m4 chief operating officer’s report susan goldsmith...council meeting, 26 april 2017 agenda item:...

Council meeting, 26 April 2017

Agenda item: M4

Report title: Chief Operating Officer’s Report

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

Action: To consider

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

Bringing Tests of Competence (ToC) in-house

Smarter Working Project

Transitioning at Work policy

2017 Pay Award

Contract Management policy

Modern Slavery Statement 2016

Other operational matters arising:

GMC Services International

Staff Survey

PSA Annual Performance Review

Investment Performance reporting

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

mailto:[email protected]

Council meeting, 26 April 2017 Agenda item - M4 – Chief Operating Officer’s report

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Issue

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

Operational Key Performance Indicators (KPIs)

2 All operational key performance indicators, at Annex A, were met up to the end of February 2017 other than the exception set out below:

Income and expenditure has a positive variance, our operational surplus was £2,207k against a budgeted surplus of £1,013k. Income is slightly over budget due to increased volumes of PLAB 2 candidates sitting compared to expectations and investment income over achieving against target. Expenditure is £958k under budget mainly driven by operational headcount from higher than assumed staff turnover and new roles in 2017 not yet being filled. Additionally, MPTS hearing volumes have been lower than expected and more have been held using a legally qualified Chair than expected which both give favourable cost advantages.

Council Priorities

3 We have aligned the Council Priority report at Annex A with the 2017 business plan, and introduced our updated RAG status criteria (as at page 3). As I outlined in my report to you of 23 February 2017, the main purpose of these revisions is to include greater consideration of whether we are still on track to deliver against the original business case, taking into account more qualitative or external factors such as political uncertainty and stakeholder response.

4 As at the end of February 2017, the majority of Council priority work has a green status other than the exceptions set out below. A summary of our position and more detail on exceptions is at Annex A.

Red – ‘Council priority 2’ Legislative reform (full detail at page 15 of Annex A)

Prospects of wider legislative reform are looking unlikely in the near future due to competing government priorities particularly around Brexit, so we will need to rethink how we take forward some of our ambitions for the future shape of regulation. Additionally, the Department of Health England’s consultation on legislative reform and regulation of Physician Associates has been further delayed due to political changes in Northern Ireland, although we still expect the consultation to be issued this spring. We continue to review our legislative priorities with the view to securing a Section 60 Order at the earliest opportunity.

Red – ‘Council priority 6’ Credentialing (page 26 of Annex A).


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As I reported to you in February 2017, this work was delayed due to prioritising resource towards our Standards for Curricula and Assessment Review (Item M6 of this meeting); and Flexibility of Training, which was completed on time and delivered to ministers on 31 March. We expect to be able to progress our work on credentialing shortly, and outline plans are already developed for the constituents of the project team to include membership from across the GMC.

Red – ‘Council priority 10’ List of Registered Medical Practitioners (LRMP) Development (page 42 of Annex A).

Following consultation feedback, we will not be taking forward initial plans to add additional information to the Register at this time. As agreed by Council in February 2017, we will continue working with the Academy of Medical Royal Colleges (AoMRC) on exploring the practicalities of collecting and possibly recording information about a doctor’s scope of practice, and look for ways to improve the current register. We will also undertake an internal review of our consultation approach, to see if there are any wider lessons that can be drawn.

Amber – ‘Council priority 1’ Corporate Strategy Development (page 9 of Annex A)

We have rescheduled Council consideration of our full Corporate Strategy 2018-2020 from June to September 2017, for further input from Council and staff.

Amber – ‘Council priority 6’ Generic Professional Capabilities (page 29 of Annex A)

The Generic Professional Capabilities (GPC) framework is complete and will now form part of our launch of the Standards for Curricula and Assessment Review (SCAR) package in early May 2017 (more information at Item 6).

Amber – ‘Council priority 9’ Co-ordinate best handling of Inquiries and Reviews (Page 40 of Annex A).

We have disclosed all of the material that was originally requested from us by the Gosport Inquiry Independent Panel. However, in January 2017, the Panel asked us to make additional searches of 290 named individuals; these searches were completed in March 2017. The Panel intends there to be maximum public disclosure of the material we provided and asked us to review and redact any sensitive personal data from the material, so that we can meet our legal obligations under the Data Protection Act to any data subjects identified. We have recruited and trained 12 temporary staff to help and we expect to complete the work at the end of April 2017. We have submitted a business case to the Panel requesting 50% reimbursement of our direct costs.


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Operational risk reporting

5 Our approach to risk in decision-making is outlined in Annex D, along with the current Corporate Risk Register. Risk 16A has been added to the Register to set out the mitigating actions that are in place to manage the risk of establishing and running our trading subsidiary, GMC Services International.

Performance and Resources Board meeting updates

6 The Performance and Resources Board met on 1 March 2017 and:

a Approved the implementation of the project to Bring Tests of Competence (ToCs) in-house. The project will involve recruiting operational staff and engaging associates with the relevant clinical and assessment skills as well as the development of an exam management system (EMS). This will reduce costs and create centralised expertise to manage assessments.

b Considered an update on the Smarter Working Project (SWP), which is looking at how we can support remote workers effectively. The initial phase involved research, analysis and engagement with staff to understand the challenges they face. The Board agreed to move into the second ‘implementation’ phase, which will focus on pilots to enhance how we collaborate and the use of improved technology tools to aid this collaboration. This project was part of the Change Programme Working Smarter portfolio.

c Agreed our new Transitioning at Work policy and the establishment of a Lesbian, Gay and Bisexual and Trans (LGBT) network for employees. The policy provides practical guidance for trans staff, managers and other colleagues; and sets out what support is available for people who are transitioning at work. Additionally later this year we will be participating in the Stonewall equality index benchmarking process. Our previous submission helped us identify opportunities to enhance our practice. This included the establishment of an LGBT network for staff.

d Agreed the 2017 Pay Award. Our 2017 award has taken into account our aim to ensure that our pay bands better reflect the market and a priority has been to ensure staff in the lower zone can progress more effectively through the pay band. All staff who joined the GMC before 1 January 2017 will receive a minimum pay rise of 2%, unless they are rated as ‘unsatisfactory’. We have also engaged external consultants to review our current pay and performance management structure and ensure that it meets all of our requirements relating to recruitment, retention, performance and talent management. This will see us start to make changes to the performance management system and how it links to pay in 2017. This will include integrating 360 degree feedback with our appraisal process; a


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stronger emphasis on personal development and a focus on behaviours and skills alongside personal and team objectives. A detailed update on the Pay and Performance Review is detailed on page 12 of Annex A.

e Approved the new Contract Management Policy, that will support our relationships with our suppliers to ensure they are conducted in the most professional and consistent way.

f Approved the Modern Slavery Statement, which we are required to publish under the Modern Slavery Act that came into force on 29 October 2015 (at Annex E).

Other operational matters arising

GMC Services International

7 The governance arrangements for GMCSI were reviewed at the Audit and Risk Committee on 8th March 2017. The Business Plan for GMCSI was finalised and was approved at the first GMCSI Board Meeting, held on 5th April 2017. The Business Plan, Operating Model and Governance framework is on the agenda for this meeting.

8 Current consultancy projects and training programmes are on track and helping to drive innovation and capability development within the organisation. Internal seminars are being prepared to update staff on progress and share the experience of those already working on GMSCI work overseas and in the UK.

Staff Survey

9 We have now met with Survey Solutions, who will be running our Staff Survey 2017 and draft Staff Survey questions have been reviewed by our Staff Forum, the Equality and Diversity Team, and the Senior Management Team. We will be finalising the questions and the internal communications plan with Survey Solutions, to enable the survey to go live in May 2017. We will also introduce the capability to sample staff opinion more frequently through regular pulse surveys and plan to launch staff surveys on an annual basis from now on.

PSA Annual Performance Review

10 On 15 March 2017, the Professional Standards Authority (PSA) published their Annual review of performance 2015/16: General Medical Council report. The report confirmed that we met all of the PSA’s 24 Standards of Good Regulation for this period. The paper at Item 7 considers the report in detail, including areas of learning.

http://www.professionalstandards.org.uk/docs/default-source/publications/performance-reviews/performance-review-2015-16-gmc.pdf?sfvrsn=6

http://www.professionalstandards.org.uk/docs/default-source/publications/performance-reviews/performance-review-2015-16-gmc.pdf?sfvrsn=6


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Investment Performance reporting

11 Our external fund manager, CCLA, provides a dashboard and detailed performance report on investment income at the end of each quarter. We will circulate the March dashboard to Council for information after it has been considered by the Investment Sub-Committee at its meeting on 3 May 2017. Future updates on investment income will be provided within this report.

