all staff by the end of 2022
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launched a new anti-racist allyship programme. As part of the first phase, 50 colleagues across the organisation have taken the training, including our senior management team.
We will review and report on progress against our goals in this area regularly based on human resource data, focus groups, and the results of our annual people survey.
- pay gaps.
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Delivering on our strategy
Investors in people
We use Investors in People (IiP)’s We Invest in People framework to assess our processes and policies relating to our people. We have a talented and committed workforce and the IiP standard allows us to look at how we can best engage and inspire our people to achieve our strategy and deliver our business plan.
We have been accredited against this standard since 2018 at Silver level and we are working to achieve Gold accreditation. In 2021, following a survey and targeted interviews with staff, IiP found that we made significant strides towards Gold across all areas of the standard. Out of the 27 themes assessed, 12 met the Gold standard and 15 achieved the Silver standard. IiP also acknowledged that we improved on all the indicators in the framework since 2018.
Our focus for the next few years will be on continuing to embed our people management policies and procedures across the organisation.
There have been improvements in the responses to all indicators compared to the results in 2018, with many themes within each indicator increasing to Advanced (Gold) level…it is clear, from a strategic perspective, that the organisation is operating at Advanced (Gold) level. - IiP 2021 report
Professional Behaviours: Championing respect and inclusion
The majority of our colleagues tell us they find the GMC a great place to work. But we know that not everyone has the same experience.
During 2021, we developed mandatory training, Professional Behaviours: championing respect and inclusion. The training underpins our strategy and our equality, diversity, and inclusion objectives. It combines online learning with team discussions and follow-up events and encourages staff to consider their behaviour, the impact they have on others, and our individual responsibility for creating an inclusive and professional environment. It also focuses on what colleagues can do if they feel someone is not behaving appropriately and how to raise a concern. Those who completed the first phase of the training provided very positive feedback:
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88% agreed or strongly agreed they had reflected critically on their behaviour past and present
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83% agreed or strongly agreed they are now more likely to change their behaviour where it may be negatively affecting another person
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72% agreed or strongly agreed they feel more confident to challenge or report unprofessional behaviour in the future.
We expect the training to be completed by all staff by the end of 2022.
49 General Medical Council
Delivering on our strategy
Freedom to speak up
The Freedom to speak up (FTSU) initiative started in 2016 with the appointment of Freedom to Speak Up Guardians across the NHS. The scheme encourages and supports workers to speak up about events or behaviours that impact negatively on patients or on staff.
At the GMC, we have had a FTSU Guardian since March 2019. We recognised the value of enhancing our existing arrangements for colleagues internally to raise any issue they felt was negatively affecting our work and our culture.
The initiative has proved a valuable addition to our existing arrangements. Between March 2019 and December 2021, 279 issues were raised through
this channel. These covered a range of matters, with the main themes including:
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behaviours (how we treat one another)
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consistent application of GMC policies
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perceived fairness of recruitment exercises.
Evidence from the programme shows that an increasing number of colleagues have felt able to take follow-up action themselves after a conversation with the Guardian or one of our supporting FTSU champions. It takes courage for colleagues to speak up and we actively encourage them to do so. We recognise the valuable learning from their experiences, which we can use to continuously improve our policies, management training, and communication.
General Medical Council 50
Corporate social responsibility
51 General Medical Council
Corporate social responsibility
We strive to be a socially responsible organisation. We want to embed sustainability, social impact, and ethics into everything we do. From standalone initiatives to everyday activities, we try to carry out our work in a way that benefits the environment and society.
In 2021, we made progress with this agenda in several ways.
Supporting social mobility and widening participation in medical education
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We designed and implemented a legal apprenticeship scheme with support from the Social Mobility Foundation. We launched the scheme in August 2021, receiving a positive response. The scheme allowed us to recruit four talented law students from the Greater Manchester area who will study towards their degree while they work in our legal team.
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We also took part in a number of events organised by the Social Mobility Foundation. The events were aimed at young people who want to go to medical school. Three of our clinical fellows presented at summer school events for these students, sharing their experiences of applying for medical school and their experiences of training.
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We joined the National Medical Schools Widening Participation Forum and worked with the Medical Schools Council on plans to develop resources to help widen participation in medical education.
Protecting the environment
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We launched the GMC’s net zero carbon project. The project is designed to enable us to measure our environmental impact and develop options to become a net-zero-carbon organisation.
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We grew our internal network of GMC environment champions.
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We attended the International Association of Medical Regulatory Authorities conference. As part of this, we gave a joint presentation with Greener NHS.
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We published a blog in support of COP26.
Benchmarking and working with partners to promote CSR
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We strengthened our relationship with Business in the Community (BITC). As part of this, we started using their Responsible Business Tracker to benchmark our CSR work. The tracker allows us to measure our progress compared to other organisations.
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We represented the GMC on the BITC North West Leadership Board. The Board provides guidance and support for responsible business work across the region.
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Corporate social responsibility
Creating opportunities and developing our CSR programme further
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We began a pilot programme of internships focusing specifically on CSR. Our first CSR intern joined us in May 2021 for 12 weeks. The intern helped us with research into widening participation schemes at UK medical schools.
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We launched our first corporate volunteering pilots. As part of this, some of our staff took part in a virtual reading scheme with a north London academy. They have been reading with Year 9 and 10 pupils from the academy with English as a second or third language for 30 minutes twice a week. We also worked with an academy trust in Manchester on their plans for Special Educational Needs schools in the area.
The reading scheme will provide huge benefits, as literacy is so important. For me, being able to contribute to it will be a positive highlight of my work at the GMC. It also reflects well on the organisation, showing it wants to contribute to local communities and society in this way.
-
GMC colleague taking part in our
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corporate volunteering scheme
The steps we have taken so far in relation to our CSR agenda will help us identify where we can do even more in future.
53 General Medical Council
Our structure, governance, and mana ement g
Council and other governance groups
Council is our governing body. Its role is to provide strategic direction, hold the executive to account, and take major high-level policy decisions. It comprises 12 members from the 4 countries of the UK, 6 of whom are medical members and 6 of whom are lay members.
We are a registered charity and our Council members are also the trustees of the organisation.
They are all independently appointed by the Privy Council through a process that follows the Professional Standards Authority’s guidance for making appointments to healthcare professional regulatory bodies.
The trustees between 1 January 2021 and 31 December 2021 were:
- Mr Steve Burnett
Dame Clare Marx was appointed by the Privy Council as the Chair of the General Medical Council in January 2019, but sadly due to ill health decided to step down at the end of July 2021. Dame Carrie MacEwen took on the role of acting Chair after Dame Clare Marx stepped down and chaired Council from then on.
In August 2021, we were shocked and extremely saddened by the untimely death of Lara Fielden, an outstanding member of Council who joined us in January 2021. Her contribution will be greatly missed.
Council therefore had two vacancies. Recruitment for a permanent Chair commenced in November 2021 and concluded in May 2022, with the appointment of Dame Carrie MacEwen as Chair.
Council members are also asked to declare any conflicts of interests. These are listed in a register of interests published on our website.
-
Dr Vanessa Davies
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Ms Lara Fielden (until August 2021)
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Professor Anthony Harnden
All Council members also participated in appraisal reviews in 2021, which included consideration of any learning and development needs and revisiting actual or perceived conflicts of interest to make sure any conflicts identified are manageable.
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The Rt Hon Lord Hunt of Kings Heath PC
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Professor Paul Knight
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Professor Dame Carrie MacEwen
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Professor Deepa Mann-Kler
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Dame Clare Marx (until July 2021)
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Professor Suzanne Shale
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Dr Raj Patel
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Miss Alison Wright.
As a charity, we take into account the seven principles set out in the Charity Governance Code (2020) and can demonstrate how we use these principles to guide our work on an ‘apply or explain’ basis.
There are two exceptions to the Code, which we explain rather than apply. Firstly, our Council and committees operate without a formally appointed deputy or vice-chair. However, provisions are made in the Governance handbook
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Our structure, governance, and management
for chairs to nominate a deputy to assist during periods of absence, which was enacted this year. Secondly, as our appointments process is well established and thorough and is overseen by the Professional Standards Authority, a nominations committee is not considered necessary.
The Governance handbook is the governing document of the organisation. It was reviewed in 2019 to further incorporate the Charity Governance Code and minor updates are made with Council’s approval on an ongoing basis, for example, to the membership of committees.
Our Corporate Governance team is charged with supporting the Council in maintaining high standards of governance, on an ‘apply or explain’ basis, in line with the good practice set out within the Charity Governance Code. The team also provides training and advice to the organisation on matters of governance. Each committee accounts to the Council through a formal report, and the Council and each committee undertake to review their effectiveness in delivering its statement of purpose, which is reviewed annually.
The diagram on the next page shows the different governance groups that assist Council in discharging its responsibilities. These have all been agreed by Council to help it oversee our work effectively. The roles and activities of these groups are described in the pages that follow.
Council business is conducted in an open and transparent manner and the agenda and papers for each meeting are published on our website.
55 General Medical Council
Our structure, governance, and management
----- Start of picture text -----
Council Governance
Council
Audit and Risk Committee
MPTS Committee
Remuneration Committee
GMC/MPTS
Investment Committee Liaison Group
Executive Governance
Executive Board
Directorate work plans
Formal Engagement
Advisory Forums
Scotland Education
Wales Equality, diversity, and inclusion
Northern Ireland
Liaison Groups
Task and Finish Groups
----- End of picture text -----
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Our structure, governance, and management
Audit and Risk Committee
Paul Knight chaired the Audit and Risk Committee during 2021. Its external co-opted members were Elizabeth Butler (until July 2021), Jon Hayes (from July 2021), and Kenneth Gill.
The Committee plays a key part in our governance, providing Council with independent assurance about:
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the integrity of our financial statements
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the effectiveness of internal control, governance, and risk management systems
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the delivery of internal and external audit services.
The Committee met five times in 2021 and reports to Council twice a year. You can find out more about its role and its work in the Audit and Risk Committee Report section (see page 71) of this report.
Remuneration Committee
Anthony Harnden chaired the Remuneration Committee in 2021. The Committee advises Council on the remuneration, the terms of service, and the expenses policy for Council members, including the Chair. It oversees the recruitment process of the Chair and Council members before their appointment by the Privy Council. It determines the appointment process for the Chief Executive and the Medical Practitioners Tribunal Service (MPTS) Chair and the
remuneration, benefits, and terms of service for the Chief Executive, directors, MPTS Chair, and MPTS Committee members. It is also responsible for making sure the assessment and measurement of performance and the assessment of recruitment and succession planning take place within an appropriate framework for the senior management roles within its remit. The Committee reports annually to Council and met three times in 2021.
Investment Committee
Steve Burnett chaired the Investment Committee in 2021. Its external co-opted members during 2021 were Tim Scholefield (until May 2021), David Stewart (until June 2021), Keith MacKay, and Mike Jennings (from November).
The Committee is responsible for implementing and reviewing our investment policy, making sure the management of assets is consistent with the policy, appointing and managing fund managers, and monitoring performance.
It also has responsibility for overseeing the GMC’s investment in GMC Services International Limited (GMCSI), including ensuring compliance with the GMC’s Investment Policy, scrutinising GMCSI’s business plan, and assessing the potential levels of investment risk and return. The Committee reports on investment performance to Council via post-meeting circulars and reports on the performance of the portfolio to Council on an annual basis. It met five times in 2021.
57 General Medical Council
Our structure, governance, and management
GMC Services International
GMC Services International Limited (GMCSI) was established by Council in 2016 as a wholly owned trading subsidiary of the GMC. The main objective of GMCSI is to introduce new revenue streams and so reduce our reliance on doctors’ fees.
Robust and effective governance arrangements are in place to ensure that our interests are protected and that our relationship with GMCSI is managed effectively.
While Council has overall responsibility for GMCSI, the Audit and Risk Committee considers the risks to the GMC from the operation of GMCSI, conducting routine internal audit and spot checks as appropriate.
Andrew McCulloch chaired the GMCSI Board during 2021. The Board comprised (in addition to the Chair) Paul Reynolds, Anthony Harnden, Alison Wright, and Colin Melville.
Board of Pension Trustees
The GMC’s defined benefit staff superannuation scheme is managed and administered by a board of trustees in accordance with the scheme’s trust deed and rules. The trust makes sure the pension scheme’s assets are kept separate from those of the employer.
Deirdre Kelly chaired the Board during 2021. Deirdre, Steve Burnett, Raj Patel, and Vanessa Davies are employer-nominated trustees. Danny Dubois, John Foley, Paula Robblee, and Martin Hart are member-nominated trustees.
