How to Keep a UK’s GMC License to Practice
you are working abroad for more than a year you
could lose your UK GMC license to practice in the UK ,
and worse still you would lose your position on the NHS GP performers'
list unless you followed
rules below. Alas, as you go to the bottom of this blog, you read
that recent changes may make it more difficult, despite various
NHS announcements to encourge doctors to come home or come to the UK.
You may be aware that that overseas
practice, that means anywhere
where there is no UK NHS, is seen by some as a career break, which of
nonsense as you are learning more than staying at home. This xenophobic
that anything outside the NHS is beyond the pale has coloured RCGP and
thinking. Even the Channel Islands and all British Overseas Territories are
regarded as foreign by these institutions. The
GMC has until recently been much more pragmatic, but we have to
worry about the interpretation
by RCGP and local health authorities. Bureaucrats look for
from RCGP CoGPED
There are two linked issues. You
need to stay on the performers’ list so
you can go back into general practice on return to the UK.
Then you need to be
revalidated by the GMC to continue to have a licence to practice in the
The performers’ list requires that you work one day a year in
the UK as a GP and
do an annual appraisal, and being revalidated requires five appraisals
few up to the new required standard. Various localities may
attempt apply longer UK working rules, but I do not think there is
any basis in law to have them applied.
When working abroad you do not want to burn your bridges, and need to
to come back to the UK without having to retrain in an expensive onesize fits all manner. Another
reason to keep a UK license is that that foreign registration
authorities and employers may not favour the GMC tag line
licensed to practice” when looking you up on the GMC
web site. The GMC is quite phlegmatic about giving up and
regaining the license to practice, and believes doctors should not be
fearful of doing so. I suspect the GMC fears being seen to
on the role of licensing doctors to practice overseas, but that
licensing is always the responsbility of
jurisdictions of the host country.
The GMC is not involved in
the performers' lists whose management is fragmented across the UK, so
we do we know
retraining rules to get back onto GP performers' list. The
main risk is coming off the performers lists with each area inventing
its own rules.
Retraining is a nonsense concept for those working
in primary care almost anywhere as so much is based on British
practice, espcially if working in Australia or New Zealand. The
suggestion of retraining implies that you are not in contact with home,
that the jet aircraft, let alone the internet have not
been invented. Yes, at one time keeping
in contact with Blighty when overseas required letter, telegraph and
If you have given up your UK license to practice, to get it back, the retraining needed is here https://gprecruitment.hee.nhs.uk/Induction-Refresher
The RCGP has a blanket rule banning the use of the easier sensible
portfolio route if you have been abroad more than five years no matter
where you have worked. This is at odds with with GMC and GP Recruitment expectations of flexibility according to needs. Beware of this trap.
you have been abroad less than five years, and may yet come back to the
UK, do the portfolio route, much of which can be done abroad, and
get back your license to practice and place on the performers list,
then keep up your license with regular appraisals.
I had been working almost full
time overseas for seven
years, and was back in the UK regularly. I was revalidated
after six years, and have my licence to practice
UK for another five years. I am working again in London as if I never
left. I gained useful
overseas for UK practice, and like to think, as does my appraiser, that
overseas experience contributed to NHS practice. This may not work now
for such long spells now. New changes in May 2018 (see last
update below) means the GMC is expecting the data to be UK
based, and the doctor to be working mainly in the UK . This is a
huge backwards step, and I am puzzled that the GMC has taken this step,
which is not in line with GMCs earlier advice.
is to stay on the performers list and continue with your
UK NHS appraisals until you have decided you are never going back to
the UK; then
you can give up appraisals and stop paying the GMC fee.
Appraisals are good for you, and doing them
makes overseas CPD
Here are my
voluntarily give up your license to practice when you have decided to
We do not know the potential difficulty in getting the
license back on your return or back onto the preformers' list. Any
bureaucrat will find it is safer to
say no and interpret rules and opinions they see from any source
strictly, requiring retraining of some sort on return. It is
a huge risk giving up one’s license. Don’t, unless
never coming back.
Authorities do not need to know your future plans or where you plan to
work other than you do plan to do locums in your area so need to be on
the performers’ list. Stay on the list.
resigning from your
partnership make sure you transfer from provider to performer on the
National GP performers' list. Under no
circumstances resign from the performers' list altogether.
You need to be on it to have an NHS GP appraisal and GMC responsible
officer. Some doctors have been told they MUST
resign. Do not resign.
your appraisals when working abroad. This is
essential. Appraisals are good for you anyway and make all
other country's CPD requirements very easy indeed. Other countries CPD
systems are more basic and can credit you points for your NHS
appraisal. You can add overseas data your appraisal folder, or
clarity.co.uk profile. Alas since May 2018 the GMC advice is that
the majority of this data has to come from UK practice. This make long
term working overseas working more problematic.
- Make sure you point out how up to date and in contact with UK practice you are within th folder.
with your appraiser that they
are happy with this; most will be delighted to have something
different. The data you collect will be from your overseas
work. You might have to pay for your appraisal
yourself. In your appraisal you need to outline how you are
keeping with UK practice, and how you new knowledge will be of use on
returning to the UK. You
can find other appraisers. InternationalSOS and others have their
appraisal system that will keep you licensed but may not keep you on
the performers’ list.
back to see your family every year, do a short locum, a few days,
perhaps you do this at your old practice (charge them very little!) and
while there you can also have your appraisal in the UK. Skype is useful
as well to do this, or split the appraisal between Skype and person to
person. Just one day's UK GP practice working and appraisal
keeps you on the performer's list. Revalidation follows on in the
normal way. Keep up with your appraisals at all
expense is MDU/MPS and both have mechanisms very low insurance costs
for this situation. You do not need to keep up the full subs.