M4 - Annex A Council Priority Report

Data accurate as of 27 March 2017

M4 – Chief Operating Officer’s Report


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Council Priorities Previous Period

Current period

Delivery Risk

Trend

Next period

1 Organisational development

All items on track or in pre-project phase: New Corporate Strategy development; Excellence For Quality Management (EFQM) Excellence Model – pre-project; Smarter working (FTP); Implementation phase of Pay and Performance work – pre-project; Investors in People; Deliver staff survey programme and pulse surveys for all staff

N/A G N/A G

2 Responding to legislative change and influencing/driving the UK regulatory reform agenda

Delays to our work underpinning legislative reform including influencing content and outcome of Department of Health (England) (DH) consultation on Future Shape of Regulation and Physicians Associates consultation and identifying legislative priorities and securing legislative change via S60 orders

N/A R N/A R

3 Understand the context in which doctors practise

• All items on track or in pre-project phase: Confidentiality project; Consent guidance; Flexibility of Training; My GMP Phase 2 (Standards App) – pre-project; Track and advise on impact of Health Board reconfiguration in Scotland and new models of care in England on GMC business including Sustainability and Transformation Plans (STPs) and Accountable Care Organisations (ACOs) and related discussions in Wales and NI

G G G

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

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

Implementing the recommendations from the review of revalidation G G G

6 Respond to Shape of Training Review

Most items on track: Credentialing (a lack of resources and competing priorities means the current period has a red rating) Generic Professional Capabilities (progress and resource have an amber rating); Standards for Curricula and Assessment and Operationalising Standards for Curricula and Assessment are on track.

R R R

7 Fairness and Proportionality All items on track: Deliver Equality & Diversity (E & D) Strategy 2014-17;

Differential attainment G G G

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

All items on track: Vulnerable doctors G G G

9 Communications and engagement

• Most items on track: Coordinate and implement the best handling of our engagement and respond to major inquiries and reports (e.g. Historical Abuse Inquiry) (amber due to resource and ongoing demands of the Gosport Inquiry) Communications and engagement strategy; Four-country implementation plan; Digital media strategy and Responsible Officer Programme (FTP) are on track

G G G

10 Develop our use and sharing of data and insight

Most items on track: List of Registered Medical Practitioners (LRMP) development (overall scope and outcomes of project are changing due to consultation response means the current period has a red rating); Intelligence and Insight Unit data sharing projects is on track

G R G

11 Speeding up fitness to practise procedures All items on track or in pre-project phase: FTP operations and Blueprint

programme (FTP) G G G


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Key to RAG ratings

Progress

Resource

Overall RAG status

Green - Project on track compared to anticipated time scales, benefits and overall business case Amber - Change to project delivery but without overall change to timescales, benefits, or business case Red – Not on track to meet planned timescales and/or benefits and overall business case Closed

Green - Project cost within 5% tolerance of original cost Amber – Project cost is under / over spending by between 5% - 10% [NB only an overspend of £50K or more will affect overall status] Red – Project cost is under / over spending by more than 10% [NB only an overspend of £50K or more will affect overall status] Closed

Green – Relevant skillsets and resource secured to deliver the project Amber – Relevant skillsets and resource are not secured / being secured but this will not impact on the project delivery or quality overall Red – Relevant skillsets and resource not secured, with negative impact on project delivery and/or quality Closed

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

Red, Amber Green (RAG) ratings for 2017 Corporate Projects

Cost



Operational KPIs



# Area BAU Operational KPIs [monthly] Jan Feb RAG for

Next period

Commentary

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

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

- R&R Answer 90% of calls within 15 seconds (2016) 90 87 - Revised KPI introduced for 2017

3 R&R Answer 80% of calls within 20 seconds¹ (2017) 92 89 On track

4 E&S Respond to 90% of ethical/standards enquiries within 15 working days 94 96 On track

- E&S 80% of enhanced monitoring concerns where action plan is being adhered to² - - - KPI to be updated

- E&S 90% of visits completed in within agreed timescales³ - - - KPI to be updated

5 FtP Conclude 90% of fitness to practise cases within 12 months 91 96 On track

6 FtP Conclude or refer 90% of cases at investigation stage within 6 months 93 96 On track

7 FtP Conclude or refer 95% of cases at the investigation stage within 12 months 96 98 On track

8 FtP Commence 100% of IC hearings within two months of referral 100 100 On track

9 MPTS Commence 90% of tribunal hearings within nine months of referral 94 100 On track

10 MPTS Commence 100% of IOT hearings within 3 weeks of referral 100 100 On track

11 R&QA Rolling twelve month staff turnover within 8-15% (excluding change programme (redundancy) effects) 10.81 10.26 On track

12 R&QA 2016/17 Income and expenditure [% variance] 6.95 7.22

Income is slightly over budget due to increased volumes of PLAB 2 candidates sitting compared to expectations and investment income over achieving against target. Expenditure is £958k under budget mainly driven by operational headcount being under budget, overall there is an operational surplus of £2,207k against a budgeted surplus of £1,013k.

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

14 S&C Monthly media score 1,014 -94 N/A



A4

¹Following agreement at the Performance and Resources Board in September 2016 , the SLAs to answer calls and respond to emails, faxes and letters have been amended from January 2017. As agreed at PRB, we are reporting performance against both the 2016 target and 2017 target. ²³Education KPIs are being revised as part of the wider work on developing KPIs/SLAs across the organisation.

# Area BAU Operational KPIs [monthly] Jan Feb Next period Commentary

15 S&C Doctors and medical students surveyed who said they would change their practice as a result of attending a Regional Liaison Service or Devolved Offices event [%]

66% This reflects the Q4 2016 submission.

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



A5

# Area BAU Operational KPI [Annual] Previous period

Current period Commentary

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

90.9%¹ N/A

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

18 S&C Level of confidence in the GMC’s regulation of doctors (from biennial tracking survey) 79%² N/A

19 R&QA Staff engagement score³ 78%³

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

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

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

Business As Usual – Operational KPIs (annual / biennial)



A6

¹The percentages for the current 2016 period are based on a 50.7% response rate to the annual survey that went to our top 65 policy influencing partners as identified by our external relations teams: the Devolved Offices, European and International Affairs, and the UK Government, Parliament & Stakeholder Relations teams. ²79% of patients/public who had heard of the GMC are confident in its regulation of doctors ³Staff engagement will be reported once per year as and when staff survey results are analysed

Detailed Appendix

Data accurate as of 22.03.17



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1) Organisational development Overall Priority Status

Previous Period

Current Period

Trend

Next period

N/A G N/A G

Linked Strategic Aim(s)

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

Delivery Activities

• New Corporate Strategy development • Excellence For Quality Management (EFQM) Excellence Model • Smarter working (FTP) • Implementation phase of Pay and Performance work • Investors in People • Deliver staff survey programme and pulse surveys for all staff

New Corporate Strategy development Owner: Paul Buckley Corporate Project

Last period Current period Forecast period

Overall status last report Progress Cost Resource Overall

Status Trend Forecast overall status

N/A A G A A N/A G

Summary comments (including trend)

Each of the six work streams is making progress and are considering issues such as what would good look like, what can be achieved in the timescale, what are the different elements that would need to be delivered, what are the resource implications, what are the equality and diversity considerations etc. We have set up and started to test thinking with a GMC Reference Community. We also held focus groups in December 2016 with various groups of doctors, students and trainees, which were informed by a discussion paper on future strategic direction for the organisation. Early thinking has been tested with both internal and external stakeholders and we have presented to Assistant Directors and Head of Section groups. In February 2017, emerging thinking was shared with the Senior Management Team and Council. We discussed the feedback with each work stream lead in March 2017. The date for submitting the final Corporate Strategy to Council has been changed, this was originally scheduled for June 2017 and has now moved to September 2017, this will allow more time for further engagement with Council and staff to help inform the development of the strategy.

Exception explanation

Progress Progress has been marked as amber due to change of key milestone (Corporate Strategy now being submitted to Council September 2017 instead of June 2017). Resource Project milestones currently on track but we are now experiencing resources challenges because of competing workloads and loss of key staff who have been working on the project.

Executive action Resources across the team have been stretched over the last few months due to a number of competing projects. Workload is now beginning to ease on other projects such as the LRMP consultation which allows the team to dedicate more time to work on developing the Corporate Strategy.

Forecast explanation Project milestones will remain on track, we may still experience challenges with resources but it is unlikely these challenges will be significant enough to change the overall status of the project.



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Previous Period

Current Period

Trend

Next period

N/A G N/A G



Delivery Activities


European Foundation For Quality Management (EFQM) Owner: Neil Roberts Corporate Project




N/A N/A N/A N/A N/A N/A N/A


This is in pre-project phase. The full EFQM project has not yet commenced. A pilot has been conducted in relation to the Strategy Work stream. A draft report on the findings from the pilot; relating to the Strategy criteria is being prepared and was presented to directors in March 2017. The report also includes a high level proposal for the next stages of the project which involves the roll out of the full EFQM model.



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Previous Period

Current Period

Trend

Next period

N/A G N/A G



Delivery Activities


Smarter working (FTP) Owner: Anthony Omo Corporate Project




N/A G G G G N/A G


The analysis phase is complete and a full recommendations paper has been formulated with the outputs from the Smarter Working (SW) project. The paper outlines the objectives of each theme (work stream), the achievements to date and the recommended actions for Directorate leads to complete as part of their work for the project. At the Performance and Resources Board on 1 March 2017, the Board approved the recommendations, the direction of the project with particular support for the pilots. The SW project will proceed with implementing the pilot of a collaborative tool, and a Communications Strategy to highlight our remote workers and strengthen the changes the SW Project has brought about, and begin to embed a change in culture and working practices.

Exception explanation N/A

Executive action N/A

Forecast explanation The project is continuing to progress on time and to budget.