Medical Practitioners Tribunal Service
The Medical Practitioners Tribunal Service (MPTS) is responsible for overseeing the adjudication of fitness to practise hearings. It is overseen by Dame Caroline Swift as Chair and by Gavin Brown as Executive Manager.
The MPTS Committee and joint GMC/MPTS Liaison Group are a core part of our governance framework.
Dame Caroline Swift chairs the MPTS Committee. The Committee oversees the delivery of the hearing service for doctors and makes sure the service meets its responsibilities under the Medical Act 1983 . The GMC/MPTS Liaison Group is chaired by the Chair of Council. It oversees the working relationship between the MPTS and the functions of the GMC with which it interacts.
The scheme’s trustees are responsible for the proper running of the scheme, including the collection of contributions, the investment of assets, and payment of the pension benefit commitments made by the employer.
General Medical Council 58
Our structure, governance, and management
Executive Board
The Executive Board is the senior decision-making and oversight forum established to provide strategic direction, scrutiny, and reporting to Council by the GMC’s senior management team on significant policy, strategy, finance, performance, operational delivery, and resource management issues. It ensures that the GMC is a high-performing and agile regulator that understands its registrants, the healthcare systems in which it operates, and the views of its key stakeholders.
The Board meets monthly (except for August) and reports to every meeting of Council through the Chief Executive’s report and via a separate annual report.
UK Advisory Forums
In 2013, we established advisory forums in Northern Ireland, Scotland, and Wales. The forums make sure we have effective engagement and consultation with interest groups and that our policies are suited to all parts of the UK. The invited membership differs from country to country and reflects the diverse range of those who have an interest and expertise in the areas under our regulation across the UK. The forums report on their work to the Executive Board twice a year.
Education Advisory Forum
The Education Advisory Forum, which replaced the Education and Training Advisory Board (ETAB) and the Assessment Advisory Board (AAB), began work in February 2019. The forum engages widely and effectively with our key interest groups on education, training, and assessment matters, making sure we are able to best develop and promote a strategic approach to this work across all countries of the UK. Professor Colin Melville, Medical Director and Director of Education and Standards, chairs the forum and the invited membership reflects the diverse range of those who have an interest and expertise in medical education, training, and assessment across the UK. The work of the forum is reported to the Chief Executive and to Council through the Chief Executive’s report.
Equality, Diversity and Inclusion Forum
Our Strategic Equality, Diversity and Inclusion Forum helps us make sure that our activities respond to the needs of diverse groups of doctors. The forum comprises organisations representing doctors with shared protected characteristics, and helps us meet our ED&I objectives by providing feedback and advice on our policies and strategies, raising issues and concerns requiring our attention, and generally acting as a sounding board in relation to ED&I issues. In 2021, discussions with the forum covered our new ED&I targets, fairness and transparency, bullying, harassment, and discrimination, our review of Good medical practice , and the redesign of our processes as part of our regulatory reform programme.
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Our structure, governance, and management
Member attendance at Council, boards, and committees in 2021[* ]
----- Start of picture text -----
Member and trustee Number of meetings attended
Steve Burnett
Council 8/8
Investment Committee 4/4
Board of Trustees of the GMC’s Superannuation Scheme 5/5
UK Advisory Forums – Wales 2/2
Vanessa Davies
Council 8/8
Remuneration Committee 3/3
Board of Trustees of the GMC’s Superannuation Scheme 5/5
Lara Fielden (until August 2021)
Council 3/4
Investment Committee 2/2
Anthony Harnden
Council 8/8
Remuneration Committee 3/3
Investment Committee 1/1
GMCSI 3/3
Philip Hunt
Council 8/8
Audit and Risk Committee 5/5
Remuneration Committee 3/3
----- End of picture text -----
- Includes seven Council meetings and one strategic away day. Council member attendance at the Forum meetings is on a voluntary basis on the invitation of the Chair of Council. Attendance data reflects the total number of meetings where attendance was possible.
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Our structure, governance, and management
----- Start of picture text -----
Member and trustee Number of meetings attended
Paul Knight
Council 8/8
Audit and Risk Committee 5/5
GMC Services International 1/1
UK Advisory Forums – Scotland 2/2
Carrie MacEwen
Council 8/8
Investment Committee 4/4
GMC/MPTS Liaison Group 1/1
UK Advisory Forums – Northern Ireland 1/1
UK Advisory Forums – Scotland 1/1
UK Advisory Forums – Wales 1/1
Deepa Mann-Kler
Council 8/8
Investment Committee 4/4
Remuneration Committee 3/3
UK Advisory Forums – Northern Ireland 2/2
Clare Marx (until July 2021)
Council 4/4
GMC/MPTS Liaison Group 1/1
UK Advisory Forums – Northern Ireland 1/1
UK Advisory Forums – Scotland 1/1
UK Advisory Forums – Wales 1/1
Raj Patel
Council 8/8
Audit and Risk Committee 5/5
Board of Trustees of the GMC’s Superannuation Scheme 5/5
Suzanne Shale
Council 8/8
Audit and Risk Committee 5/5
----- End of picture text -----
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Our structure, governance, and management
External co-opted members
External co-opted members sit on the Investment Committee and Audit and Risk Committee respectively.
----- Start of picture text -----
Investment Committee
Mr Keith MacKay 5/5
Mr Tim Scholefield 1/2
Mr David Stewart 1/2
Mike Jennings 1/1
Audit and Risk Committee
Ms Elizabeth Butler 3/3
Mr Kenneth Gill 4/5
Jon Hayes 2/2
GMCSI
Dr Andrew McCulloch 4/4
----- End of picture text -----
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Our structure, governance, and management
Management
At the beginning of 2021, our staff were under the direction of Chief Executive Charlie Massey. He is supported by a team of directors, who, as at 31 December 2021 were:
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Shaun Gallagher, Director of Strategy and Policy
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Una Lane, Director of Registration and Revalidation
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Colin Melville, Medical Director and Director of Education and Standards
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Anthony Omo, General Counsel and Director of Fitness to Practise
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Paul Reynolds, Director of Strategic Communications and Engagement
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Neil Roberts, Director of Resources.
Key management personnel – remuneration policy
The Remuneration Committee is responsible for determining the remuneration, benefits, and terms of service for the Chief Executive, Chair of MPTS, and directors. The Committee sets all aspects of salary or honoraria, the provision of any other benefits, and any other arrangements or contractual terms for this group of staff.
The Committee considers that we should provide remuneration and rewards that will attract and retain the high-calibre staff necessary to enable us to fulfil our statutory remit and deliver our strategic objectives.
In setting the base pay for individual posts, the Committee will take external advice on roles within its remit and align salaries with an appropriate market rate subject to resource considerations.
An annual consolidated pay award is considered with reference to the organisation’s level of performance, the financial implications of any award, the award agreed for other GMC employees and wider market trends. An annual variable non-consolidated element is considered, reflecting personal performance with regard to the same considerations applied to any consolidated award. We review the effectiveness of these arrangements on an annual basis.
Staff within the Remuneration Committee’s remit will usually be entitled to the benefits package available to all GMC employees on the same terms. The Committee retains the ability to withdraw, adjust, or change any benefits for staff within its remit, subject to any consultation and contractual requirements. The Committee considers any additional benefits in kind (such as relocation payments) on a case-by-case basis.
New external staff appointees within the Committee’s remit are automatically enrolled into our defined contribution pension scheme. Where employees have existing agreed pension arrangements, such as membership of our defined benefit scheme, they retain this for the course of their employment, subject to any changes to the rules agreed by trustees and the employer.
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The Committee makes sure that the equality and diversity implications of remuneration policy and related decisions are considered appropriately. Specifically, it ensures that:
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any salary differentials are supported by a formal job evaluation or independent external market advice
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any decisions relating to variable pay are supported by an objective assessment of performance
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any adjustment or changes to remuneration arrangements do not discriminate unlawfully
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other decisions relating to terms of service are supported by appropriate advice on any equality and diversity implications.
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2021 fnancial review
The accounts for the year ended 31 December 2021 have been prepared in accordance with the Charities Statement of Recommended Practice (FRS 102).
We also generated £4.9 million of gains on our investments in 2021. This was higher than 2020 due to the impact of the early stages of the pandemic on financial markets in 2020.
Our total income and expenditure in 2021
The coronavirus (COVID-19) pandemic continued to have a significant impact on our activities throughout 2021, but we were able to start to work through the backlogs created by the early pandemic lockdowns and we continued to deliver many of our core services to support doctors and patients.
In 2021, we generated unrestricted income of £119.7 million, which was £11.4 million higher than 2020. This was due to the increase in the size of the register and the impact of running more Professional and Linguistic Assessments Board (PLAB) tests in 2021 than 2020, plus the subsequent increase in new applications to the register.
We were able to run additional PLAB tests by investing £1 million in a new temporary clinical assessment centre designed specifically for socially distanced exams, which allowed us to return to pre-pandemic capacity from June.
In addition, the Department of Health and Social Care of the UK Government provided £2.6 million of funding in 2021 to continue implementation work to bring physician associates and anaesthesia associates into regulation by the General Medical Council. This funding is restricted in nature, and so is shown separately in the accounts. It was fully spent in 2021, with £0.9 million used to develop IT systems, which are capital in nature, creating a restricted asset on the balance sheet.
Our unrestricted charitable expenditure in 2021 was £117.9 million, which was an increase of £11.3 million compared with 2020. In 2020 tribunals and PLAB 2 tests were temporarily postponed and restarted in the second half of the year. Throughout 2021 we were able to run tribunals on a hybrid basis, with some being face to face and some being virtual. We continued to deliver PLAB 2 tests under social distancing measures and successfully ran PLAB 2 tests on a non-socially distanced basis towards the end of 2021. We increased capacity for both tribunals and PLAB tests in 2021, which allowed us to process some of the work delayed during the temporary closures, which increased costs.
We increased our dilapidations provision by £1.9 million to ensure our obligations under our building leases can be met. Our 2021 accounts also include a further £0.1 million provision to meet potential costs arising from legal claims.
Our other core activities continued throughout 2021 with the impact of the pandemic generally influencing our ability to travel, return to the office with new working patterns, and host and attend events.
We set an efficiency target to generate savings of £1.5 million, which we felt was a realistic target considering the challenges the pandemic has brought to our operating environment. We managed to deliver cost savings of £1.9 million by realising savings through implementing virtual tribunals and deferring recruitment to vacant posts.
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2021 financial review
The charity had no fundraising activities requiring disclosure under S162A of the Charities Act 2011 .
Reserves policy and going concern
Our level of reserves and our reserves policy are reviewed annually, and any financial implications are addressed as part of the budget-setting process.
Our total reserves are made up of free reserves, reserves backed by fixed assets, and pension reserves.
We hold free reserves:
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to provide working capital to undertake our normal day-to-day business
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to provide funds to deal with any risks that materialise
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to provide funds to respond to new initiatives, opportunities and challenges that present themselves
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to cover the period before any changes to fee levels take full effect.
A significant proportion of our total reserves is represented by fixed assets, which cannot easily be converted into cash without adversely affecting our ability to fulfil our charitable aims and statutory obligations. The value of fixed assets is therefore disregarded for reserves policy purposes.
The value of pension reserves is also disregarded for reserves policy purposes. The defined benefit scheme was closed to future accruals in 2018, and any deficit or surplus in the scheme can be managed over the medium term, so has no immediate impact on free reserves.
There is no standard formula that can be used to calculate the ideal level of free reserves. We follow the Charity Commission’s guidance and set a target range based on our cash flow requirements and an assessment of the risks facing the organisation. We aim to hold free reserves at a level that is not excessive but does not put our solvency at risk.
Based on our analysis of cash flows and the risks facing the organisation, our policy has been to maintain free reserves in the range of £25 million to £45 million. However, in 2021 we re-assessed the risks we face, and Council approved increasing our upper threshold to £50 million.
For future years, to ensure that the free reserves policy continues to reflect changes in the size of the organisation, we will link the target range directly to expenditure, expressed in percentage terms, therefore our target range of free reserves will be between 20% and 35% of annual expenditure.
We will also continue to review the purpose and scope of our reserves policy on an annual basis to ensure the thresholds reflect our current risk profile, cash flow requirements and operating environment.
Our policy is to maintain actual free reserves in line with the target level over the medium term. If our actual reserves vary significantly from the
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target range set out in the reserves policy, we take action to address the variation as part of the annual budget-setting process to bring actual reserves back into line within a reasonable period.
Our total reserves at the end of 2021 were £99.8 million, made up of free reserves of £45.2 million, plus £18 million of reserves represented by fixed assets, and a pension reserve of £36.6 million.
