The Royal College of Physicians (RCP) has responded to the Department of Health and Social Care (DHSC) consultation on reforms to the General Medical Council (GMC) legislative framework, supporting the overall direction of modernisation while highlighting several important concerns about oversight, accountability and patient safety.
The RCP supports proposals to create a more flexible and proportionate regulatory system, including reforms to fitness to practise processes and governance arrangements. It welcomes measures to improve efficiency and strengthen action in cases involving serious criminal offences.
However, the college raises concerns that some proposals could weaken scrutiny of the GMC. In particular, the RCP does not support the removal of routine Privy Council approval for rule changes and is clear that stronger safeguards are needed, including a statutory requirement for meaningful consultation with the medical royal colleges and greater transparency in decision-making.
The college has also raised concerns about proposals to retain the GMC’s right of appeal against tribunal decisions, arguing that the Professional Standards Authority should take on this function to ensure consistency across health regulators.
The RCP is clear that the role of medical royal colleges in education and training must be protected. Colleges must continue to lead on setting curricula and standards, and there should be no move towards unilateral decision-making by the GMC, including on overseas training programmes. The Certificate of Completion of Training (CCT) must remain the recognised benchmark for specialist qualification for doctors, and the integrity of UK training routes must be preserved.
Professor Mumtaz Patel explained:
‘A CCT should only be awarded to a registered medical practitioner after completion of an approved UK postgraduate training programme. The integrity of the CCT as the gold standard for specialty qualification must be preserved.’
The college also highlights the importance of embedding equality, diversity and inclusion in the regulatory framework, with a particular focus on ensuring that reforms lead to meaningful change in how fitness to practise cases are handled, including those involving allegations of racism.
Concerns have also been raised about proposed changes to registration, including the move to a single register and the introduction of a ‘complete restriction’ status, which risk creating confusion for both doctors and patients if not clearly implemented and communicated.
On professional titles, the RCP supports efforts to improve clarity for patients. This includes protecting the title ‘registered medical practitioner’ and renaming ‘physician associates’ as ‘physician assistants’, alongside clearer definitions of roles, responsibilities and scope of practice to reduce patient confusion.
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