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Previous Period

Current Period

Trend

Next period

N/A G N/A G



Delivery Activities


Implementation phase of Pay and Performance work Owner: Neil Roberts Corporate Project




N/A N/A N/A N/A N/A N/A N/A


This is in pre-project phase. We have engaged Mercer HR Consultancy to review our current pay and performance management structure and ensure that it meets all of our requirements relating to recruitment, retention, performance and talent management. We have recently conducted a market review of GMC roles in relation to pay and used this information to inform the 2017 pay award. We have held a number of focus groups to explore the views of our Staff Forum Representatives, Heads of Section and Assistant Directors in relation to their priorities for the performance management system as well as executive interviews with the Senior Management Team. We expect the final recommendations from Mercer HR Consultancy to be presented in May 2017.



13


Previous Period

Current Period

Trend

Next period

N/A G N/A G



Delivery Activities


Investors in People Owner: Neil Roberts Corporate Project




N/A G G G G N/A G


The Investors in People (IiP) Improving Systems, Developing People, Growing Business’(IDG) Voice Survey report has now been received and with the Senior Management Team (SMT), Communications Team and our staff forum. A further programme of work is now underway ahead of a follow up survey in the Autumn that will form part of our submission seeking accreditation.



Forecast explanation

‘Communications’ are on track to be circulated to Directors and Assistant Directors from across the organisation during March 2017. These communications will cover the summary highlights of the Voice Survey Report alongside a brief outline of the next steps. In addition the project is on track to engage with the Communications team at the end of March to assist in formatting the summary highlight report for all GMC staff. IDG are also on track to deliver a finalised IiP accreditation plan at the end of April 2017. The next planning meeting with IDG is scheduled for 3 April 2017.



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Previous Period

Current Period

Trend

Next period

N/A G N/A G



Delivery Activities


Deliver staff survey programme and pulse surveys for all staff Owner: Neil Roberts BAU




N/A G G G G N/A G


The set up meeting has now taken place with Survey Solutions and we have received the draft Staff Survey questions. The draft questions were reviewed during the Senior Management Team away day on 27 February 2017; and the questions are now being reviewed further with Survey Solutions (survey provider) to ensure that they are grouped and themed effectively. The Staff Forum have reviewed the draft questions and they have also been put to Assistant Directors and the Equality & Diversity team for review and comment. The Survey Solutions and GMC communication plans were finalised during March 2017 to allow the survey to go live in May 2017.



Forecast explanation On track.



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2) Responding to legislative change and influencing/driving the UK regulatory reform agenda

Overall Priority Status

Previous Period

Current Period

Trend

Next period

N/A R N/A R


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

Delivery Activities

• Legislative reform (including influencing content and outcome of Department of Health (DH) consultation on Future Shape of Regulation and Physicians Associates consultation and identifying legislative priorities and securing legislative change via S60 orders)

• Understanding the implications of and responding to emerging government plans for the UK withdrawal from the EU

Legislative reform Owner: Paul Buckley BAU




G R G G R R


Department of Health (England) (DH) consultation on legislative reform and regulation of Physician Associates has been further delayed due to political uncertainty in Northern Ireland resulting in inability to achieve four country sign off for consultation. Prospects of wider legislative reform are looking unlikely in the near future due to competing government priorities. We are continuing to review our legislative priorities in the hope to secure a S60 order in the absence of a Bill on legislative reform. We have taken all possible action to advance our legislative ambitions but it remains outside our control to secure legislative reform in the near future.

Exception explanation Progress DH consultation on legislative reform has been further delayed which is impacting on our ability to progress work on the future shape of regulation, legislative reform and securing S60 orders.

Executive action Colleagues in the Northern Ireland (NI) office are engaging with stakeholders and are preparing a briefing to outline the potential impact on the GMC following the reforming of the NI government. We continue to engage with DH and stakeholders about the prospect of legislative reform but it is unlikely that there will be parliamentary time to dedicate to legislative reform. We will respond to both DH consultations when they are launched.

Forecast explanation Prospect of legislative reform will remain uncertain and we do not know when to expect the DH consultation on legislative reform.



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2) Responding to legislative change and influencing/driving the UK regulatory reform agenda


Previous Period

Current Period

Trend

Next period

N/A R N/A R


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

Delivery Activities

• Legislative reform (including influencing content and outcome of Department of Health (DH) consultation on Future Shape of Regulation and Physicians Associates consultation and identifying legislative priorities and securing legislative change via S60 orders)

• Understanding the implications of and responding to emerging government plans for the UK withdrawal from the EU

Understanding the implications of and responding to emerging government plans for the UK withdrawal from the EU

Owner: Paul Buckley BAU




N/A G G G G N/A G


Chief Executive appeared in front of the Health Select Committee on 28 February 2017 for their inquiry into the impact of Brexit on health and social care. The briefing document was made available to all staff. We have further formalised our response to Brexit and the priorities we would like to proceed with as an organisation. The European and International team provided initial analysis on the Government White paper on potential impact on our functions & government timelines. We also conducted a survey to understand the impact of Brexit on the UK medical profession and whether European Economic Areas (EEA) doctors intend to remain in UK practice post Brexit, the survey was published on our website on 28 February 2017 (link to GMC survey of EEA doctors). The Intelligence and Insight Unit also published a paper on the GMC website setting out our data about doctors with a European PMQ (link to Our data about doctors with a European primary medical qualification).



Forecast explanation Activity on track



http://www.gmc-uk.org/Briefing___GMC_survey_of_EEA_doctors__February_2017_.pdf_69558586.pdf

http://www.gmc-uk.org/static/documents/content/2017.02.21_GMC_data_on_EEA_doctors_in_the_UK.pdf

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3) Understand the context in which doctors practise Overall Priority Status

Previous Period

Current Period

Trend

Next period

G G G


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

Delivery Activities

• Confidentiality project • Consent guidance • Flexibility of Training • My GMP Phase 2 (Standards App) • Track and advise on impact of Health Board reconfiguration in Scotland and new models of care in England on GMC business including Sustainability and Transformation Plans

(STPs) and Accountable Care Organisations (ACOs) and related discussions in Wales and NI

Confidentiality project Owner: Colin Melville Corporate Project




G G G G G G


Work on case studies is continuing. We are developing a number of new case studies and revising and amending existing ones. Work has started on building the web pages for the guidance to come into effect on the 25 April 2017. Work has also begun on the patient guide. We have commenced our staff training workshops to update them on the new confidentiality guidance before it comes into effect.



Forecast explanation Forecast on track. Throughout February and March 2017 we have planned staff sessions on the new guidance for key teams within the GMC as well as interested individuals.



18


Previous Period

Current Period

Trend

Next period

G G G



Delivery Activities



Consent guidance Owner: Colin Melville Corporate Project




N/A G G G G G


The patient survey launched on 6 February 2017 and closed in March. We held the first task and finish group (TFG) meeting on 24 February 2017 with all confirmed members in attendance except one, who we met with separately. Unfortunately the TFG member from Northern Ireland was unable to attend, we are now seeking a replacement. We are currently finalising dates for the next three TFG meetings. Community Research have finished their focus groups with doctors and have provided their interim report of the findings.




Forecast on track. We are finalising the date and practical arrangements for the second TFG meeting and drafting papers. The patient survey closed towards the end of March 2017 and we will begin to analyse the results. The externally commissioned research is currently in the bulletin board phase and we expect to receive the final report in April 2017.



19


Previous Period

Current Period

Trend

Next period

G G G



Delivery Activities



Flexibility of Training Owner: Colin Melville Corporate Project




N/A G G G G G


Throughout February 2017 we have engaged with the majority of Medical Royal Colleges/Faculties to collect their views and invited written submissions. We also obtained agreement at Council on 23 February 2017 as to the overall vision of the review and draft actions and conclusions. The project is still on track to meet the business case (public commitment to submit final report to Ministers at the end of March 2017) and overall objective.



Forecast explanation Team will be collating the views of stakeholders collected throughout the engagement programme - with a view to developing the final report to ministers at the end of March 2017.



20


Previous Period

Current Period

Trend

Next period

G G G


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

Delivery Activities



Track and advise on impact of Health Board reconfiguration in Scotland and new models of care in England on GMC business including Sustainability and Transformation Plans (STPs) and Accountable Care Organisations (ACOs) and related discussions in Wales and NI





N/A G G G G N/A G


Northern Ireland office to circulate a briefing note on implications of recent NI elections. We continue to closely monitor the situation. We are expecting an announcement from Scottish Government about re-configuration of Scottish Health Boards and will then develop an engagement plan and appropriate response considering the impact on GMC work.



Forecast explanation On track



21

4) Medical Licensing Assessment Overall Priority Status

Previous Period

Current Period

Trend

Next period

G G G


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

Delivery Activities

• Medical Licensing Assessment

Medical Licensing Assessment Owner: Colin Melville Corporate Project




G G G G G G


The Medical Licensing Assessment (MLA) consultation is ongoing and, by the end of February 2017, had received around 100 responses; almost all from individuals. The programme team has continued to engage with stakeholders and to develop its programme planning.



Forecast explanation The programme is on track at this stage with the consultation running until 30 April 2017.