The spread of the coronavirus (COVID-19) had a significant impact on our activities throughout 2020 and 2021, and in overall terms our net costs were lower than planned. We are planning for our expenditure to be higher than our income in 2022 as we continue our recovery plans. We estimate that our free reserves will reduce to around £40.9 million at the end of 2022, which is consistent with our reserves policy.
Most of our income comes from registration fees paid by doctors. All doctors must be registered with us to practise medicine in the UK, and so our income is relatively certain. Despite the impact of the pandemic, trustees remain of the view that the GMC is a going concern for the foreseeable future, and therefore have prepared the financial statements on a going concern basis.
There are no material uncertainties related to events or conditions that cast significant doubt on our financial stability for the foreseeable future.
Investment policy
Council is responsible for determining and reviewing the overall investment policy, objectives, risk appetite and target returns. It has delegated responsibility for implementing the investment policy, appointing and managing fund managers, and monitoring performance to the Investment Committee, which regularly reports to Council.
Our investment policy separates our funds into four categories:
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those which are required as working capital for the normal day-to-day operation of the business
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those which we may invest under management
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those which we may invest in a trading subsidiary
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any residual cash balance.
We hold a minimum of £15 million as working capital for normal cash flow purposes. This is held in instant access bank accounts and provides sufficient flexibility to avoid temporary borrowing and/or the need to liquidate investments to deal with short-term variations in operational income and expenditure.
We originally invested £50 million under management in June 2019. Our target rate of return on funds invested under management is inflation (CPI) plus 2% over a rolling five-year period. This reflects our relatively low risk appetite. We seek to provide protection against inflation; to generate a modest level of return; and to diversify our funds to reduce the risk of capital and/or revenue loss.
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We have adopted a comprehensive ethical approach to investments. We believe that investing in certain companies or sectors would conflict with our charitable aims or may create reputational damage. We do not wish directly to profit from, or provide capital to, activities that are materially inconsistent with our charitable aims and so we specifically exclude investment in companies that derive more than 10% of their revenue from: tobacco, alcohol, gambling, pornography, high-interest-rate lending, cluster munitions and landmines, and the extraction of thermal coal or oil sands. We do not invest in companies that are under investigation for, or have been found guilty of, tax evasion or money laundering in the past three years.
£57 million at the start of the year. We generated a return of 8.59% in 2021, compared with a target of 7.4%.
We invested £0.6 million as share capital in GMC Services International Limited, a trading subsidiary of the GMC, at the end of 2016. Our investment at the end of 2021 was valued at £0.2 million.
Any residual cash not held as working capital or invested is held in medium-term deposits and/or interest-bearing accounts. We generated interest of £0.08 million on our cash balances, equivalent to an average annual rate of return of 0.20%. Cash held as working capital, and any residual cash, is shown on our balance sheet within current assets.
We may invest in companies whose activities are consistent with, or supportive of, our charitable aims. We expect companies in which we invest to demonstrate responsible employment and corporate governance practices, to be conscientious regarding environmental and social issues, and to deal fairly with people and the communities in which they operate. We may also use our position as an investor to actively engage with and influence the corporate behaviour of those companies we invest in.
We invest only through fund managers who demonstrate the strongest environmental, social, and governance credentials. When appointing fund managers, we take into consideration how they incorporate an assessment of a company’s performance on environmental, social, and governance issues in their stock selection.
Our funds under management were valued at £61.6 million at the end of 2021, compared with
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GMC Services International Limited
The trading subsidiary was incorporated as a private company limited by shares on 16 December 2016. It is a wholly owned subsidiary of the GMC and provides services on a commercial basis, including consultancy, training, and accreditation. One of its main objectives is to introduce new revenue streams and so reduce the GMC’s reliance on core financial resources. It will do this by gifting its profits back to the GMC for the purpose of delivering the GMC’s charitable aims.
The GMC invested £0.6 million as share capital in GMC Services International Limited (GMCSI). In its early years of operation GMCSI generated net losses but has been able to recently generate modest profits. In 2021, GMCSI generated a net loss of £7,410 and ended the year with net assets of £230,445, so no profits have been gift-aided back to the GMC. GMCSI is projected to generate profits over the medium term.
The accounts presented here are consolidated group accounts to include our trading subsidiary GMCSI. The statement of financial affairs shows the consolidated position for the GMC and GMCSI combined. The balance sheet shows separate columns for the group position (GMC and GMCSI combined) and the parent charity position (GMC). Separate company accounts have been prepared for GMCSI.
Trustees’ responsibilities for the financial statements
The trustees are responsible for preparing the trustees’ annual report and the financial statements in accordance with applicable law and United Kingdom Generally Accepted Accounting Practice (United Kingdom Accounting Standards). The law, applicable to charities in England, Scotland and Wales, requires the trustees to prepare financial statements for each financial year which give a true and fair view of the state of affairs of the charity and the group, and of the incoming resources and application of resources of the group for that period.
In preparing these financial statements, the trustees are required to:
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select suitable accounting policies and then apply them consistently
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observe the methods and principles in the Charities Statement of Recommended Practice
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make judgements and estimates that are reasonable and prudent
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state whether applicable accounting standards have been followed, subject to any material departures being disclosed and explained in the financial statements
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prepare the financial statements on the going concern basis unless it is inappropriate to presume that the charity will continue in business.
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The trustees are responsible for keeping adequate accounting records that are sufficient to show and explain the charity’s transactions, and to disclose, with reasonable accuracy at any time, the financial position of the charity, enabling them to make sure that the financial statements comply with the Charities Act 2011, the Charity (Accounts and Reports) Regulations 2008, the Charities and Trustee Investment (Scotland) Act 2005, the Charities Accounts (Scotland) Regulations 2006 (as amended), the Privy Council Directions issued under the Medical Act 1983 , and the provisions of the charity’s constitution. They are also responsible for safeguarding the assets of the charity and the group and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities.
Related party transactions
We require that all trustees and senior managers disclose details of any organisations in which they (and their close family members and business partners) hold a position of authority or other material interest and whose business could bring them into financial contact with the GMC. Details of any actual transactions between the GMC and related parties in the year must also be disclosed. We also publish a register of interests on our website.
In 2021, all disclosures were made and there were no issues of concern.
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Audit and risk committee re ort p
Our Council’s Audit and Risk Committee plays a key role in our governance. The committee provides Council with independent assurance about:
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the integrity of our financial statements
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the effectiveness of internal control, governance, and risk management systems
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the delivery of internal and external audit services.
It also monitors our anti-fraud policies and any risks relating to the General Data Protection Regulations and reviews arrangements for raising concerns.
In 2021, the committee met five times and submitted two formal reports on its work and findings to Council. As well as this, committee members had the opportunity to learn more about and scrutinise specific areas of the business and their risks in five seminar sessions.
The committee bases its annual work programme on risk and our Corporate Opportunities and Risk Register reflects the key strategic risks we manage. The committee’s oversight and scrutiny play a valuable role in assuring that risks are being managed and opportunities are enhanced through effective systems of governance, internal control, and risk management arrangements.
The committee bases its advice and decisions on guidance issued by the Financial Reporting Council, the Charity Commission, the Office of the Scottish Charity Regulator and, where appropriate, independent external advice.
At the beginning of 2021, there were seven members on the committee – five Council members and two co-opted members. The committee welcomed a new co-opted member in July and unfortunately lost one of our Council members in September due to their untimely passing, resulting in four Council members and two co-opted members on the committee at the end of 2021. Co-opted or independent, members enhance the work of the committee by bringing valuable additional skills and experience to the independent scrutiny of finance, risk, and governance. All members of the committee participate in an annual appraisal process.
Key activities during 2021
In 2020, the committee paused its planned programme of audit work to respond to the emerging risks of the pandemic and focus instead on a series of learning reviews and audit activity to provide assurance over new activities and risks. In 2021, the committee was able to pursue its planned internal audit programme. This has continued to focus on activities which have been adapted to respond to the pandemic, checking progress on our plans for backlog recovery, and completing regular spot checks to assess progress in our work to support the Government’s regulatory reform programme.
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Audit and risk committee report
At each of its meetings, the committee:
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discussed a wide range of strategic risks to provide an important backdrop to its understanding of the challenges and opportunities the GMC was facing
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considered the assurance it had with respect to how the organisation was responding to emerging threats and opportunities
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challenged our Corporate Opportunities and Risk Register
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continued support for risk maturity evolution in line with the principles of effective risk management set out in the ISO 31000:2009 international guidance standard
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scrutinised audit and learning review findings to satisfy itself that the actions being taken were appropriate
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monitored the implementation of
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recommendations made in previous audit reports to make sure they were being managed effectively by senior management
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reviewed any findings and lessons learnt from work undertaken in relation to significant adverse events.
Other key activities in the year included:
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approving the external audit letter of engagement and scrutinising the Annual report and accounts for 2020
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reviewing the Head of Internal Audit’s annual report and opinion
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commissioning an independent test of our cyber security control arrangements
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reviewing concerns raised to our Freedom to Speak Up (FTSU) Guardian, as reported in the FTSU 2020 annual report
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holding a seminar to understand how we are addressing the committee's corporate social responsibility agenda
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considering risk and assurance through the lens of organisations that experienced a major event or failing of governance and internal controls.
The committee also commissioned an independent review of our arrangements for compliance with BS 10008 standard on the evidential weight and legal admissibility of electronically stored information (ESI), to which the GMC became fully accredited in 2016. The independent reviewer was again complimentary about our work and the ongoing maintenance of high standards despite the continued disruption caused by the pandemic. The review concluded that our information management system is effective in ensuring the trustworthiness of electronic information.
Risk management in 2021
During 2021, the wider context has continued to be dominated by the pandemic. Our priority has continued to be protecting patients, supporting the medical workforce, and the health and well-being of our colleagues. The organisation has continued to adapt to external circumstances and risks. For example, reflecting COVID-19 contexts in fitness to practise decision making, continuing MPTS hearings remotely, developing interim circuits for PLAB 2 clinical assessments, and continually updating plans to ensure a safe return to offices.
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Audit and risk committee report
This ability to handle a diverse range of risks, continually scanning the wider external horizon for emerging threats and opportunities, and work with others across the health landscape illustrates the maturity of our risk arrangements and their resilience.
High-level strategic risk discussions at both Council and Audit and Risk committee provide an important backdrop to understanding the context of the GMC’s activities and the potential to achieve positive impacts for patients and doctors. As well as reflecting on the potential implications of the ongoing nature of the pandemic and thinking about the opportunities for future plans and recovery activities, some of the key areas of risk and opportunity focus in 2021 have been:
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considering the opportunities to re-shape and improve delivery of our statutory responsibilities through the Government’s programme of regulatory reform
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managing preparations for the impact of Brexit
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preparing for the introduction of the Medical Licensing Assessment in 2024
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responding to a range of important public investigations and inquiries, including the Independent Neurology Inquiry in Northern Ireland, the Independent review into West Suffolk Hospital NHS Foundation Trust, and the review into safety of maternity services in England
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developing our approaches to regulatory fairness to eliminate the disproportionate pattern of fitness to practise concerns we receive from employers based on doctors’ ethnicity and place of qualification, and eliminating discrimination, disadvantage, and unfairness in undergraduate and postgraduate medical education and training
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maintaining staff safety and welfare in responding to Government guidance for home working and for return to offices.
Risk thinking is inherent in discussions and operations at all levels of the business. We have a mature set of risk management arrangements embedded in day-to-day activities and risk registers are used as a tool for identifying, articulating, monitoring, and managing operational and project risks which help us identify opportunities to improve how the business is managed and our working environment. Our Corporate Opportunities and Risk Register is published regularly on the website through the ’ Chief Executive s report to Council.
Learning from events and issues
Fundamental to good risk management and developing resilience is the ability to appraise situations openly and honestly when something unexpected arises. We have a robust approach to undertaking significant event and learning reviews to identify opportunities to improve.
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We carried out a number of these in 2021, including:
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a learning review following an incident when sensitive information was inadvertently shared in response to a Freedom of Information request. In this instance the Information Commissioner was notified in line with the statutory GDPR notification process, but they decided not to investigate or take action and subsequently closed the matter.
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a review following the judgment from an employment tribunal in a case where a doctor brought a claim of race and religious discrimination against the GMC, in relation to the handling of a concern regarding their fitness to practise. The tribunal found that the complaint of direct race discrimination was well founded and succeeded. The complaint of discrimination on the grounds of religion and belief was deemed to be not well founded and was dismissed. As part of the review, we undertook an initial exercise to consider immediate learnings to help improve how we respond to future employment tribunal claims and other non-standard litigation. Separately, recognising the potential for racial inequality to affect our activities, we have established a programme of work focused on making sure that existing systems, controls, and approaches on mitigating bias, monitoring differentials, and promoting fairness across our regulatory functions are effective both for now and the longer term (see page 45). The outcomes from this work will become a blueprint for how we embed stronger fairness control mechanisms in our processes as part of the UK Government’s regulatory reform agenda.
