On the merger of the GMC and PMETB in April 2010 the GMC became responsible for the awarding of the CCTs, other than streamlining the application process the policy around awarding of CCTs has not been reviewed. The CCT application process requires an application from the trainee and a recommendation from the parent College. The GMC invites those trainees that the College have indicated are due to complete their training in the next three to six months, to apply for their CCT via GMC Online. The College use the information that they hold on the trainee to determine whether they consider that the trainee has fulfilled the curriculum requirements and to provide the GMC with a recommendation. The College base their decision on information from the local Postgraduate Medical Education (PGME) office and usually additional information submitted by the trainee.
Once the GMC has received the application from the trainee together with the recommendation from the parent College the GMC issue the trainee with the CCT and add the doctors name to the specialist or GP register.
GP trainees in 96% of cases apply for their CCT in the month immediately before or the month after their CCT date. It is likely that this is because a GP trainee is removed from the performers list when their training finishes and cannot apply for entry (or re-entry) to a performers list unless they are listed in the GP Register.
Specialist trainees are less likely (51%) to apply within a month of their CCT date, this is likely to be because they can continue to work in any capacity other than that of a substantive NHS consultant (except a foundation Trust) and many of them also take up the opportunity provided for them by the local PGME office for a grace period (up to six months post CCT date).
In the last six months the GMC have received a small number of enquiries from doctors, PGME offices or medical Royal Colleges where a doctor failed to apply for their CCT (this will have been for numerous reasons). It appears that as doctors are preparing for their revalidation they are checking their registration status and are finding that they do not have specialist registration. One doctor had completed training in 2004.
There are a number of reasons which may make it impossible for the GMC to award a CCT to doctors who apply some time after their expected CCT date:-
- The final assessment was not carried out before they left training (i.e. no Annual Review of Competence Progression (ARCP) or for the doctors from some time ago no Record of In Training Assessment (RITA) G was undertaken)
- The College did not receive the information that they needed in order to be able to make a recommendation (either from the doctor or the local PGME office)
- The College made a recommendation to the GMC (or previously PMETB) but no application was received from the doctor.
In discussion with the PGME offices they have reported that where a trainee had not participated in the final ARCP/RITA at the time of their completion of training it becomes difficult to make a judgement that the trainee had fulfilled the CCT curriculum and becomes impossible when a long period of time has elapsed.
Colleges have reported that they are not able to make a judgement without PGME documentation or when the doctor has left training and is working in limited practice. They have also reported that they are not always able to respond if they have been asked by the GMC if a recommendation they have submitted still stands (this happens when there is a gap between the college recommendation and the trainee application of more than six months).
From those that apply (the GMC currently does not maintain details of trainees coming up to their expected CCT date and relies on the medical Royal Colleges to provide these details) 99% apply within six months of their expected CCT date.
Post training revalidation is linked to a doctors end of training and so it is important that the trainee concludes their training with the award of the CCT and gains entry to the Specialist or GP register.
Legal advice has confirmed that the GMC is able to limit the timeframe within which it will consider an application for a CCT.
The Postgraduate Board agreed to the introduction of a limit on the timeframe within which a doctor is able to apply for a CCT. This time limit is 12 months from the doctors expected end of training date. It was further agreed that this time limit would be introduced effective from 31 March 2013.
It was further agreed that the GMC would work with interested parties (Colleges, trainees groups etc.) to publicise this time limit. In addition the GMC would contact all the doctors that the GMC had been informed of (by the Colleges) that had to date not applied to inform them of this time limit.
It was noted that the GMC may not be able to make a decision on late applications submitted prior to 31 March 2013 where their was insufficient evidence of satisfactory completion of training (namely contemporaneous PGME and College documentation).
Doctors will continue to have the ability to apply for entry to the specialist or GP register but they would need to do so via the equivalence routes of CESR or CEGPR and provide the necessary documentation to confirm their current competence.
If numbers remain at the low level (four since Jan 2012) the financial impact is minimal as the additional work can be absorbed within current staffing. The affect on Colleges and PGME offices would be to reduce their work load in relation to delayed CCT applications but may increase the number of CESR/CEGPR applications, however they are resourced for these via the evaluation fee.
Contacting doctors who have not applied for a CCT will have resource implications for Colleges and the GMC will work with them to reduce this burden.
It was acknowledged that setting a time limit may have a disproportionate affect on less than full time trainees or those on maternity leave. To minimise this the time limit has been set at 12 months after a trainees CCT date which will give those in these groups sufficient time in which to submit an application. Other protected characteristic groups will not be affected by the implementation of the time limit.