22

5) Revalidation review Overall Priority Status

Previous Period

Current Period

Trend

Next period

G G G



Delivery Activities

• Evaluation of revalidation • Revalidation operations • Implementing the recommendations from the review of revalidation

Evaluation of revalidation Owner: Una Lane Corporate Project




G G G G G G


A monthly review meeting with UMbRELLA was held in February 2017 and went well. For future meetings, we will be inviting communication colleagues from both the GMC and UMbRELLA to attend so we can begin to plan communications for the publication of the final report. The second survey to targeted doctors (to locums, specialty and associate specialist doctors, doctors working in the independent sector, and doctors without a connection for revalidation) has now closed. Following the extension of the closing date and reminder email, the response rate increased.






23


Previous Period

Current Period

Trend

Next period

G G G



Delivery Activities


Revalidation operations Owner: Una Lane BAU




G G G G G G


The team is operating within capacity and meeting Service Level Agreements (SLAs). We have carried out further analysis on the increase in deferral rates and there are a number of different factors that could be influencing this increase. During February 2017, we met with colleagues from the Employer Liaison Service to look at how we can best share information with them so they can support us with working with Responsible Officers where deferral rates are higher. We are considering the option of developing a dashboard to do this. The revalidation assessment continues to be delivered as part of our BAU activity. On 10 March 2017 an appeal hearing was held for a doctor who appealed against the decision to remove their licence to practise for failure to book their revalidation assessment (and submit an annual return). This was the first appeal to be heard relating to a decision to remove a licence for failure to book the assessment.






24


Previous Period

Current Period

Trend

Next period

G G G



Delivery Activities


Implementing the recommendations from the review of revalidation Owner: Una Lane Corporate Project




N/A A G G G N/A G


The internal Taking Revalidation Forward (TRF) Programme Board met for the first time on 27 February 2017, with representation from all directorates. The Board agreed six work streams – reflecting the five priorities identified in our published response to Sir Keith Pearson’s report, plus one more to cover the residual TRF recommendations. It also identified affected GMC teams and preliminary leads for each work stream. Between 21 Feb and 6 March 2017, colleagues met or spoke with all members of the external Revalidation Advisory Board (RAB) to gain insight into their organisations’ response to the TRF report. There is widespread support for all recommendations with the notable exception of bringing forward the date of first revalidation for new registrants, which is felt to be of limited value (especially for trainees). Governments in Wales, Scotland and Northern Ireland indicated that they needed more time to consult with local stakeholders before offering a full response, and agreeing actions and timescales. Reflecting this request, our initial action plan for implementation has been amended to include an engagement period running from March to May 2017, leading to an agreed stakeholder-wide ‘output plan’ in June 2017. Implementation activity would begin in June, although ongoing GMC revalidation projects will continue on their existing timescales. We presented a summary of stakeholder responses and an outline timescale for implementation to RAB at its meeting on 7 March 2017. The same meeting also discussed the GMC’s proposal to disband RAB from June 2017 and to introduce a new forum, to be called the Revalidation Oversight Board, through which stakeholders in revalidation can meet to collaborate, coordinate agreed actions and to monitor implementation of the TRF recommendations.

Exception explanation Progress We have reported progress as amber to reflect the change in project delivery to include the engagement period from March to May 2017.

Executive action None required.

Forecast explanation Project on track.



25

6) Respond to Shape of Training Review Overall Priority Status

Previous Period

Current Period

Trend

Next period

R R R



Delivery Activities

• Credentialing • Generic Professional Capabilities • Standards for Curricula and Assessment • Operationalising Standards for Curricula and Assessment

Credentialing Owner: Paul Buckley Corporate Project




R R G R R R


A scoping document for Phase 2 of this work has been drafted. The Senior Management Team agreed we should model our approach for cosmetic surgery with the Royal College of Surgeons of England (RCSEng). We are now discussing with internal teams how they would like to arrange this pilot. External stakeholders, including the chair of the UK Shape of Training Steering Group and potential early adopters continue to press for the introduction of regulated credentials, but for different reasons. Current legal advice suggests we may not have powers to ‘regulate’ without legislative change. The next phase of work will commence once the flexibility report has been delivered to ministers and the Standards for Curricula and Assessment (SCAR) review has been approved by Council. Outline plans are already developed for the constituents of the project team to include membership from across the GMC.


Progress Progress of the project has been stalled due to inability to secure resources and impact of other high priority work programmes. Resource Progress has been delayed due to lack of level 4 support resource and the prioritisation of the Standards for Curricula and Assessment review and the flexibility review, to ensure that these projects will complete in the time they are committed to.

Executive action Discussions about resourcing and supporting (regulated) credentials is ongoing across relevant directorates.

Forecast explanation Until we identify resources for the next phase of this work, progress will continue to be stalled. The next steps will be to agree an action plan with the directors of education and registration, discuss with the RCS about piloting their accreditation scheme and agree milestones and outcomes for the pilot.



26


Previous Period

Current Period

Trend

Next period

R R R



Delivery Activities


Generic Professional Capabilities Owner: Colin Melville Corporate Project




G A G A A A


The Generic Professional Capabilities (GPC) framework is complete and will be part of the launch of the Standards for Curricula and Assessment (SCAR) package in early May 2017. There are some issues to be resolved with the Academy of Medical Royal Colleges (AoMRC) around the final version of the GPC supporting guidance. We are uncertain if this will be ready for the SCAR launch in early May 2017, so publication may follow later in May.


Progress Outstanding issues about the final version of the GPC guidance may delay publication till later in May 2017. A meeting with key people from the GMC and the AoMRC was planned for the end of March 2017, to resolve these issues and agree a publication date. Resource As the project needs to go a little longer than planned, the AoMRC may ask for extra money to pay for an extension for the project manager.

Executive action We are in discussions with the AoMRC about funding an extension to the project manager's contract.

Forecast explanation Throughout March we have been working with the AoMRC to resolve outstanding issues, but publication of the guidance could be delayed until late May 2017. This will be after the launch of the SCAR standards and new approvals process, which is scheduled for early May.



27


Previous Period

Current Period

Trend

Next period

R R R



Delivery Activities


Standards for Curricula and Assessment Owner: Colin Melville Corporate Project




G G G G G G


We are working with communications colleagues on stakeholder engagement and messaging for launch, and designing graphics for publication. We have continued to work closely with colleagues in operational teams who are developing new approvals processes and templates which will be ready for the standards launch. Publication of Generic Professional Capabilities (GPC) guidance, which is being developed in a joint project led by the Academy of Medical Royal Colleges (AoMRC), may be delayed until later in May 2017, but the GPC framework will be available, so this will not delay the launch of the standards.




On track - We will seek signoff from the Strategy and Policy Board and Council in March/April 2017 and are on track to launch the new curriculum standards, GPC framework, GMC approvals process and associated guidance by May 2017. We are committed to launch in early May as curriculum submissions have been planned around this. This means we need to be able to publish the standards within days of Council approval but we have held time to work on any document changes if needed, and we will share SPB papers with the GMC Chair to allow early sight of the documents to prepare in advance for Council.



28


Previous Period

Current Period

Trend

Next period

R R R



Delivery Activities


Operationalising Standards for Curricula and Assessment Owner: Colin Melville Corporate Project




N/A G G G G N/A G


Workshops held with Head of Section and Assistant Director to confirm direction of travel and review approvals processes. Continued to develop guidance and curricula submission form through engagement with Royal Colleges, Curriculum Advisory Group (CAG) and internal stakeholders. Meeting scheduled for Education and Standards Senior Team (ESST) to review process flows and confirm direction of travel for the project. We are still awaiting confirmation from the Academy of Medical Royal Colleges (AoMRC) on the format for Generic Professional Capabilities inclusion in curricula.



Forecast explanation Project currently on track and no known reasons for it to fall behind schedule. Visits to Royal Colleges, to discuss the approvals process and their ‘critical to quality measures’ (CTQs), are on going and should be completed by early April 2017.



29

7) Fairness and Proportionality Overall Priority Status

Previous Period

Current Period

Trend

Next period

G G G


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

Delivery Activities

• Deliver Equality & Diversity (E &D) Strategy 2014-17 • Differential attainment [as part of E&S E&D Strategy]

Deliver E&D Strategy 2014-17 Owner: Paul Buckley BAU




G G G G G G


Work remains on track, the Equality and Diversity (E&D) Programme Board met on 8 March 2017 and discussed the role of E&D champions and our governance on E&D, enhancing our reporting on E&D, and plans for implementing our E&D strategy throughout 2017.






30

7) Fairness and Proportionality Overall Priority Status

Previous Period

Current Period

Trend

Next period

G G G



Delivery Activities

• Deliver Equality & Diversity (E & D) Strategy 2014-17 • Differential attainment [as part of E&S E&D Strategy]

Differential attainment [as part of E&S E&D Strategy] Owner: Colin Melville BAU




G G G A G G


Team had a useful meeting with the six pilot areas using the Differential Attainment packs, where Deans provided their initial feedback on the data and discussed how they reflect local context and identify local responses to their data. The Terms of Reference were signed off by the Strategy and Policy Board. The E&D Advisory Group meeting was constructive with a range of views across those we regulate. Black and Minority Ethnic (BME) representatives, academic researchers and external E&D experts from outside the medical professions attended the advisory group meeting.