Beyond 2021
As we begin to recover from the effects of the pandemic operationally, the external environment will remain uncertain as the wider health system begins to address the mounting backlog of elective activity and we enter a challenging economic period. This will present us with further opportunities and threats. Our ambitious Corporate strategy 2021-2025 and the public commitments we have made require us to remain focused but cognisant of the pressures on partners externally and colleagues internally. Active risk management will continue to be key to aiding us in balancing our work and priorities so that we continue to support doctors and patients.
Key opportunities in 2022
Externally, we have the opportunity to:
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continue working on a legislative reform agenda that transforms us (and other regulators) into a progressive, modern, and flexible regulator
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use our influence, data, and insight to generate pace in our partners’ understanding and support to address inequalities and unfairness in the medical education and wider health system.
Internally we will build momentum to:
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refresh and evolve ways of working to enhance business recovery, building on learning and progress in responding to the pandemic
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advance ways of working that support a culture of inclusivity and innovation, including delivery of our diverse talent and leadership programmes.
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Audit and risk committee report
Key challenges in 2022
There will also be challenges for us to navigate as a regulator and employer, including:
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delivering the policy and operational changes for regulatory reform in line with the timeframes set by the UK Government
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maintaining effective collaboration with key partners whose capacity and organisational efforts are focused on responding to the after effects of the pandemic
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balancing the continued pressures and potential impact on the well-being of our colleagues.
We are not underestimating the scale of these challenges. We know that we cannot achieve the positive impacts patients and doctors deserve if we do not continue to listen to them, to medical leaders, and to patient organisations so that we learn about their experiences and expectations for the future. We have to work with compassion and understanding in a time when society’s expectations are shifting. We must be sensitive and flexible so that we continue to keep patients safe, support doctors, and earn respect for being an effective, relevant, and compassionate regulator and employer.
Approved by the trustees on 22 June 2022 and signed on their behalf by:
Dame Carrie MacEwen
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Independent auditors’ report to the trustees of the GMC
Opinion
We have audited the financial statements of the General Medical Council (‘the charitable company’) and its subsidiary (‘the group’) for the year ended 31 December 2021 which comprise the Consolidated Statement of Financial Activities, Consolidated Balance Sheet, Consolidated Statement of Cash Flows and notes to the financial statements, including significant accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and United Kingdom Accounting Standards, including Financial Reporting Standard 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland (United Kingdom Generally Accepted Accounting Practice).
Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our responsibilities under those standards are further described in the Auditor’s responsibilities for the audit of the financial statements section of our report. We are independent of the charitable company in accordance with the ethical requirements that are relevant to our audit of the financial statements in the UK, including the FRC’s Ethical Standard, and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
In our opinion the financial statements:
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give a true and fair view of the state of the group’s and the charitable company’s affairs as at 31 December 2021 and of the group’s income and expenditure, for the year then ended;
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have been properly prepared in accordance with United Kingdom Generally Accepted Accounting Practice; and
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have been prepared in accordance with the requirements of the Companies Act 2006 and the Charities and Trustee Investment (Scotland) Act 2005 and Regulations 6 and 8 of the Charities Accounts (Scotland) Regulations 2006 (amended).
Conclusions relating to going concern
In auditing the financial statements, we have concluded that the trustee's use of the going concern basis of accounting in the preparation of the financial statements is appropriate.
Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the charitable company's or the group’s ability to continue as a going concern for a period of at least twelve months from when the financial statements are authorised for issue.
Our responsibilities and the responsibilities of the trustees with respect to going concern are described in the relevant sections of this report.
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Independent auditors’ report to the trustees of the GMC
Other information
The trustees are responsible for the other information contained within the annual report. The other information comprises the information included in the annual report, other than the financial statements and our auditor’s report thereon. Our opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated in our report, we do not express any form of assurance conclusion thereon.
Our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated. If we identify such material inconsistencies or apparent material misstatements, we are required to determine whether this gives rise to a material misstatement in the financial statements themselves. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact.
We have nothing to report in this regard.
Opinions on other matters prescribed by the Companies Act 2006
In our opinion based on the work undertaken in the course of our audit:
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the information given in the trustees’ report, which includes the directors’ report and the strategic report prepared for the purposes of company law, for the financial year for which the financial statements are prepared is consistent with the financial statements; and
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the strategic report and the directors’ report included within the trustees’ report have been prepared in accordance with applicable legal requirements.
Matters on which we are required to report by exception
In light of the knowledge and understanding of the group and charitable company and their environment obtained in the course of the audit, we have not identified material misstatements in the strategic report or the directors’ report included within the trustees’ report.
77 General Medical Council
Independent auditors’ report to the trustees of the GMC
We have nothing to report in respect of the following matters in relation to which the Companies Act 2006 and the Charities Accounts (Scotland) Regulations 2006 require us to report to you if, in our opinion:
-
adequate and proper accounting records have not been kept; or
-
the financial statements are not in agreement with the accounting records and returns; or
-
certain disclosures of trustees' remuneration specified by law are not made; or
-
we have not received all the information and explanations we require for our audit.
Responsibilities of trustees
As explained more fully in the trustees’ responsibilities statement set out on page 69, the trustees (who are also the directors of the charitable company for the purposes of company law) are responsible for the preparation of the financial statements and for being satisfied that they give a true and fair view, and for such internal control as the trustees determine is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.
In preparing the financial statements, the trustees are responsible for assessing the charitable company’s ability to continue as a going concern, disclosing, as applicable, matters related to
going concern and using the going concern basis of accounting unless the trustees either intend to liquidate the charitable company or to cease operations, or have no realistic alternative but to do so.
Auditor’s responsibilities for the audit of the financial statements
We have been appointed as auditor under section 44(1)(c) of the Charities and Trustee Investment (Scotland) Act 2005 and under the Companies Act 2006 and report in accordance with the Acts and relevant regulations made or having effect thereunder.
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.
Details of the extent to which the audit was considered capable of detecting irregularities, including fraud and non-compliance with laws and regulations are set out below.
General Medical Council 78
Independent auditors’ report to the trustees of the GMC
A further description of our responsibilities for the audit of the financial statements is located on the Financial Reporting Council’s website at: www.frc. org.uk/auditorsresponsibilities. This description forms part of our auditor’s report.
Extent to which the audit was considered capable of detecting irregularities, including fraud
Irregularities, including fraud, are instances of non-compliance with laws and regulations. We identified and assessed the risks of material misstatement of the financial statements from irregularities, whether due to fraud or error, and discussed these between our audit team members. We then designed and performed audit procedures responsive to those risks, including obtaining audit evidence sufficient and appropriate to provide a basis for our opinion.
We obtained an understanding of the legal and regulatory frameworks within which the charitable company and group operate, focusing on those laws and regulations that have a direct effect on the determination of material amounts and disclosures in the financial statements. The laws and regulations we considered in this context were the Companies Act 2006, Medical Act 1983 and the Charities and Trustee Investment (Scotland) Act 2005 together with the Charities SORP (FRS102). We assessed the required compliance with these laws and regulations as part of our audit procedures on the related financial statement items.
In addition, we considered provisions of other laws and regulations that do not have a direct effect on the financial statements but compliance with which might be fundamental to the charitable company’s and the group’s ability to operate or to avoid a material penalty. We also considered the opportunities and incentives that may exist within the charitable company and the group for fraud. The laws and regulations we considered in this context for the UK operations were, General Data Protection Regulation (GDPR), and employment legislation.
Auditing standards limit the required audit procedures to identify non-compliance with these laws and regulations to enquiry of the trustees and other management and inspection of regulatory and legal correspondence, if any.
We identified the greatest risk of material impact on the financial statements from irregularities, including fraud, to be within the timing of recognition of income, estimates surrounding legal provisions, dilapidations and the override of controls by management. Our audit procedures to respond to these risks included enquiries of management, internal audit, legal counsel and the Audit & Risk Committee about their own identification and assessment of the risks of irregularities, sample testing on the posting of journals, reviewing accounting estimates for biases, reviewing regulatory correspondence with the Charity Commission, performing data analytics on ARF and PLAB income and reading minutes of meetings of those charged with governance.
79 General Medical Council
Independent auditors’ report to the trustees of the GMC
Owing to the inherent limitations of an audit, there is an unavoidable risk that we may not have detected some material misstatements in the financial statements, even though we have properly planned and performed our audit in accordance with auditing standards. For example, the further removed non-compliance with laws and regulations (irregularities) is from the events and transactions reflected in the financial statements, the less likely the inherently limited procedures required by auditing standards would identify it. In addition, as with any audit, there remained a higher risk of non-detection of irregularities, as these may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal controls. We are not responsible for preventing non-compliance and cannot be expected to detect non-compliance with all laws and regulations.
Use of our report
This report is made solely to the charitable company’s members, as a body, in accordance with Chapter 3 of Part 16 of the Companies Act 2006 , and to the charitable company’s trustees, as a body, in accordance with Regulation 10 of the Charities Accounts (Scotland) Regulations 2006 . Our audit work has been undertaken so that we might state to the charitable company’s members those matters we are required to state to them in an auditor’s report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the charitable company and the charitable company’s members as a body and the charitable company’s trustees as a body, for our audit work, for this report, or for the opinions we have formed.
Naziar Hashemi Senior Statutory Auditor For and on behalf of Crowe U.K. LLP Statutory Auditor 55 Ludgate Hill London EC4M 7JW 1 July 2022
General Medical Council 80
Accounts 2021
Consolidated statement of financial activities for the year ended 31 December 2021
| Unrestricted | Restricted | Total | Total | ||
|---|---|---|---|---|---|
| funds | funds | 2021 | 2020 | ||
| Note | £’000 | £’000 | £’000 | £’000 | |
| Income | |||||
| From charitable activities | |||||
| Registration | 2 | 114,545 | - | 114,545 | 103,042 |
| Specialist and GP registration | 2 | 4,047 | - | 4,047 | 4,052 |
| Revalidation | 2 | 107 | - | 107 | 54 |
| Other trading activities | 3 | 337 | - | 337 | 193 |
| Commercial trading operations | 3 | 239 | - | 239 | 316 |
| Investments | 3 | 154 | - | 154 | 388 |
| Department of Health funding - MAPS* | 3 | - | 2,605 | 2,605 | 1,577 |
| Other | 3 | 308 | - | 308 | 242 |
| Total incoming resources | 119,737 | 2,605 | 122,342 | 109,864 | |
| Expenditure | |||||
| Raising funds | |||||
| Commercial tradingoperations | 4 | 246 | - | 246 | 302 |
| Investment management costs | 4 | 249 | - | 249 | 221 |
| 495 | - | 495 | 523 | ||
| Charitable activities | |||||
| Fitness topractise | 4 | 46,882 | - | 46,882 | 42,936 |
| Registration and revalidation | 4 | 29,803 | - | 29,803 | 25,394 |
| External relationships | 4 | 15,319 | - | 15,319 | 15,140 |
| Medical Practitioners Tribunal Service | 4 | 14,012 | - | 14,012 | 11,297 |
| Education | 4 | 9,941 | - | 9,941 | 10,025 |
| Standards | 4 | 1,920 | - | 1,920 | 1,760 |
| Department of Health funding- MAPS | 4 | - | 1,749 | 1,749 | 1,577 |
| 117,877 | 1,749 | 119,626 | 108,129 | ||
| Other expenditure | |||||
| Legalprovision | 11 | 144 | - | 144 | 3,744 |
| Dilapidationsprovision | 11 | 1,882 | - | 1,882 | 973 |
| 2,026 | - | 2,026 | 4,717 | ||
| Total expenditure | 4 | 120,398 | 1,749 | 122,147 | 113,369 |
| Operating surplus/(defcit) | (661) | 856 | 195 | (3,505) | |
| Netgains/(losses)on investments | 8 | 4,879 | - | 4,879 | 2,476 |
| Net income/(Net loss) | 4,218 | 856 | 5,074 | (1,029) | |
| Other recognised gains and losses Actuarial (loss)/gain on defned beneft pension scheme |
16 | 30,143 | - | 30,143 | (6,971) |
| Net movement in funds | 34,361 | 856 | 35,217 | (8,000) | |
| Total funds brought forward | 64,581 | - | 64,581 | 72,581 | |
| Total funds carried forward | 98,942 | 856 | 99,798 | 64,581 |
81 General Medical Council
Accounts 2021
The General Medical Council incorporated a wholly owned trading subsidiary on 16 December 2016 with the purpose of providing services on a commercial basis including consultancy, training and accreditation. The Charity has taken exemption from presenting its unconsolidated profit and loss account. The charity movement in funds for the year is £35,217,000.