GMC in its Advice to local
GMC Responsible Officers fitted in with this line. Its
statement below emphasises the
importance that the appraisal evidence and data is relevant for UK
which is quite easily done. It asked
ROs to consider the proportion of the appraisals that is
relevant to UK practice:
GMC Guidance for Responsible
Information from overseas practice or practice that does not require a
practise in settings where they do not require a UK licence –
for instance, they may work abroad, or they may undertake
specific functions in the UK that do not legally require a
licence to practise.
is the case, it is at your (RO) discretion whether you consider
supporting information from these practice settings in making your
judgement. You should consider whether such information is material in
your evaluation of their fitness to practise, taking account of whether
it is demonstrably relevant to the doctor’s licensed UK
practice and the proportion of the doctor’s supporting
information that it represents.”
that SOME appraisal
teams in parts of England had been reading that to mean the proportion
of actual data
(360, complaints, PUNS,DENS, audits etc) has to come from the UK
and that would even exclude all overseas courses, even those with international accreditation (ALS, ALSO etc). That was quite incorrect until May 2018! (see below)
That interpretation would mean all doctors having to
months a year in the UK to get all the required data; thus excluding
regular overseas returning super-specialists and most overseas
months of UK work would be at odds with requirement only to work one
day a year
in the UK to remain on the performers' list.
Update May 2018
The latest guidance to Regional Officers https://tinyurl.com/y85usps7 changes matters considerably, although may still be wriggle room if you are working overseas.
The wording is now quite different from the guidance above.
"We (GMC) expect doctors to collect their supporting information from the
practice that they undertake in the UK, unless there are exceptional
circumstances. For example a doctor in the military who is stationed
Only in exceptional circumstances would a doctor with supporting
information drawn wholly or substantively overseas from practice be able
to maintain their UK licence to practise.
If a doctor is working overseas only sporadically, as well as
undertaking UK practice, there is no reason why they can’t collect and
reflect on some evidence from that practice as part of their appraisal.
You can use your judgement to decide whether or not to accept
supporting information from practice that does not require a UK licence.
You may wish to consider:
If you (RO) decide the supporting information from overseas practice is
not relevant, you should discuss with the doctor what alternative
information they need to provide."
- the relevance of the supporting information to the doctor’s licensed UK practice
- what proportion of the doctor’s supporting information it represents
- whether it is material to your evaluation of their fitness to practise.
The GMC guidance still make no concessions for those working in British Overseas Territories.
It seems it may be possble to negotiate the R.O.
If you have data from UK practice to use that is relatively
recent, things may still be OK. However the default position of
any officer, fearing being blamed for errors, will be to be
restrictive and offer no leaway.
Update September 2018
Registering and doing a few sessions with UK remote GP services such as GP AT HAND or Babylon (there are new competitors entering this market) where you offer on line consultations to UK patients, may convince all that you never left UK practice. Location
in a different time zone may even help as you could offer out of hours
services. No doubt you will need UK indemnity.
Update July 2017
It seems from the feedback I have had that some regional officers and
appraising groups have been muddying the waters by applying various
other rules outside GMC requirements. GMC regional officers have no
role in maintaining the performers' list. The GMC has recognised this meddlesome trend and in
the publication Taking Revalidation Forward the GMC has the following statement in Sir Kieth Pearsons recommendations (Appendix B)
The GMC should continue its work with partners to update guidance on
the supporting information required for appraisal for revalidation to
make clear what is mandatory (and why), what is sufficient, and where
flexibility exists. They should also ensure consistency and
compatibility across different sources of guidance.
9 Responsible officers should
make sure that the revalidation process for individual doctors is not
used to achieve local objectives that are not part of the requirements
specified by the GMC.
GMC Policy Change?
The GMC need not encourage GP to give up a license to
practice, which always means giving up a place on the performers'
list....the latter is far too risky. My
view is that the GMC should turn about, and further faciliate GPs
abroad, and then enable doctors to come back to UK with ease,
providing doctors have kept up their appriasals. This May 2018 GMC has gone
backwards making it more difficult for GPs to return to
UK practice from overseas. I suspect this is due to lobbying from
the Medical Education Industry here. This policy conflicts with
statments made in the media: Guardain encourage overseas doctors to come home. 2018 Goverment announced it will ease red tape for Australians GPs coming to UK, It would be odd if it is made easier for an Australian GP to come UK over than for a UK trained GP to return!
Abolish the Performers' lists.
me at https://bulger.co.uk/message.htm
The NHS has no place as an employer in licensing doctors as General Practitioners,
which in effect is what the performers’ lists do. The role of registration and definition of a specialist is properly carried
out by the GMC. No other doctor group
has to undergo a double registration process, GMC and then also NHS. The performers' list is an anachronism, a left
over from before there was GP training, let alone MRCGP. The
GMC should take over and abolish the
performers’ lists by registering GPs as specialists; catching up
with most countries. GPs for example are registered as specialists in
Australia, so no need for a performers' list there. BMA/RCGP are moving in this direction in 2016 and again in 2018
- Australia experience
Learning points for doctors to australia
is here at
get a password for that email me here
Gerard Bulger BSc MBBS DCH FRACGP FRCGP