Exception explanation Resource The Differential Attainment Project Manager role is vacant and the team have shortlisted and will be interviewing soon.

Executive action Recruitment is currently underway. In advance of securing a new project lead, the Strategy and Communication E&D team are providing increased support and continuity.

Forecast explanation The team are reflecting on the feedback following the two workshops and planning the next steps for the key work streams.



31

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


Previous Period

Current Period

Trend

Next period

G G G


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

Delivery Activities

• Vulnerable doctors

Vulnerable doctors Owner: Anthony Omo Corporate Project




G G G G G G


The project is progressing well and remains on track. A number of key milestones have been achieved this month including: • Initial scoping and research undertaken re: our approach to providing access to psychiatric advice during an investigation/hearing • Updated the project Equality Analysis • First draft of guidance for staff on signs that a Doctor may be unwell completed • Agreed who will make up the Specialist team • Workshop held with Enterprise Systems to draft Siebel requirements for Provisional Enquiries for health cases, pausing the investigation and Specialist team • Second British Medical Association (BMA) Doctor Support Service training session taken place. As we start to operationalise a number of the medium/longer term proposals, we have identified areas of overlap between some of the work streams. As such, we have scheduled a mapping session to review this and potentially re-group/reallocate resource to ensure that any linked work streams are delivered as a single package. This month a decision was taken to pause work (as part of the Supporting Vulnerable Doctors project) on 'Explaining the impact of conditions/undertakings'. This is because the majority of this work streams’ objectives are being delivered through other existing projects such as the Enhanced role of the MS project and the Restrictions bank review. We will liaise with those respective projects to ensure that this proposal is delivered satisfactorily.



Forecast explanation Project on track.



32

9) Communications and engagement Overall Priority Status

Previous Period

Current Period

Trend

Next period

G

G

G


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

Delivery Activities

• Communications and engagement strategy • Four-country implementation plan • Digital media strategy • Coordinate and implement the best handling of our engagement and respond to major inquiries and reports (e.g. Historical Abuse Inquiry) • RO Programme (FTP)

Communications and engagement strategy Owner: Paul Buckley BAU




G G G G G G


We will be refreshing priority narratives to reflect agreed 2018-2020 Corporate Strategy by the end of the year and will continue to deliver our strategic media plan. We are also establishing a communications evaluation programme, an Evaluation Working Group has been set up and an evaluation audit has been completed. Additionally we are working with colleagues in IS to develop ‘penetration analysis’ of GMC news for doctors. We are also creating development plans for our key audiences.






33


Previous Period

Current Period

Trend

Next period

G G G



Delivery Activities


Four-country implementation plan Owner: Paul Buckley Corporate Project




N/A A G G G N/A G


Colleagues from the devolved offices are working through the plan, following a change the original deadline of December 2016. A Performance & Resources Board and Council Paper on four country reporting were discussed in July 2016. We are considering how the second phase of implementation will work. We will present a new plan, which will include work streams and governance to the S&C Director in early 2017.


Progress Change to overall deadline due to internal changes over past 6 months (New Head of Welsh Affairs, Interim Assistant Director Strategy & Communications). Original deadline was December 2016, once the new plan to implement suggested changes from the review is approved, activities will be completed during the course of 2017, though some activities are likely to be completed over the next two years.

Executive action We are continuing to develop a plan for the project and will be considering how to take this work forward following the CE’s announcement of establishing two new directorates. We continue to engage with all Devolved Offices about how to progress the project. Once a proposed plan has been developed this will be submitted to the Director of S&C in early 2017.

Forecast explanation We will be on track to deliver activities against new deadlines.



34


Previous Period

Current Period

Trend

Next period

G G G



Delivery Activities


Digital media strategy Owner: Paul Buckley Corporate Project




G G G A G G


The Project board meeting was held on 10 February 2017, with good discussions and advice for moving forward. The directorate web team workshops have all been delivered. Phase one of the internal audit was completed, with green/amber rating and suggested recommendations to implement. Three of the seven work streams have developed clear objectives and key results.

Exception explanation Resource Amber has been marked for resources whilst we secure in detail the resource needed from each directorate for work on content for the web project.

Executive action Workshops have been held across the business to establish the amount of content that will need reviewing across the business which will then help us identify the resource needed from each directorate.

Forecast explanation Project board meeting held on 14 March 2017, the focus was on rebranding the strategy, developing audience profiles and finalising the resourcing plans.



35


Previous Period

Current Period

Trend

Next period

G G G



Delivery Activities


Coordinate and implement the best handling of our engagement and respond to major inquiries and reports (e.g. Historical Abuse Inquiry)





N/A A G A A N/A A


We have disclosed all of the material that was originally requested from us by the Gosport Inquiry Independent Panel. However, in January 2017, the Panel asked us to make additional searches of 290 named individuals; these searches were completed in March 2017. The Panel intends there to be maximum public disclosure of the material we provided and asked us to review and redact any sensitive personal data from the material, so that we can meet our legal obligations under the Data Protection Act to any data subjects identified in those documents. We have recruited and trained 12 temporary staff to help with this work which we expect to be complete at the end of April 2017.


Progress Further demands imposed by the Gosport Independent Panel will impact on our ability to progress with internal work in relation to the wider review of historical abuse cases as significant resources will need to be allocated to service the request from the Gosport Panel. Resource We do not have sufficient resource to service the request from the Gosport Panel in the time specified and continue to progress work in relation to the wider internal review of historic abuse cases. Additional resources have been secured from across the business.

Executive action We have secured additional resources to service the request from the Panel though this will likely impact on other areas of work across the business. We have submitted a business case to the Panel requesting 50% reimbursement of our direct costs.

Forecast explanation The request for further work will continue to have an impact on other work streams/projects across the business.



36

10) Develop our use and sharing of data and insight Overall Priority Status

Previous Period

Current Period

Trend

Next period

G R G



Delivery Activities

• List of Registered Medical Practitioners (LRMP) development • Intelligence and Insight Unit data sharing projects

LRMP development Owner: Paul Buckley Corporate Project




G R G G R G


We completed the full analysis of the consultation responses in January 2017. The overall themes remain the same as those found in the interim report. The full consultation report was presented to Council in February 2017. Council agreed with the recommendations to continue working with the Academy of Medical Royal Colleges (AoMRC) on scope of practice and look for ways to improve the current register. Council had wider feedback on the way that the GMC runs consultation, and how we engage with certain groups as part of our consultations. They have asked us to review our approach and report back to them. We will also request an internal review of how we undertook this consultation.


Progress Based on the consultation responses we received, we will not be taking forward any of the options to add additional information to the register. This will change the overall scope and outcomes of the project. However, we will look for ways to improve the register, and continue to work with the AoMRC on scope of practice. An internal review of our consultation process is being conducted and will aim to conclude within the next two months.

Executive action

We published a blog on 24 February 2017 (link to Improving the medical register – doctors’ scope of practice) highlighting that we had listened carefully to the views expressed by the profession, in particular their concerns about privacy and safety and that we wouldn’t be making any significant changes to the register at this stage. We will however continue to work with the AoMRC to explore how we might be able to collect information about doctors’ scope of practice in an accurate and meaningful way. The existing project ‘Development of LRMP’ will be closed to reflect the end of this phase of work, lessons learned and benefits realisation will be captured as part of the closure process. An internal review of the consultation process is also being conducted to identify lessons learned, the outcomes of which will be captured within Planview. A new separate project will be set up to manage our collaborative work with the AoMRC on scope of practice.

Forecast explanation We will be closing down this project next month.



https://gmcuk.wordpress.com/2017/02/24/improving-the-medical-register-doctors-scope-of-practice/

37

10) Develop our use and sharing of data and insight Overall Priority Status

Previous Period

Current Period

Trend

Next period

G R G



Delivery Activities

• LRMP development • Intelligence and Insight Unit data sharing projects

Intelligence and Insight Unit data sharing projects Owner: Paul Buckley BAU




N/A G G G G N/A G


External Launch of Agora Recommendations are due to go to the Performance and Resources Board in April 2017 with regards to the external launch of Agora which is planned for later this year. This will include commercial, scoping and phasing recommendations following engagement with Directorates. Plans are being refined to release an Responsible Officer’s (RO) dashboard. It is planned that following final testing, RO’s will be engaged in the launch of this Dashboard before it is further deployed to automate routine data sharing to support their inspectors. Data Sharing Evaluation The evaluation was due to be shared around the end of March 2017. The associated action plan will include recommendations regarding specific agreements.



Forecast explanation On track



38

11) Speeding up fitness to practise procedures Overall Priority Status

Previous Period

Current Period

Trend

Next period

G G G


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

Delivery Activities

• FTP operations • Blueprint programme (FTP)

FTP operations Owner: Anthony Omo BAU




G G G G G G

Summary comments (including trend) All FtP SLA’s were met.