- The Department for Health and Social Care (DHSC) provided funding in 2021 to continue implementation work to bring physician associates and anaesthesia associates under regulation with the General Medical Council. Funding was restricted in nature, and was fully spent in the year. A proportion of the funds paid for IT System Development which has created an asset on the balance sheet. The net impact on GMC reserves is £856,000. The balance of the reserves will reduce when the asset is amortised in future periods.
General Medical Council 82
Accounts 2021
Balance sheet
| 2021 | 2020 | ||||
|---|---|---|---|---|---|
| Group | Charity | Group | Charity | ||
| Note | £’000 | £’000 | £’000 | £’000 | |
| Fixed assets | |||||
| Intangible fxed assets | 6 | 11,702 | 11,702 | 10,361 | 10,361 |
| Tangible fxed assets | 7 | 6,305 | 6,305 | 7,519 | 7,519 |
| Investments | 8 | 61,649 | 61,879 | 57,020 | 57,257 |
| 79,656 | 79,886 | 74,900 | 75,137 | ||
| Current assets | |||||
| Debtors andprepayments | 9 | 24,041 | 24,096 | 23,349 | 23,303 |
| Cash and bank balances | 46,821 | 46,502 | 38,128 | 37,882 | |
| 70,862 | 70,598 | 61,477 | 61,185 | ||
| Liabilities | |||||
| Creditors: amounts fallingdue within oneyear | 10 | (80,538) | (80,504) | (71,067) | (71,012) |
| Net current liabilities | (9,676) | (9,906) | (9,590) | (9,827) | |
| Total assets less current liabilities | 69,980 | 69,980 | 65,310 | 65,310 | |
| Provisions for liabilities and charges | 11 | (6,743) | (6,743) | (4,717) | (4,717) |
| Net assets excluding pension scheme asset | 63,237 | 63,237 | 60,593 | 60,593 | |
| Defned beneftpension scheme asset | 16 | 36,561 | 36,561 | 3,988 | 3,988 |
| Total net assets | 99,798 | 99,798 | 64,581 | 64,581 | |
| Unrestricted income funds | 62,381 | 62,381 | 60,593 | 60,593 | |
| Restricted income funds | 856 | 856 | - | - | |
| Pension reserve | 36,561 | 36,561 | 3,988 | 3,988 | |
| Total funds | 12,13 | 99,798 | 99,798 | 64,581 | 64,581 |
The financial statements were approved by the trustees and authorised for issue on 22 June 2022. They were signed on behalf of trustees by:
Dame Carrie MacEwen Chair of Council
83 General Medical Council
Accounts 2021
Consolidated cash flow statement
| 2021 | 2020 | |||||
|---|---|---|---|---|---|---|
| £’000 | £’000 | £’000 | £’000 | |||
| Cash fows from operating activities: | ||||||
| Net cashprovided by/(used in) operating activities(note i below) | 16,902 | 14,064 | ||||
| Cash fows from investing activities: | ||||||
| Dividends,interest and rents from investments | 84 | 180 | ||||
| Purchase ofproperty, plant,equipment and intangibles | (8,293) | (6,783) | ||||
| Net cash used in investing activities | (8,209) | (6,603) | ||||
| Change in cash and cash equivalents (note ii below) | 8,693 | 7,461 |
| Note (i) | ||
|---|---|---|
| Cash fow from operating activities | ||
| Net incoming/(outgoing) resources | 5,074 | (1,029) |
| Investment income and interest | (154) | (388) |
| Net investment movement | (4,629) | 8,029 |
| Non-cash items - depreciation and amortisation | 8,165 | 7,854 |
| Non-cash items - assets written off | 1 | 47 |
| Pension scheme contribution | (2,360) | (1,360) |
| (Increase)/decrease in debtors | (692) | (2,200) |
| Increase/(decrease)in creditors andprovisions | 11,497 | 3,111 |
| Net cashprovided by/(used in) operating activities | 16,902 | 14,064 |
| Cash at | |||
|---|---|---|---|
| Note (ii) | bank | ||
| Short-term | and in | ||
| deposits | hand | Total | |
| Cash and equivalents | £’000 | £’000 | £’000 |
| Balances at 1January2021 | - | 38,128 | 38,128 |
| Net increase in cash and cash equivalents | - | 8,693 | 8,693 |
| Balances at 31 December 2021 | - | 46,821 | 46,821 |
General Medical Council 84
Accounts 2021
Notes to the accounts
General information
We are a statutory body governed by the Medical Act 1983 and are registered with the Charity Commission for England and Wales (1089278), and with the Office of the Scottish Charity Regulator (SC037750).
1. Principal accounting policies
(i) Accounting convention
The financial statements have been prepared to give a ‘true and fair’ view and have departed from the Charities (Accounts and Reports) Regulations 2008 only to the extent required to provide a ‘true and fair’ view. This departure has involved following the Charities SORP (FRS 102) first published on 16 July 2014, updated 1 October 2019.
Our financial statements have been prepared on a going concern basis and in accordance with the Charities Statement of Recommended Practice (FRS 102) - effective 1 October 2019, applicable to charities preparing their accounts in accordance with the Financial Reporting Standard applicable in the UK and Republic of Ireland, the Charities Act 2011, the Charities and Trustee Investment (Scotland) Act 2005, the Charities Accounts (Scotland) Regulations 2006 and UK Generally Accepted Practice as it applies from 1 October 2019. The GMC meets the definition of a public benefit entity under FRS 102.
- (ii) On 16 December 2016 the GMC incorporated a trading subsidiary, GMC Services International LTD, company number 10530157, which is wholly owned by share capital by the General Medical Council.
Incoming resources
Income is included in the statement of financial activities when all of the following criteria are met:
-
Entitlement - control over the rights or other access to the economic benefit has passed to the GMC
-
Probability - it is more likely than not that the economic benefits will flow to the GMC
-
Measurement - the value can be measured reliably.
The following specific policies apply:
-
Annual retention fees relate to services to be provided over a 12-month period. Income is deferred and released to the statement of financial activities on a straight-line basis over the period to which the income relates.
-
Registration fees, including provisional registration fees, are recognised when registration is granted.
-
Professional and Linguistic Assessments Board (PLAB) fees are recognised when the examinations are sat.
-
Income from investments and funds held on deposit is recognised when it is receivable and the amount can be accurately measured.
All income is recognised gross.
- (iii) The principal accounting policies adopted in the preparation of the financial statements, which have been applied consistently, are:
85 General Medical Council
Accounts 2021
Basis for recognising liabilities
Expenditure includes staffing costs, office costs, committee costs, legal costs, accommodation costs, purchase of assets, and financial, actuarial and professional costs.
Resources expended are included in the statement of financial activities on an accruals basis. All liabilities are recognised as soon as there is a legal or constructive obligation committing the charity to expenditure.
Basis for allocation of resources expended
The majority of our resources are expended directly in pursuit of our charitable aims, and are identified as such in the statement of financial activities.
Accommodation costs, governance costs and other support costs are apportioned to charitable activities on the basis of staff head count across the organisation.
Irrecoverable VAT
Any irrecoverable VAT is charged to the statement of financial activities as part of the relevant item of expenditure, or capitalised as part of the cost of the related asset where appropriate.
Taxation
We can take advantage of the exemptions from taxation on income and gains available to charities, so no taxation is payable on the net incoming resources.
Debtors
Creditors and provisions for liabilities
Creditors and provisions are recognised when the charity has a present legal or constructive obligation as a result of a past event. They are recognised when it is probable that a transfer of economic benefit will be required to settle the obligation and a reliable estimate can be made of the amount of the obligation. Creditors and provisions are normally recognised at their settlement amount after allowing for any trade discounts due.
Critical accounting judgements and key sources of estimation uncertainty
The key sources of estimation uncertainty that have a significant effect on the amounts recognised in the financial statements are:
-
All unsettled claims for legal costs made against the GMC are reviewed on a case-by-case basis at the year end. Provisions are based on historical experience and a detailed assessment of the specific details of current cases. The final settlement of cases is dependent on a number of factors, so the accuracy of the provision is subject to a significant degree of uncertainty.
-
Provisions for property dilapidation costs are made for all leased buildings. They are assessed on a case-by-case basis reflecting the different configurations of leased buildings and the cost to revert to their original state.
-
Provisions for holiday pay are based on the actual level of accrued days and salaries of each staff member.
Trade and other debtors are normally recognised at the settlement amount due after any trade discount offered. Prepayments are normally valued at the amount prepaid net of any trade discounts due.
General Medical Council 86
Accounts 2021
Tangible fixed assets
Tangible fixed assets are stated at cost, net of depreciation and any provision for impairment. Expenditure is only capitalised where the cost of the asset or group of assets acquired exceeds £5,000.
Intangible fixed assets
Intangible fixed assets comprise computer software. They are stated at cost, net of amortisation and any provision for impairment. Expenditure is only capitalised where the cost of the asset or group of assets acquired exceeds £5,000.
Licensed IT software
Development costs for implementing new IT systems are capitalised and depreciated over the lesser of 3 years or the useful life of the asset. The first year license costs are capitalised as they are necessary to bring the asset into use, subsequent year license costs are treated as operating expenditure.
Operating leases
Rent payable under operating leases is charged to the statement of financial activities on a straightline basis over the period of the lease.
Depreciation
Depreciation is provided so as to write off the cost, less estimated residual value, of the assets evenly over their estimated lives.
The estimated useful lives are as follows:
-
Leasehold buildings and leasehold improvements - the lesser of five years or the remaining term of the lease.
-
Furniture, fixtures, and office fittings - the lesser of five years or the remaining term of the lease.
-
Information Technology (IT) equipment - three years.
Financial instruments
The charity has financial assets and liabilities of a kind that qualify as basic financial instruments. Basic financial instruments are initially recognised at transaction value and subsequently measured at amortised cost. Financial assets held at amortised cost consist of cash and bank balances, short-term deposits (cash flow statement), investments held in cash deposits (note 8) together with trade and other debtors (note 9). Financial liabilities held at amortised cost comprise trade and other creditors, tax and social security creditors and accruals (note 10).
Investments
-
Intangible assets: (IT software) - three years.
-
Other office equipment - three years for ITrelated items and five years for all other items
Depreciation rates are reviewed on a regular basis comparing actual lives of assets with the accounting policy rates.
Our investment policy separates our funds into four categories: those which are required as working capital for the normal day to day operation of the business; those which we invest under management; those which we may decide to invest in a trading subsidiary; and the remaining cash balance which fluctuates during the year.
Funds held as cash for the normal day to day operation of the business are shown on the GMC’s balance sheet within current assets, while funds held for the longer term are shown as investments.
87 General Medical Council
Accounts 2021
Pensions
We have a defined benefit pension scheme for permanent employees. The scheme was closed to new members on 30 June 2013, and for future accrual to existing members on 31 March 2018, and replaced by a defined contribution scheme. The surplus or deficit of the defined benefit scheme is recognised on the balance sheet. Changes in the assets and liabilities of the scheme are disclosed and allocated as follows:
-
Charges relating to current or past service costs, and gains and losses on settlements and curtailments, are included within staff costs and charged to the statement of financial activities
-
1 member of staff who transferred to the GMC on the merger with the Postgraduate Medical Education and Training Board (PMETB), contribute to the NHS multi-employer scheme and contributions to the scheme are charged to the statement of financial activities in the year in which they are payable to the scheme.
Funds and reserves
The majority of our funds are unrestricted, and so can be expended at the trustees’ discretion in pursuit of our charitable aims. Restricted funds will be expended in line with the purpose of the funding.
Termination payments
- Interest on the net defined benefit asset/liability is shown as a net amount of other finance costs or as an incoming resource alongside investment income and interest. Actuarial gains and losses are recognised immediately in other recognised gains and losses on investments.
Termination payments are accounted for as soon as the organisation is aware of the obligation to make the payment.
-
The assets, liabilities and movements in the surplus or deficit of the scheme are calculated by qualified independent actuaries as an update to the latest full actuarial valuation. Details of the defined benefit scheme assets, liabilities and major assumptions are shown in the notes to the accounts.
-
Our defined contribution pension scheme was set up on 1 July 2013. Contributions to the scheme are charged to the statement of financial activities in the year in which they are payable to the scheme.