M4 – Annex B

2017 Income and Expenditure

Summary

1 Income and revenue expenditure at the end of February 2017 was:

Operational financial summary as at February 2017

Budget February

Actual February Variance

Budget Jan - Dec

£000 £000 £000 % £000 Income Annual retention fees 15,932 15,993 61 0% 95,569 Registration fees 338 356 18 5% 4,138 PLAB fees 314 361 47 15% 2,467 Specialist application CCT fees 313 309 (4) (1)% 2,661 Specialist application CESR/CEGPR fees 124 146 22 18% 819 Interest income 102 102 0 0% 623 Investment income 43 111 68 158% 260 Other income 227 251 24 11% 1,445 Total Income 17,393 17,629 236 1% 107,982 Expenditure by cost type Staff costs 9,510 9,104 406 4% 56,241 Staff support costs 435 389 46 11% 3,268 Office supplies 399 323 76 19% 2,436 IT & telecoms costs 507 477 30 6% 3,309 Accommodation costs 1,124 1,055 69 6% 6,290 Legal costs 674 578 96 14% 4,834 Professional fees 186 177 9 5% 2,278 Council & members costs 66 59 7 11% 397 Panel & assessment costs 2,085 1,900 185 9% 14,114 Depreciation 1,259 1,214 45 4% 7,309 PSA Levy 115 115 0 0% 707 Unallocated efficiency savings (11) 0 (11) 0% (2,067) Total Operational Expenditure 16,349 15,391 958 6% 99,116 Transformation fund revenue expenditure 31 31 0 0%

2,000

Change programme 0 0 0 0%

2,730 Overall surplus/(deficit) 1,013 2,207 1,194

4,136

M4 - Chief Operating Officer’s Report

Council meeting, 26 April 2017 Agenda item - M4 Chief Operating Officer’s Report

B2

2 The budgeted surplus to the end of February was £1,013k and the actual surplus was £2,207k, mainly because operational expenditure has been under budget. The significant variances were:

a Staff costs (£406k under budget). Our staffing cost budgeting process assumes a level of vacancies in the organisation at any given time, in this period we assumed there would be 25 vacant posts whereas there are 90. The additional 65 vacancies are made up of 24 arising from higher turnover than assumed, which we expect to be recruited in the near future, four posts relocated from London that have not yet been filled and 37 posts are being held vacant either while an assessment is made on whether they need to be recruited to, as a result of a reported efficiency saving or due to holding the position open due to internal secondment.

b Panel and assessment costs (£185k under budget). Within MPTS the budget number of hearing days to the end of February was 390 and the actual number was 348, with a drop in average hearing length, compared to 2016, being the main driver. In addition, there was a significant underspend due to reduced transcription services linked to reduced volumes and an increased use of Legally Qualified Chair (LQC) led hearings, which are less costly than hearings with a separate chair and legal assessor.

Expert report costs in FTP are also under budget due to lower volumes. The reduction in volumes is linked to the reduced investigation volumes, changing the criteria for requesting reports and a reduction in the number of health assessments compared to budget. FTP Panel and assessment costs are also impacted by the deferral of the health examiner recruitment exercise to May.

c Legal costs (£96k under budget). Barristers’ fees within FTP, which are linked to MPTS hearing volumes, are £60k under budget. The remainder of the underspend, also in FTP, is due to reduced volumes of High Court Extension cases compared to budget.

d Office supplies (£76k under budget). Photocopying and stationery are under budget due to reduced hearing and investigation volumes, and as a result of using more electronic communications across the organisation.

e Investment income (£68k over budget). The target for fund managed investment returns is CPI +2% over a rolling five year period. Returns in the short term can fluctuate significantly from month to month depending on market conditions. Our external fund manager, CCLA, provides a dashboard and detailed performance report at the end of each quarter. We will circulate the March dashboard to Council for information after it has been considered by the Investment Sub-Committee.

Council meeting, 26 April 2017 Agenda item - M4 Chief Operating Officer’s Report

B3

Capital expenditure

3 Capital expenditure at the end of February 2017 was:

Capital expenditure as at February 2017 Budget

February Actual

February Variance Budget

Jan - Dec £000 £000 £000 % £000

IT projects 724 725 (1) (0)% 5,100 Accommodation projects 77 75 2 3% 900 Total 801 800 1 0% 6,000

4 Expenditure was broadly in line with budget.

Efficiency programme

5 Efficiency targets are initially held centrally and then reallocated to specific budget lines when efficiencies have been confirmed. To date the cumulative target is £122k and £111k of efficiencies has been confirmed, resulting in an £11k variance. The forecast of confirmed efficiencies for the full year is currently £489k, leaving £2,067 still to be identified:

Efficiencies by directorate

Efficiency target

February

Variance to target February

Full year efficiency

target

Full year confirmed efficiencies

Full year variance (target vs confirmed)

OCCE/OCOO 5 27 99 193

94 Fitness to Practise 47 (13) 982 159

(823)

MPTS 13 15 284 27

(257) Strategy & Communication 11 (11) 237 0

(237)

Education & Standards 8 (8) 167 0

(167) Registration & Revalidation 17 0 354 110

(244)

Resources & Quality Assurance 21 (21) 433 0

(433) Total 122 (11) 2,556 489 (2,067)



Appeals and Judicial Reviews

M4 – Annex C

1 The table below provides a summary of appeals and judicial reviews as at 21 March 2017:

Open cases carried forward

since last report

New cases Concluded cases

Outstanding cases

s.40 (Practitioner) Appeals

18 5 11 13

s.40A (GMC) Appeals

4 4 0 8

PSA Appeals 1 1 0 2

Judicial Reviews

4 2 2 4

IOP/IOT Challenges

1 1 1 1

Explanation of concluded cases

2 Appeals -

a 8 appeals dismissed

b 2 appeal successful

Council meeting, 26 April 2017 Agenda item M4 – Chief Operating Officer’s Report

C2

c 1 struck out.

3 Judicial Reviews -

a 1 permission refused

b 1 dismissed.

4 GMC Appeals -

a 4 new appeals

b 4 outstanding appeals.

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

5 PSA Appeals -

a 1 new appeal

b 1 appeal outstanding.

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

6 IOP/IOT challenges -

a 1 new IOT challenge;

b 1 unsuccessful IOT challenge.

The outstanding IOT challenge is awaiting listing for hearing.

Any other litigation of particular note

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

8 The table below provides a detailed breakdown of outstanding Doctor (s.40) appeals as of 21 March 2017.


C3

No Case Decision appealed Current status

1 A Appeal against Medical Practitioners Tribunal decision.

Hearing listed for 06/04/2017

2 C Appeal against Medical Practitioners Tribunal sanction.

Hearing listed for 09/06/2017.

3 Cha Appeal against Medical Practitioners Tribunal decision.

Awaiting judgment – (reserved but yet to be handed down) following hearing before HHJ Gore on 16/02/2017.

4 Cho Appeal against Medical Practitioners Tribunal decision.

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

5 E Appeal against Medical Practitioners Tribunal decision.

Hearing listed for 28/03/2017

6 H Appeal against Medical Practitioners Tribunal decision.

Awaiting hearing date.

7 I Appeal against Medical Practitioners Tribunal decision.


8 N Appeal against Medical Practitioners Tribunal decision.


9 Ny Appeal against Medical Practitioners Tribunal decision.


10 O Appeal against Medical Practitioners Tribunal decision.

Adjourned – to be relisted after 24/03/2017.

11 R Appeal against Medical Practitioners Tribunal decision.



C4


12 S Appeal against Medical Practitioners Tribunal decision.


13 Sh Appeal against Medical Practitioners Tribunal decision.

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

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

of 22 March 2017.


1 J Appeal against Medical Practitioners Tribunal decision.

Hearing listed for 9-10/05/2017

2 C Appeal against Medical Practitioners Tribunal Service

Awaiting re-listing date.

3 S Appeal against Medical Practitioners Tribunal Service


4 N Appeal against Medical Practitioners Tribunal decision.


5 T Appeal against Medical Practitioners Tribunal decision.


6 Nw Appeal against Medical Practitioners Tribunal decision.




8 L Appeal against Medical Practitioners Tribunal decision.



C5

10 The table below provides a detailed breakdown of outstanding PSA (s.29) appeals as of 22 March 2017.




2 S Appeal against Medical Practitioners Tribunal decision.

Hearing listed for 9-10/05/2017

11 The table below provides a detailed breakdown of outstanding Judicial Reviews as at 22 March 2017.

No Case Claim Current status

1 H Application for Judicial Review of the GMC's decision to refuse to re-open a complaint under Rule 12.

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

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

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

3 R Application for permission to JR CE decision to offer advice on misreporting allegation which was not part of GMC case at Rule 7.

The terms of a consent order for the dismissal of the proceedings with no order as to costs have been agreed. Awaiting sealed Consent Order.


C6

No Case Claim Current status

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

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



M4 – Annex D

Corporate Risk Register 1 Risk appetite statement

2 Corporate risk register

of 9

Inherent business risks and how we manage them

Like

lihoo

d

Impa

ct

Ass

essm

ent

Like

lihoo

d

Impa

ct

Ass

essm

ent

8

Del

iver

y pa

rtne

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

P.BuckleyH

ighl

y lik

ely

Maj

or

Criti

cal

• GMC processes and systems have other relevant checks/controls

• Individual process controls exist around major interfaces

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

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

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Council• Discussion at Council Seminar (tbc)

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

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

-

9

Dat

a

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

N.Roberts

Hig

hly

likel

y

Maj

or

Criti

cal

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

• Certified to BSI10008 standard

• Information Security Working Group oversees controls

• Security incident reporting process in place

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

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Information Security Working Group

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

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

-

12

Exte

rnal

env

ironm

ent

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

P.Buckley

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

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

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

• Engagement programme of Chair and Chief Executive

• Performance monitoring and reporting

• Risk management framework - escalations

• Research agenda

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

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

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

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

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

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

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

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

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

ID Risk Controls in place to mitigate risk

Risk pre-controls

Func

tion

/ A

ctiv

ity

Owner

Strategic aim 1 - Making the best use of intelligence

CommentAssurance

Residual risk with controls in place

Council and/or Board Review

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Owner CommentAssurance



21

Legi

slat

ion

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

A.Omo

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

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

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

• Cross-directorate impacting completed

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

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Council • Regular updates via COO report

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

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

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

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

22

Exte

rnal

env

ironm

ent

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

S.Goldsmith

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Monitoring and forecasting of Fitness to Practise case loads

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

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

• Monitoring external environment

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

Unl

ikel

y

Mod

erat

e

Low

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

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

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2

Educ

atio

n -

qual

ity a

ssur

ing

prov

ider

s

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

C. Melville

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Documented process and procedures to investigate and monitor concerns

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

• Trained and available staff and Associates

• Enhanced Monitoring Information Published on our website quarterly

• Relationships with other delivery partners

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

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

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

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

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

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

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

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

-

4

Reva

lidat

ing

doct

ors

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

U.Lane

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Documented process and procedures

• Regular performance monitoring and reporting

• Trained and available staff

• Local clinical governance systems identify and address performance concerns

• Employer controls help protect patient safety

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

Unl

ikel

y

Mod

erat

e

Low

Council• Operational KPIs reported each meeting

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

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

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

-

7

Ethi

cal s

tand

ards

& g

uida

nce

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

C. Melville

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Internal oversight group

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


• Extensive outreach and engagement activities to promote ethical guidance

• Proactive communications strategy and website improvements

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

Unl

ikel

y

Mod

erat

e

Low

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

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

• Annual tracking survey 2015 indicates good awareness of our guidance

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

Strategic aim 2 - Raising standards in medical education and practice

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

1

FtP

- in

vest

igat

ing

conc

erns

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

A.Omo

Qui

te li

kely

Maj

or

Criti

cal

• Documented process and procedures


• Trained and available staff (general)

• Training programme for decision makers

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

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

• Reform agenda to drive process improvements


• English Language process introduced

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

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

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

• Stream 2 process replaced by Notify Employer/Notify RO

Unl

ikel

y

Maj

or

Sign

ifica

nt

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

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

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

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

5

Adju

dica

tion Patient safety is impacted and/or

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

L. Geddes

Qui

te li

kely

Maj

or

Criti

cal

• Documented process and procedures (Adjudication Manual)


• Trained and available staff (including MPTS induction)

• Tribunal members training and assessment (including Induction programme)

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

Unl

ikel

y

Min

or

Low

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

MPTS Advisory Committee• Quarterly reports to MPTS Advisory Committee

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

Other Assurance• Professional Standards Authority (PSA) Performance Review 2014/15 Standards of good regulation met• Review of MPTS outcomes and affected characteristics, no issues identified with bias toward gender or ethnicity (Feb 2017)

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6

FtP

- sa

nctio

ns

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

A.Omo

Unl

ikel

y

Maj

or

Sign

ifica

nt

• Case Review Team - documented processes and skilled resources

• Sanctions are listed on the List of Registered Medical Practitioners

• Notification of overseas regulators (if required)

• Publication of public hearing minutes



• Continuing development of GMC/RO relationships

Unl

ikel

y

Mod

erat

e

Low

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

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

-

10

Legi

slat

ion The UK and European

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

P.Buckley

Hig

hly

likel

y

Mod

erat

e

Criti

cal

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

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

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

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

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

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

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

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

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

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

19

Exte

rnal

env

ironm

ent

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

P.Buckley

Qui

te li

kely

Maj

or

Criti

cal

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

• Ongoing engagement planned with Governments and key stakeholders

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

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

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

• Publication of analysis of licensed doctors with an EEA PMQ

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

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

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

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

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

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

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20

Exte

rnal

env

ironm

ent

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

P.Buckley

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

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

Quite likely Min

or

Low

Council• Regular milestone for Council review to be agreed

Performance and Resources Board• PRB agreement of risk September 2016

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

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3

Regi

ster

ing

doct

ors

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

U.Lane

Qui

te li

kely

Maj

or

Criti

cal

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



• Information exchange with competent authorities informs our processes



Unl

ikel

y

Mod

erat

e

Low

Council• Operational KPIs reported each meeting

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

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

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

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

-

13

Med

ia

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

P.Buckley

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Skilled and resourced media team to handle media enquiries

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

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

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

• Governance - media principles agreed by Chair & Chief Executive

• Development of Media Strategy includes audience plans

Qui

te li

kely

Min

or

Low

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

Performance & Resources Board• Media performance reviewed at each Board

Strategy & Policy Board• Relationships Review (Oct 2016)

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

Other Assurance• Tracking Survey publication April 2015

We are currently reviewing the media principles to look at using an increased number of staff for media activity and measuring the sentiment of media coverage. In due course we hope to change the Council KPI to align with this.

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

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

11

Gov

erna

nce Our governance arrangements

may not enable the Trustees to discharge their accountabilities effectively

S.Jones

Hig

hly

likel

y

Maj

or

Criti

cal

• Governance arrangements in place including Council, executive and external engagement and in relation to GMC Services International Ltd

• Performance management system for members and staff

• Business planning & budget setting process

• Risk Management Framework

• Performance monitoring & reporting

• Policies and procedures

• Internal audit

• Council member training and annual appraisal in place

• Regular governance reviews

Unl

ikel

y

Mod

erat

e

Low

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

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

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

-

14

Fina

ncia

l con

trol

s (f

raud

) an

d ex

pend

iture

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

N.Roberts

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

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

• Monthly management reporting and review

• Financial controls including delegated authorities by the PRB

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

• Oversight of Investment Policy by Investment Sub Committee

Unl

ikel

y

Mod

erat

e

Low

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

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

Performance & Resources Board• Financial performance reviewed at each meeting

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

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

-

15

Wor

k pr

ogra

mm

e de

liver

y

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

C. Massey(S.Goldsmith)

Qui

te li

kely

Maj

or

Criti

cal

• Business planning & budget setting process

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

• Monthly monitoring of delivery progress and reporting

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

• Trained and skilled staff in project management

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

• Corporate Business Planning Manager stage gate reviews for all projects

Unl

ikel

y

Mod

erat

e

Low

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

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

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

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16

Staf

fing

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

N.RobertsQ

uite

like

ly

Maj

or

Criti

cal

• Talent and leadership programmes builds capacity

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

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

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

•Working with our advertising company, LinkedIn and outreach activities to target our marketing activity helping to increase our external profile as an employer of choice.

• Working with our PSL partners to source candidates and temps to ensure core functions are supported.

Unl

ikel

y

Mod

erat

e

Low

Council• Council receive an annual HR report

Council - Members Circular• Niall decision to step down (Jan 2016)• CE recruitment (April 2016)• Senior Staff Appointments/Changes (June; July)• HR end of year and mid year report to Council

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

Internal Audit• Review of induction planning (August 2016, green)• HR appraisal review (June 2015, green-amber) • HR conducting annual review of succession planning

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

-

17

Busi

ness

Con

tinui

ty

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

N.Roberts

Qui

te li

kely

Maj

or

Criti

cal

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

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

• Testing of process recovery

• Information security processes protect against IS failures

Unl

ikel

y

Mod

erat

e

Low

Business Continuity Working Group - (2 monthly)

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

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

18

Ope

ratio

n of

DB

pens

ion

sche

me

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

N.Roberts

Qui

te li

kely

Maj

or

Criti

cal

• Maintaining adequate reserves

• Future liabilities restricted by scheme closure and benefits changes

• Full implementation of Trustees de-risking investment strategy

Unl

ikel

y

Mod

erat

e

Low

Council approved the triennial valuations and agreed the additional payments into the scheme. Furthermore Council have requested a further strategic review.