General Medical Council 88
Accounts 2021
2. Income from charitable activities
| Unrestricted | Total | Unrestricted | Total | |
|---|---|---|---|---|
| funds | 2021 | funds | 2020 | |
| £’000 | £’000 | |||
| Registration | ||||
| Annual retention fees | 99,025 | 99,025 | 93,428 | 93,428 |
| Registration fees | 4,630 | 4,630 | 3,916 | 3,916 |
| Provisional registration fees | 416 | 416 | 25 | 25 |
| PLAB fees | 10,388 | 10,388 | 5,576 | 5,576 |
| Other fees | 86 | 86 | 97 | 97 |
| 114,545 | 114,545 | 103,042 | 103,042 | |
| Specialist and GP registration | ||||
| Certifcates of Completion of Trainingfees | 2,949 | 2,949 | 2,790 | 2,790 |
| Certifcate of Eligibility for Specialist Registration/ | 1,072 | 1,072 | 1,220 | 1,220 |
| Certifcate of Eligibility for General Practitioner | ||||
| Registration fees | ||||
| Other fees | 26 | 26 | 42 | 42 |
| 4,047 | 4,047 | 4,052 | 4,052 | |
| Revalidation | ||||
| Revalidation annual return | 98 | 98 | 48 | 48 |
| Revalidation assessment | 9 | 9 | 6 | 6 |
| 107 | 107 | 54 | 54 |
89 General Medical Council
Accounts 2021
3. Income from raising funds
| Unrestricted | Restricted | Total | Unrestricted | Restricted | Total | |
|---|---|---|---|---|---|---|
| funds | funds | 2021 | funds | funds | 2020 | |
| £’000 | £’000 | |||||
| Activities for raising funds | ||||||
| Other tradingactivities* | 337 | - | 337 | 193 | - | 193 |
| Commercial tradingoperations† | 239 | - | 239 | 316 | - | 316 |
| Other‡ | 308 | - | 308 | 242 | - | 242 |
| 884 | - | 884 | 751 | - | 751 | |
| Investment income | ||||||
| Other fnance income - pension | 70 | - | 70 | 208 | - | 208 |
| scheme(note 16) | ||||||
| Bank interest | 84 | - | 84 | 180 | - | 180 |
| 154 | - | 154 | 388 | - | 388 | |
| Department of Health funding | ||||||
| Funding to cover expenditure on | - | 2,605 | 2,605 | - | 1,577 | 1,577 |
| Medical Associate Professionals | ||||||
| regulation¶ |
-
Other trading activities include the reimbursement of costs of visiting overseas medical schools and the reimbursement of costs of staff seconded to external bodies.
-
Income from commercial trading operations is derived from GMC Services International Ltd, a wholly owned subsidiary, which provides services on a commercial basis including consultancy, training and accreditation.
‡ Other income includes reimbursement of legal fees from appeals and transaction fees generated through registration status changes.
¶ The Department of Health and Social Care have provided funding for the General Medical Council to start implementation work to bring physician associates and anaesthesia associates under regulation with the General Medical Council. The work is ongoing and legislation is expected to be in place for regulation to start no sooner than 2023.
General Medical Council 90
Accounts 2021
4. Total expenditure
Charitable activity and support cost allocation
| Direct staffng costs | Direct costs | Allocated costs | Total 2021 | Direct staffng costs | Direct costs | Allocated costs | Total 2020 | |
|---|---|---|---|---|---|---|---|---|
| £’000 | £’000 | £’000 | £’000 | £’000 | £’000 | £’000 | £’000 | |
| Expenditure on: | ||||||||
| Commercial trading operations | 216 | 30 | - | 246 | 266 | 36 | - | 302 |
| Investment management costs | - | 249 | - | 249 | - | 221 | - | 221 |
| Total expenditure on raising funds | 216 | 279 | - | 495 | 266 | 257 | - | 523 |
| Fitness to practise Registration and revalidation External relationships* Medical Practitioners Tribunal Service Education Standards Department of Health funding- MAPS |
21,354 12,077 8,948 4,782 5,841 1,109 1,196 |
6,774 5,915 602 4,972 345 13 553 |
18,754 11,811 5,769 4,258 3,755 798 - |
46,882 29,803 15,319 14,012 9,941 1,920 1,749 |
20,168 10,491 8,992 4,295 6,048 1,002 1,185 |
4,597 4,403 506 3,054 151 2 392 |
18,171 10,500 5,642 3,948 3,826 756 - |
42,936 25,394 15,140 11,297 10,025 1,760 1,577 |
| Total charitable expenditure | 55,307 | 19,174 | 45,145 | 119,626 | 52,181 | 13,105 | 42,843 | 108,129 |
| Other expenditure - legal provision Other expenditure - dilapidationprovision |
- - |
144 1,882 |
- - |
144 1,882 |
- - |
3,744 973 |
- - |
3,744 973 |
| Totalgroup expenditure | 55,523 | 21,479 | 45,145 | 122,147 | 52,447 | 18,079 | 42,843 | 113,369 |
- External relationships include the work done by our Regional Liaison Service, strategic relationships, our devolved offices, and our European and international development activities.
| Fitness to practise Registration and revalidation External relationships* Medical Practitioners Tribunal Service Education Standards |
Support costs allocated to charitable activities |
|---|---|
| Management IT Human resources Finance Procurement Facilities Governance Total 2021 Management IT Human resources Finance Procurement Facilities Governance Total 2020 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 |
|
| 3,249 6,066 2,367 875 161 4,678 1,358 18,754 3,237 5,817 2,082 756 154 4,744 1,381 18,171 2,046 3,820 1,490 551 102 2,946 856 11,811 1,871 3,361 1,203 437 89 2,741 798 10,500 999 1,866 728 269 50 1,439 418 5,769 1,005 1,806 646 235 48 1,473 429 5,642 738 1,377 537 199 37 1,062 308 4,258 703 1,264 452 164 34 1,031 300 3,948 650 1,215 474 175 32 937 272 3,755 682 1,225 438 159 32 999 291 3,826 138 258 101 37 7 199 58 798 135 242 87 31 6 198 57 756 |
|
| Total charitable expenditure | 7,820 14,602 5,697 2,106 389 11,261 3,270 45,145 7,633 13,715 4,908 1,782 363 11,186 3,256 42,843 |
Support costs are allocated to charitable activities on the basis of staff head count across the organisation.
Support cost recharges have been made to both the trading subsidiary, GMCSI, and the MAPS project throughout the year on a direct basis therefore are treated separately to the year end allocation.
91 General Medical Council
Accounts 2021
Group expenditure by type
| Charitable activities 2021 Expenditure on raising funds 2021 Department of Health funding - MAPS 2021 Other expenditure 2021 Total 2021 Charitable activities 2020 Expenditure on raising funds 2020 Department of Health funding - MAPS 2020 Other expenditure 2020 Total 2020 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 £’000 |
|
|---|---|
| Staffng costs Offce costs Council and committee costs Panel and assessment costs Legal costs Accommodation costs Financial, actuarial and professional costs Purchase of assets - charged to revenue Assets written off Depreciation Amortisation |
74,880 216 1,196 - 76,292 71,692 266 1,185 - 73,143 1,412 24 530 - 1,966 1,558 29 392 - 1,979 359 - - - 359 435 1 - - 436 13,220 - - - 13,220 9,296 - - - 9,296 4,408 - - 144 4,552 2,627 - - 3,744 6,371 7,016 - - 1,882 8,898 5,876 - - 973 6,849 4,115 255 23 - 4,393 3,371 228 - - 3,599 4,301 - - - 4,301 3,795 - - - 3,795 1 - - - 1 47 - - - 47 3,163 - - - 3,163 3,070 - - - 3,070 5,002 - - - 5,002 4,784 - - - 4,784 |
| 117,877 495 1,749 2,026 122,147 106,551 524 1,577 4,717 113,369 |
| Total resources expended includes: | ||
|---|---|---|
| 2021 | 2020 | |
| Operating lease costs: leasehold property and equipment | 3,639 | 3,505 |
| Audit fees | 43 | 43 |
General Medical Council 92
Accounts 2021
5. Staff
| 2021 2020 £’000 £’000 |
|
|---|---|
| Total costs of all staff | |
| Salaries | 59,022 56,922 |
| Social securitycosts | 6,189 5,874 |
| Superannuation costs - defned contribution scheme | 8,487 7,928 |
| Redundancycosts | 202 - |
| Other staffngcosts | 2,392 2,419 |
| 76,292 73,143 |
During the year the General Medical Council made termination payments of £40,000 (2020: £0), a further £162,000 was paid after year-end relating to decisions within 2021, giving a total expense for the year of £202,000 (2020: £0).
| 2021 2020 |
2021 2020 |
|---|---|
| Average staff numbers in theyear by category | |
| Fitness topractise | 478 460 |
| Registration and revalidation | 301 266 |
| External relationships | 147 143 |
| Medical Practitioners Tribunal Service | 109 100 |
| Education | 96 97 |
| Standards | 20 19 |
| Governance and Management | 154 145 |
| Resources | 217 211 |
| GMC Services International Ltd | 1,522 1,441 |
| 1 1 |
|
| 1,523 1,442 |
93 General Medical Council
Accounts 2021
The number of staff whose total employee benefits (excluding employer pension contributions) fell into higher salary bands was:
| 2021 2020 |
|
|---|---|
| GMC | |
| £60,000–£70,000 £70,001–£80,000 £80,001–£90,000 £90,001–£100,000 £100,001–£110,000 £110,001–£120,000 £120,001–£130,000 £130,001–£140,000 £140,001–£150,000 £150,001–£160,000 £160,001–£170,000 £170,001–£180,000 £180,001–£190,000 £190,001–£200,000 £200,001–£210,000 £210.001–£220,000 £220,001–£230,000 £230,001–£240,000 £240,001–£250,000 £250,001–£260,000 |
52 59 57 42 28 29 14 12 7 7 11 11 9 7 3 5 4 3 1 - - - - - - - - 1 6 4 - - - 1 - - - - 1 1 |
| MPTS | 193 182 |
| £60,000–£70,000 £70,001–£80,000 £80,001–£90,000 £90,001–£100,000 £100,001–£110,000 £110,001–£120,000 |
2 2 1 1 2 2 1 1 - 1 1 - |
| 7 7 |
|
| Total | 200 189 |
General Medical Council 94
Accounts 2021
| 2021 2020 |
|
|---|---|
| Number of staff included above for whom retirement benefts are accruing GMC defned contribution pension scheme NHS defned beneft pension scheme Not in scheme |
197 186 1 1 2 2 |
| 200 189 |
The senior management team includes the Chief Executive and six permanent directors in 2021. The total employee benefits (including employer pension contributions) of the senior management team was £1,705,118 in 2021. The equivalent figure for 2020 was £1,739,919.
| Basic salary 2021 | |
|---|---|
| (bands of £5,000) | |
| Senior management team remuneration | |
| £’000 | |
| Charlie Massey | 245–250 |
| Paul Reynolds | 200–205 |
| Anthony Omo | 200–205 |
| Shaun Gallagher | 200–205 |
| Una Lane | 200–205 |
| Neil Roberts | 200–205 |
| Colin Melville | 200–205 |
All GMC staff, including the senior management team, are entitled to pension contributions of 15% of salary into the GMC Group Personal Pension Plan and may exchange contributions for salary.
All GMC staff, including the senior management team, are entitled to buy and sell leave and to the taxable benefit of private medical insurance. These costs and benefits are not included in the table above.
The Chief Executive’s salary is 7.67 times the median salary.
There were no related party transactions in the year that require disclosure other than payments made to Trustees as disclosed in notes 17 and 18.
95 General Medical Council
Accounts 2021
6. Intangible fixed assets
Group and charity
| Group and charity | |
|---|---|
| Computer software and systems development | |
| £’000 | |
| Cost | |
| Balance at 1 January 2021 | 28,410 |
| Additions | 6,343 |
| Disposals | (3,804) |
| Balance at 31 December 2021 | 30,949 |
| Amortisation | |
| Balance at 1 January 2021 | 18,049 |
| Amortisation charge for year | 5,002 |
| Disposals | (3,804) |
| Balance at 31 December 2021 | 19,247 |
| Balance at 1January2021 | 10,361 |
| Net book value at 31 December 2021 | 11,702 |
Intangible assets incorporates all IT software development costs including, but not limited to, the development of our strategic applications, Siebel, Livelink and Agresso, the development of IT security systems, facilities management systems and website. Intangible assets also include the systems to support working from home and mobile applications.
General Medical Council 96
Accounts 2021
7. Tangible fixed assets
Group and charity
| Group and charity | |
|---|---|
| Cost | Buildings Fixtures, furniture and equipment IT equipment Total £’000 £’000 £’000 £’000 |
| Balance at 1 January 2021 Additions Disposals |
2,188 13,353 9,344 24,885 - 1,180 770 1,950 - (1) (2,042) (2,043) |
| Balance at 31 December 2021 | 2,188 14,532 8,072 24,792 |
| Depreciation | |
| Balance at 1 January 2021 Depreciation charge for year Disposals |
1,918 8,157 7,291 17,366 82 1,913 1,168 3,163 - - (2,042) (2,042) |
| Balance at 31 December 2021 | 2,000 10,070 6,417 18,487 |
| Net book value at 1January2021 | 270 5,196 2,053 7,519 |
| Net book value at 31 December 2021 | 188 4,462 1,655 6,305 |
97 General Medical Council
Accounts 2021
8. Investments
| Managed funds Group Charity Cash & cash equivalents Listed Investments Total Cash & cash equivalents Listed Investments Equity Investment in Group Undertakings Total £'000 £’000 £’000 £'000 £'000 £'000 £'000 The valuation at the end of the year consisted of: |
Managed funds Group Charity Cash & cash equivalents Listed Investments Total Cash & cash equivalents Listed Investments Equity Investment in Group Undertakings Total £'000 £’000 £’000 £'000 £'000 £'000 £'000 The valuation at the end of the year consisted of: |
|---|---|
| As at 1 January 2021 - 57,020 57,020 Additions - 11,252 11,252 Disposals - (11,502) (11,502) Gain on investments - 4,879 4,879 (Impairment)/reversal of impairment - - (-)* |
- 57,020 237 57,257 - 11,252 - 11,252 - (11,502) - (11,502) - 4,879 - 4,879 - - (7) (7) |
| Balance at 31 December 2021 - 61,649 61,649 |
- 61,649 230 61,879 |
* The General Medical Council incorporated a wholly owned trading subsidiary on 16 December 2016. Having previously been impaired by £363k due to trading losses incurred, an additional £7k impairment at the end of 2021 has been recognised as a result of the loss generated by the company reducing its net assets. Listed investments are managed by CCLA Investment Management Ltd. Investment management fees of £249,422 were incurred (2020 £221,160).
General Medical Council 98
Accounts 2021
9. Debtors
| Amounts falling due within one year | 2021 2020 Group Charity Group Charity £’000 £’000 £’000 £’000 |
|---|---|
| Registration debtors Prepayments and accrued income Other debtors |
18,810 18,810 17,539 17,539 5,054 5,121 5,325 5,416 177 165 485 348 |
| 24,041 24,096 23,349 23,303 |
10. Creditors
| 10. Creditors | |
|---|---|
| Amounts falling due within one year | 2021 2020 Group Charity Group Charity £’000 £’000 £’000 £’000 |
| Trade creditors Tax and social security Holiday pay Accruals Deferred income |
877 872 1,129 1,120 1,829 1,825 1,774 1,771 1,106 1,106 1,763 1,763 9,050 9,025 8,378 8,335 67,676 67,676 58,023 58,023 |
| 80,538 80,504 71,067 71,012 |
Charity deferred income
Income from annual retention fees is deferred and released to the statement of financial activities on a straight-line basis over a 12 month period from the date of renewal. All deferred income brought forward from the previous year is released to the statement of financial activities in the following year. Professional and Linguistic Assessments Board (PLAB) fees are deferred to the date the examination is sat.
| Specialist | |||||
|---|---|---|---|---|---|
| Annual | and GP | Revalidation | |||
| retention | PLAB | registration | assessment | ||
| fees | fees | fees | fees | Total | |
| £’000 | £’000 | £’000 | £’000 | £’000 | |
| Deferred income at 1 January 2021 | 54,927 | 3,075 | 21 | - | 58,023 |
| Resources deferred during the year | 57,356 | 10,222 | 57 | 41 | 67,676 |
| Amounts released frompreviousyears | (54,927) | (3,075) | (21) | - | (58,023) |
| Deferred income at 31 December 2021 |
57,356 | 10,222 | 57 | 41 | 67,676 |
99 General Medical Council
Accounts 2021
11. Provisions
Group and charity
| Group and charity | |
|---|---|
| Dilapidations Legal claims |
2021 2020 £’000 £’000 |
| 2,855 973 |
|
| 3,888 3,744 |
|
| 6,743 4,717 |
Dilapidations - each year we review our property leases and make a provision for dilapidations, where the cost can be reasonably estimated. Legal claims - Each year we make a provision for potential costs related to ongoing legal cases. In 2020 we increased the provision to reflect potential additional costs that may arise following the outcome of an employment tribunal. The outcome is still outstanding, but may have implications for a wider group of individuals. Further details in relation to the ongoing case cannot be provided in order to avoid prejudicing proceedings.
| Dilapidations | Legal claims | Total | |
|---|---|---|---|
| £’000 | £’000 | £’000 | |
| Provisions at 1 January 2021 | 973 | 3,744 | 4,717 |
| Provisions created during the year | 2,855 | 3,888 | 6,743 |
| Amounts released frompreviousyears | (973) | (3,744) | (4,717) |
| Provisions at 31 December 2021 | 2,855 | 3,888 | 6,743 |
General Medical Council 100
Accounts 2021
12. Group fund movements in the year
Group and charity
| Group and charity | ||||
|---|---|---|---|---|
| Unrestricted | Restricted | Pension | 2021 | |
| funds | funds | fund | Total | |
| £’000 | £’000 | £’000 | £’000 | |
| At 1 January 2021 | 60,593 | - | 3,988 | 64,581 |
| Net incoming/(outgoing)resources | 1,788 | 856 | 32,573 | 35,217 |
| At 31 December 2021 | 62,381 | 856 | 36,561 | 99,798 |
| Unrestricted | Restricted | Pension | 2020 | |
| funds | funds | fund | Total | |
| £’000 | £’000 | £’000 | £’000 | |
| At 1 January 2020 | 63,190 | - | 9,391 | 72,581 |
| Net incoming/(outgoing)resources | (2,597) | - | (5,403) | (8,000) |
| At 31 December 2020 | 60,593 | 3,988 | 64,581 |
101 General Medical Council
Accounts 2021
13. Net assets by fund
Group and charity
Fund balances at 31 December 2021 are represented by
| Restricted | ||||
|---|---|---|---|---|
| Unrestricted | fxed asset | Pension | 2021 | |
| funds | funds | reserve | Total funds | |
| £’000 | £’000 | £’000 | £’000 | |
| Intangible fxed assets | 10,846 | 856 | - | 11,702 |
| Tangible fxed assets | 6,305 | - | - | 6,305 |
| Investments | 61,649 | - | - | 61,649 |
| Current assets | 70,862 | - | - | 70,862 |
| Current liabilities | (80,538) | - | - | (80,538) |
| Provisions for liabilities and charges | (6,743) | - | - | (6,743) |
| Pension scheme asset | - | - | 36,561 | 36,561 |
| Total net assets | 62,381 | 856 | 36,561 | 99,798 |
| Restricted | ||||
| Unrestricted | fxed asset | Pension | 2020 | |
| funds | funds | reserve | Total funds | |
| £’000 | £’000 | £’000 | £’000 | |
| Intangible fxed assets | 10,361 | - | - | 10,361 |
| Tangible fxed assets | 7,519 | - | - | 7,519 |
| Investments | 57,020 | - | - | 57,020 |
| Current assets | 61,477 | - | - | 61,477 |
| Current liabilities | (71,067) | - | - | (71,067) |
| Provisions for liabilities and charges | (4,717) | - | - | (4,717) |
| Pension scheme asset | - | - | 3,988 | 3,988 |
| Total net assets | 60,593 | - | 3,988 | 64,581 |
14. Capital commitments
Capital expenditure contracted but unspent at 31 December 2021 amounted to £63,936. The equivalent figure for 2020 was £93,288.
General Medical Council 102
Accounts 2021
15. Operating lease commitments
| Expiry date | Land and buildings Equipment |
|---|---|
| 2021 2020 2021 2020 £’000 £’000 £’000 £’000 |
|
| Within one year In years two to fve After more than fveyears |
4,359 3,649 97 145 7,723 11,119 48 48 1,974 2,876 - - |
| 14,056 17,644 145 193 |
Commitments include our obligations under our buildings and equipment leases. They are calculated up to the first lease break clause or lease end where there is no break clause in the agreeement. Commitments are calculated on a cash basis rather than incorporating rent free benefits.
103 General Medical Council
Accounts 2021
16. Superannuation schemes
The GMC has three staff pension schemes:
GMC Group Personal Pension Plan
This is a defined contribution pension scheme, which was set up on 1 July 2013. We started auto enrolment on 1 November 2013. At the end of 2021 there were 1,536 members of staff contributing to this scheme. It meets the government’s requirements following the introduction of automatic enrolment. Individuals can choose to make additional contributions by deduction from salary to the scheme. Under the terms of FRS102, contributions are accounted for as a defined contribution scheme based on actual contributions paid through the year.
NHS Multi-Employer Scheme
We have 1 member of staff who contribute to the NHS multi-employer scheme, which is a defined benefit scheme. The staff member transferred to the GMC on the merger with PMETB. The scheme operates as a pooled arrangement, with contributions paid at a centrally agreed rate. The trustees are unable to confirm the GMC’s share of the underlying assets and liabilities of the NHS scheme and so, under the terms of FRS102, contributions are accounted for as if the scheme were a defined contribution scheme based on actual contributions paid through the year.
GMC Staff Superannuation Scheme
This is a funded scheme of the defined benefit type, providing retirement benefits based on final salary. The top-up arrangement is an unfunded scheme.
This scheme was closed to new members on 30 June 2013, and replaced by the GMC Group Personal Pension Plan. The scheme was closed to future accruals for existing members on 31 March 2018 therefore at the end of 2018 there were no members of staff contributing to this scheme.
The FRS 102 valuation has been based on a full assessment of the liabilities for the Scheme as at 31 December 2018. The present values of the defined benefit obligation, the related current service cost and any past service costs were measured using the projected unit credit method. There is an ongoing full assessment of the pension liabilities which is set to conclude late 2022. The output of this will form the basis of the 2022 FRS102 valuation.
Actuarial gains and losses have been recognised in the period in which they occur (but outside the profit and loss account) through the Other Comprehensive Income (OCI).
The GMC recognises surplus in accordance with the requirements of FRS 102 Section 18. The trustees of the Scheme do not have the unilateral right to commence wind-up of the Scheme. Thus, the GMC assumes that the Scheme continues in existence until the last benefit payments are made to members, at which point any residual assets are returned to the GMC in line with the rules of the Scheme.
General Medical Council 104
Accounts 2021
The GMC made a two top-up payments to the scheme of £2.3m in total during 2021 and will contribute a top up payment to the scheme of £1.3m each year between 2022 and 2025.
Responsibility for investing pension scheme assets rests with pension trustees. The Pensions Act 1995 requires trustees to draw up a Statement of Investment Principles, setting out the scheme’s investment strategy. Pension trustees are required to
consult the employer (GMC) when drawing up the strategy, but do not require the employer’s formal agreement. Following consultation with the GMC, in 2014 the pension trustees adopted a fiduciary management approach to the investment of the scheme’s assets
The principal assumptions used by the independent qualified actuaries to calculate the liabilities under FRS102 are set out below.
Main financial assumptions
| Main fnancial assumptions | |
|---|---|
| Retail Prices Index infation Consumer Price Index infation Rate of general long-term increase in salaries Pension increases (excess over guaranteed minimum pension) Discount rate for scheme liabilities |
31 December 2021 31 December 2020 %pa %pa |
| 3.1 2.7 2.7 2.3 3.7 3.3 2.7 2.3 1.9 1.4 |
105 General Medical Council
Accounts 2021
Mortality assumptions
The mortality assumptions are based on standard mortality tables which allow for expected future mortality improvements. The assumptions are that a member currently aged 65 will live on average for a further 22.7 years (2020 22.6 years) if they are male and for a further 24.5 years if they are female (2020 24.4).
For a member who retires in 2041 at age 65 the assumptions are that they will live on average for a further 23.3 years after retirement if they are male and for a further 25.4 years after retirement if they are female.
Scheme asset allocation
| Scheme asset allocation | |
|---|---|
| Delegated consulting services Other |
31 December 2021 31 December 2020 £’000 % £’000 % |
| 327,665 99% 305,166 99% 1,891 1% 1,103 1% |
|
| Total | 329,556 100% 306,269 100% |
The Delegated Consulting Service (DCS) is a fiduciary management solution that invests in a wide range of underlying assets in order to meet the Scheme’s specific investment objectives. The underlying asset allocation changes over time, based on the views of the fiduciary manager within the overall bounds set by the trustees. Under this approach the majority of scheme assets are invested in pooled funds. The managers of the pooled funds are required to have in place a policy on social, environmental and ethical considerations.
None of the Scheme assets are invested in the Company’s financial instruments or in property occupied by, or other assets used by, the GMC.