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

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

-

Current active risks and how we are reducing them

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ent

1A

Util

isin

g da

ta

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

P.Buckley

• Data Strategy

• Patient Safety Intelligence Forum

• Quality Architecture Project Group

• Quarterly surveillance groups consider risk with CQC

• Existing specialist data teams and Siebel analytics capability

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

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

• Existing employer controls to protect patient safety

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

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

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

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

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

Evaluation of data sharing agreements to be undertaken by CAT (April 2017)

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

Council • Developing the online medical register (December 2016 and Feb 2017)• Chief Operating Officer's Report (June 2015; Sep 2015)

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

-

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te li

kely

Mod

erat

e

Sign

ifica

nt

12- External Environment

4A

Equa

lity

& D

iver

sity We do not comply

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

P.Buckley

• Equality & Diversity Strategy

• Directorate action plans

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

• Equality analysis undertaken as a component of major project activity

• Equality and diversity training for all staff and associates

• E&D Programme Board (chaired by COO)

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

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

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

• Phase II Unconscious Bias training for staff and associates

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

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

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

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

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

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

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

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

E&D operationalisation (July 2016, green)

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

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

Internal workshop on reasonable adjustments took place

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

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

Unl

ikel

y

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erat

e

Low 1-7

Strategic aim 1 - Making the best use of intelligence

ID Risk Owner

Fun

ctio

n /

Act

ivit

y Residual

Existing controls(incl. Local QA where relevant)

Corporate Risk that

Action Plan relates to

Comment(incl. external assurance where

relevant)

Further mitigating actions to be implemented

(with target date)

Risk target

Council and/or Board ReviewInternal Audit

coverage

313


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10A

Med

ical

Lic

ensi

ng A

sses

smen

t

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

C. Melville

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

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

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

• Regular engagement takes place with the Medical Schools Assessment Alliance

• Sufficient resource and budget allocated

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

• Appointment of Expert Reference Group meeting from October 2016

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

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

• A public consultation launched in Janaury 2017 and will closed in April 2017.

Qui

te li

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Mod

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Sign

ifica

nt • Review the outcomes for graduates (2017)

• Continued engagement with key stakeholders to support the consultation (April, 2017)

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

Strategy & Policy Board• Initial business case May 2015

Review planned 2017

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Low 12 - External

Environment

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

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

nlik

ely

Mod

erat

e

Low

Strategic aim 2 - Raising standards in medical education and practice

2A

Rev

alid

atio

n

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

U.Lane

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

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

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

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

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

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

Qui

te li

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erat

e

Sign

ifica

nt

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

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

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

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

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

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

12 - External Environment

314


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14A

Wor

king

with

reg

ulat

ory

part

ners

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

S. Goldsmith

• Information sharing agreement in place with CQC

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

• Education enhanced monitoring process in place

• Internal processes to manage communications


Qui

te li

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Hig

h

Criti

cal

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

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

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

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

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

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

Other• CE gave evidence to the Health Select Committee about the impact of Brexit on medical regulation (February 2017)

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

Development of PSIF alligned to vision of new CE - moving towards better understanding of impact on the healthcare system

Qui

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e

Sign

ifica

nt

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

315


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13A

Util

isin

g da

ta

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

P.Buckley

Regular media monitoring of historic abuse cases

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

uite

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ly

Mod

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e

Sign

ifica

nt

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

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

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

uite

like

ly

Mod

erat

e

Sign

ifica

nt

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

316


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3 - Registering doctors

Low

Mod

erat

e

Unl

ikel

y

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

Free

dom

of

mov

emen

t

6A

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

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

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

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

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

Audit and Risk CommitteeSession on RPQ risk (May 2015)

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

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

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

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

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

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

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

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

Sign

ifica

nt

Mod

erat

e

Qui

te li

kelyU.Lane

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

317


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11A

Chan

ge P

rogr

amm

e

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

S. Goldsmith

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

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

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

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

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

• External specialist input and scrutiny provided through Pension Trustee Board

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

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

• Detailed risk analysis and individual project risk registers

• Communication strategy for Internal and external stakeholders in place

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erat

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Sign

ifica

nt

• Ongoing lease negotiation advice sought from property advisers. Second property consultancy (Jones Lang LaSalle) engaged to work alongside Cushman & Wakefield [4 January 2017]

• Agreement on lease disposal strategy based on advice from property advisers completed [6 April 2016 with Cushman & Wakefield, reviewed and confirmed with C&W and JLL 17 January 2017]

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

Change programme papers and presentations have been discussed at:

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

Benefits realisation review in 2017

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

Unl

ikel

y

Mod

erat

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Low

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

12A

GM

C Se

rvic

es I

nter

natio

nal L

td

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

S. Goldsmith

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

Qui

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erat

e

Sign

ifica

nt

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

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

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

GMC Services review 2017

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

GMC Services International Ltd was incorporated in December 2016

Unl

ikel

y

Mod

erat

e

Low

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

318


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• Legal advice sought throughout the set up process • GMC SI incorporated (December 2016) and model articles of association adopted on incorporation• Creation of GMCSI Board with two 2 GMC Executive Directors in place from December 2016• Head of Business Development for trading subsidiary appointed (January 2017) on secondment from GMC• Work pipeline in place• Supplier Forum in place to manage resourcing requirements

S. Goldsmith

In setting up and operating a trading subsidiary, the GMC may not have assurance and clarity of how the subsidiary is being managed with a potential reputational and/or financial impact

GM

C Se

rvic

es I

nter

natio

nal L

td

16A

Mod

erat

e

Hig

hly

likel

y

Extensive legal external advice has been sought throughout the setup of the subsidiary process

Internal audit coverage planned for January 2018

Council Approval given to GMC Services International Ltd incorporation December 2016

• Governance structure being put in place including formal reporting arrangements to ARC for discussion (March 2017) and Council (April 2017). • Investment Sub Committee investment proposal and decision (May 2017)• Operating framework being established in accordance with appropriate legal requirements including Charity Commission and HMRC (February 2017)• Independent subsidiary board members being appointed (Date TBC)• Independent interim Chair to be appointed (Feb 2017)• Conflicts of interest policy under development for inclusion in framework (February 2017)• Financial framework to be agreed for use of GMC resources for inclusion in framework (February 2017) • Planned pipeline to manage workflow and resource needs being developed (ongoing through Supplier Forum) • Principles for target world markets to be developed (April 2017) • Governance structure and operating framework will document the relationship management structure and arrangements between GMC and GMCSI. The effectiveness of these arrangements and the working relationship will be reviewed every 3 months until bedded in and then on a 6 monthly or annual basis as appropriate.

Low

Mod

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e

Unl

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cal

319


Risk appetite statement

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

medical education and practice across the UK.

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

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

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

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

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

relation to our activities.

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

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

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

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

Council meeting, 26 April 2017 Agenda item M4 – Chief Operating Officer’s report

2

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

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

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

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

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

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

11 We have shown this diagrammatically below.



M4 – Annex E

Modern Slavery and Human Trafficking Statement 2016

Introduction

1 This statement sets out our actions to identify the potential modern slavery risks related to our business and the steps we have taken to ensure, as far as possible, that there is no slavery or human trafficking in our business and our supply chains. This statement relates to the period 1 January 2016 to 31 December 2016.

2 As a public sector body, the GMC recognises that it has a responsibility to take a robust approach to slavery and human trafficking and is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and purpose

3 The purpose of the General Medical Council (GMC) is to protect, promote and maintain the health and safety of the public by ensuring proper standards in the practice of medicine.

4 The law gives us four main functions under the Medical Act 1983:

a keeping up-to-date registers of qualified doctors

b fostering good medical practice

c promoting high standards of medical education and training

d dealing firmly and fairly with doctors whose fitness to practise is in doubt.

5 The GMC is a registered charity in England and Wales (1089278) and Scotland (SC037750).

6 Our governing body, the Council, has 12 members of which six are doctors and six are lay members, all appointed through an independent appointments process.


E2

7 The GMC has two major centres, one in London and two in Manchester, with smaller offices in Edinburgh, Cardiff and Belfast and a significant number of staff who work remotely and out in the health service. These sites accommodate approximately 1150 full and part time staff in the Office of the Chair and Chief Executive and across six directorates, which are:

a Registration & Revalidation

b Fitness to Practise

c Resources and Quality Assurance

d Education and Standards

e Strategy and Communication

f Medical Practitioners Tribunal Service

Modern Slavery and Human Trafficking Policy

8 During 2016, the GMC Performance and Resources Board reviewed and approved our policy on modern slavery and human trafficking.

9 We have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own businesses or those of our suppliers.

10 The nature of our business means that the risk of modern slavery in our directly managed business activities and the first line of our supply chain is low. We require all our suppliers to have robust anti-slavery and human trafficking arrangements in place.

11 If a supplier is found to be accepting of slavery in their business or supply chain we will terminate the contract and notify the relevant authorities.

Actions taken in 2016

12 In addition to agreeing and publishing our policy on Modern Slavery in 2016, we implemented a series of activities to mitigate the risk of modern slavery and human trafficking occurring within our organisation and supply chains:

a All staff received guidance explaining what modern slavery is, how to identify it, and how to log concerns.

b All recruited permanent and temporary staff are subjected to identification and background checking.


E3

c We have living wage accreditation from the Living Wage Foundation.

d We made all our suppliers aware of our Modern Slavery policy through our contract management processes.

e We updated our standard terms and conditions to ensure that our contracts with suppliers placed obligations on them to apply the principles of the Modern Slavery Act in their business and supply chains, and enable GMC to assure ourselves that they are complying with this.

f All suppliers were advised of how to log concerns with the GMC of any concerns that Modern slavery or human trafficking activity was occurring in our organisation or supply chain.

g We conducted a workshop to assess whether any specific suppliers required further intervention activity to reasonably satisfy us that steps were being taken to prevent Modern slavery and trafficking in their supply chains. It was determined that given the nature of our supply the current steps were considered appropriate in all cases, but this would be regularly reviewed.

SIGNED

Susan Goldsmith

Chief Operating Officer

General Medical Council

m4 chief operating officer’s report susan goldsmith...council meeting, 26 april 2017 agenda item:...

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