General Medical Council 106
Accounts 2021
Reconciliation of funded status to balance sheet
| Reconciliation of funded status to balance sheet | |
|---|---|
| Fair value of assets Present value of funded defned beneft obligations |
31 December 2021 31 December 2020 £’000 £’000 |
| 329,556 306,269 (291,864) (301,086) |
|
| Funded status Present value of unfunded defned beneft obligation |
37,692 5,183 (1,131) (1,195) |
| Asset/(liability) recognised on the balance sheet | 36,561 3,988 |
Amounts recognised in income statement
| Financing cost: Interest on net defned beneft liability/(asset) |
31 December 2021 31 December 2020 £’000 £’000 |
|---|---|
| (70) (208) |
|
| Pension expense recognised inproft and loss | (70) (208) |
Amounts recognised in Other Comprehensive Income (OCI)
| Asset gains/(losses) arising during the year Liability gains/(losses)arisingduringtheyear |
31 December 2021 31 December 2020 £’000 £’000 |
|---|---|
| 19,325 43,589 10,818 (50,560) |
|
| Actuarialgain/(loss) on defned beneftpension Scheme | 30,143 (6,971) |
107 General Medical Council
Accounts 2021
Changes to the present value of the defined benefit obligation during the year
| Opening defned beneft obligation (DBO) Interest expense on DBO Actuarial (gains)/losses on liabilities Net benefts paid out Past service cost |
31 December 2021 31 December 2020 £’000 £’000 |
|---|---|
| 302,281 248,752 4,213 4,955 (10,818) 50,560 (2,681) (1,986) - - |
|
| Closing defned beneft obligation | 292,995 302,281 |
Changes to the fair value of Scheme assets during the year
| Opening fair value of Scheme assets Interest income on Scheme assets Gain/(loss) on Scheme assets Contributions made by the company Net beneftspaid out |
31 December 2021 31 December 2020 £’000 £’000 |
|---|---|
| 306,269 258,143 4,283 5,163 19,325 43,589 2,360 1,360 (2,681) (1,986) |
|
| Closing fair value of Scheme assets | 329,556 306,269 |
Actual return on Scheme assets
| Interest income on Scheme assets Gain/(loss)on Scheme assets |
31 December 2021 31 December 2020 £’000 £’000 |
|---|---|
| 4,283 5,163 19,325 43,589 |
|
| Actual return on Scheme assets | 23,608 48,752 |
General Medical Council 108
Accounts 2021
17. Honoraria
| 2021 | 2020 | |
|---|---|---|
| Trustees | ||
| Dame Clare Marx (Chair)* | 64,167 | 110,000 |
| Professor Dame Carrie MacEwen (Acting Chair)† | 41,055 | - |
| Mr Steve Burnett | 18,000 | 18,000 |
| Dr Vanessa Davies‡ | 18,000 | - |
| Lady Christine Eames¶ | - | 18,000 |
| Professor Anthony Harnden | 18,000 | 18,000 |
| Lord Philip Hunt | 18,000 | 18,000 |
| Professor Deirdre Kelly¶ | - | 18,000 |
| Professor Paul Knight | 18,000 | 18,000 |
| Ms Lara Fielden§ | 12,000 | - |
| Dame Suzi Leather¶ | - | 18,000 |
| Professor Deepa Mann-Kler‡ | 18,000 | - |
| Dr Rajesh Patel | ||
| Dame Denise Platt¶ | - | 18,000 |
| Dr Suzanne Shale‡ | 18,000 | - |
| Miss Amerdeep Somal¶ | - | 13,500 |
| Miss Alison Wright |
-
Demitted as Council Member and Chair 31 July 2021.
-
Appointed as Council Member in January 2021 and Acting Chair from 1 August 2021.
-
Appointed as a Council Member in 2021.
-
Demitted as a Council Member in 2020.
-
§ Appointed as a Council Member January 2021, deceased August 2021.
-
|| Appointed as a Council Member in 2020.
Honoraria payments are permitted by the governing document of the General Medical Council, The Medical Act 1983, paragraph 17, schedule 1.
109 General Medical Council
Accounts 2021
| 2021 | 2020 | |
|---|---|---|
| Medical Practitioners Tribunal Service Committee members | ||
| Dame Caroline Swift | 93,286 | 92,937 |
| Mrs Joy Hamilton | 3,720 | 3,720 |
| Professor Jacky Hayden | 7,440 | 7,440 |
| Gill Edelman (Gillian Gordon)* | 564 | - |
| Dr Tushar Vince* | 564 | - |
| Dr Patricia Moultrie† | 3,156 | 3,720 |
| MrsJudith Worthington† | 3,156 | 3,720 |
| *Appointed as MPTS Committee member 2021. | ||
| †Demitted as MPTS Committee member 2021. |
| 2021 | 2020 | |
|---|---|---|
| Audit and Risk Committee co-opted members | ||
| Ms Elizabeth Butler* | 1,473 | 1,550 |
| Jon Hayes† | 930 | - |
| Mr Kenneth Gill | 2,945 | 2,170 |
- Demitted as ARC co-opted member 2021. † Appointed as ARC co-opted member 2021.
| 2021 | 2020 | |
|---|---|---|
| Investment Committee co-opted members | ||
| Mr Keith Mackay | 2,170 | 2,170 |
| Mr Tim Scholefield* | 620 | 1,860 |
| Mr David Stewart* | - | - |
| MichaelJennings† | 620 | - |
| *Demitted as IC co-opted member 2021. | ||
| †Appointed as IC co-opted member 2021. |
| 2021 | 2020 | |
|---|---|---|
| GMC Services International Ltd | ||
| Dr Andrew McCulloch | - | 155 |
General Medical Council 110
Accounts 2021
18. Travel and subsistence expenses claimed in 2021
| 2021 | 2020 | |
|---|---|---|
| Trustees | ||
| Dame Clare Marx (Chair)* | - | 445 |
| Professor Dame Carrie MacEwen (Acting Chair)† | 236 | - |
| Mr Steve Burnett | 732 | 489 |
| Dr Vanessa Davies‡ | 706 | - |
| Lady Christine Eames¶ | - | 1,704 |
| Professor Anthony Harnden | 184 | 84 |
| Lord Philip Hunt | - | 50 |
| Professor Deirdre Kelly¶ | - | 420 |
| Professor Paul Knight | 1,689 | 659 |
| Ms Lara Fielden§ | - | - |
| Dame Suzi Leather¶ | - | 425 |
| Professor Deepa Mann-Kler‡ ** | 2,878 | - |
| Dr Rajesh Patel | ||
| Dame Denise Platt¶ | - | 113 |
| Dr Suzanne Shale‡ | - | - |
| Miss Amerdeep Somal¶ | - | 1,380 |
| Miss Alison Wright |
- Demitted as Council Member and Chair 31 July 2021.
† Appointed as Council Member in January 2021 and Acting Chair from 1 August 2021.
‡ Appointed as a Council Member in 2021.
- Demitted as a Council Member in 2020.
§ Appointed as a Council Member January 2021, deceased August 2021.
|| Appointed as a Council Member in 2020.
** Professor Mann-Kler is our Council representative based in Northern Ireland and as such incurs higher travel and subsistence expenses to carry out her responsibilities as a Council Member.
111 General Medical Council
Accounts 2021
| 2021 | 2020 | |
|---|---|---|
| Medical Practitioners Tribunal Service Committee members | ||
| Dame Caroline Swift | 463 | 30 |
| Mrs Joy Hamilton | - | 217 |
| Professor Jacky Hayden | 302 | 316 |
| Gill Edelman (Gillian Gordon)* | 167 | - |
| Dr Tushar Vince* | - | - |
| Dr Patricia Moultrie† | - | 250 |
| MrsJudith Worthington† | - | 207 |
| *Appointed as MPTS Committee member 2021. | ||
| †Demitted as MPTS Committee member 2021. | ||
| 2021 | 2020 | |
| Audit and Risk Committee co-opted members | ||
| Ms Elizabeth Butler* | - | 21 |
| Jon Hayes† | 241 | - |
| Mr Kenneth Gill | - | 101 |
- Demitted as ARC co-opted member 2021. † Appointed as ARC co-opted member 2021.
| 2021 | 2020 | |
|---|---|---|
| Investment Committee co-opted members | ||
| Mr Keith Mackay | 74 | - |
| Mr Tim Scholefield* | - | - |
| Mr David Stewart* | - | - |
| MichaelJennings† | 26 | - |
| *Demitted as IC co-opted member 2021. | ||
| †Appointed as IC co-opted member 2021. | ||
| 2021 | 2020 | |
| GMC Services International Ltd | ||
| Dr Andrew McCulloch | - | - |
General Medical Council 112
Accounts 2021
| 2021 | 2020 | |
|---|---|---|
| Senior management team | ||
| Charlie Massey (Chief Executive) | 1,118 | 1,071 |
| Paul Buckley–Director of Strategy and Policy* | - | 1,196 |
| Shaun Gallagher–Director of Strategy and Policy† | 1,355 | - |
| Una Lane–Director of Registration and Revalidation | 971 | 1,088 |
| Colin Melville–Director of Education and Standards | 392 | 3,314 |
| Anthony Omo–Director of Fitness to Practise | - | 3,579 |
| Paul Reynolds–Director of Strategic Communications and Engagement | 156 | 2,313 |
| Neil Roberts–Director of Resources and QualityAssurance | 2,164 | 5,071 |
- Paul Buckley left his role as Director of Strategy and Policy on 31 December 2020.
† Shaun Gallagher was appointed as Director of Strategy and Policy on 01 December 2020.
Variations in expenses reflect that the trustees, committee members and the Senior Management Team live in different parts of the UK and are required to travel around the UK on GMC business, including to our offices in London, Manchester, Edinburgh, Belfast and Cardiff, and occasionally outside the UK.
Adjustments are also made for those with disabilities, which may mean that additional expenses are incurred for travel and accommodation according to specific needs.
113 General Medical Council
Accounts 2021
Reference and administrative information
We are independent of UK government and the medical profession and accountable to Parliament. Our powers are given to us by Parliament through the Medical Act 1983 .
We are registered with the Charity Commission for England and Wales (1089278), and with the Office of the Scottish Charity Regulator (SC037750). We are not currently required to be registered separately with the Northern Ireland Charity Commission.
Our principal places of business are 3 Hardman Street, Manchester M3 3AW and Regent’s Place, 350 Euston Road, London NW1 3JN. We also have offices in Belfast, Cardiff and Edinburgh; a centre for hearings, where the MPTS is based, at St James’s Buildings, 79 Oxford Street, Manchester M1 6FQ; and a Clinical Assessment Centre, in 3 Hardman Square, Manchester M3 3EB.
Our trustees have a duty to act impartially and objectively, and to take steps to avoid any conflict of interest arising as a result of their membership of, or association with, other organisations or individuals. As trustees, members have a duty to avoid putting themselves in a position where their personal interests conflict with their duty to act in the interests of the charity, unless authorised to do so. To make this fully transparent, we publish a register of members’ interests on our website.
We work with the Professional Standards Authority (PSA), an independent body, which is accountable to Parliament and scrutinises and oversees our work, together with other health and social care professional regulatory bodies in the UK.
Information requests
In 2021, we received 402 subject access requests under the General Data Protection Regulation (GDPR). This was a decrease of 15% from 2020. The number of information requests we received under the Freedom of Information Act 2000 (FOI) in 2021 was 841. This was a 32.6% increase from 2020.
We achieved 77.2% against our target of responding to 80% of subject access requests within the statutory timeframe. We achieved 83.1% against our target of responding to 90% of FOI requests within 20 working days.
Paying for goods and services
We paid 98% of valid and undisputed invoices within 30 days and did not pay any interest to suppliers due to late payment in excess of 30 days.
Day-to-day management of the organisation is delegated to the Chief Executive, Charlie Massey. You can read more about our governance and management arrangements from page 54.
General Medical Council 114
Accounts 2021
Professional advisers
| Professional advisers | |
|---|---|
| Bankers | Royal Bank of Scotland |
| 250 Bishopsgate | |
| London | |
| EC2M 4AA | |
| Solicitors | The majority of our legal work is carried out by |
| our in-house legal team. | |
| Auditors | Crowe U.K. LLP |
| 2nd Floor, 55 Ludgate Hill | |
| London | |
| EC4M 7JW | |
| Actuary and pension scheme adviser | Aon |
| Parkside House, Ashley Road | |
| Epsom | |
| Surrey | |
| KT18 5BS |
115 General Medical Council
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Published July 2022
- © 2022 General Medical Council
The text of this document may be reproduced free of charge in any format or medium providing it is reproduced accurately and not in a misleading context. The material must be acknowledged as GMC copyright and the document title specified.
The GMC is a charity registered in England and Wales (1089278) and Scotland (SC037750). Code: GMC/AR2021/0722.