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GPs Working Abroad:
How to Keep a UK’s GMC License to Practice

If 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 the 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 course is nonsense as you are learning more than staying at home. This xenophobic view, that anything outside the NHS is beyond the pale has coloured RCGP and CoGPED 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 “rules” 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 UK.  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 the last 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 be able 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 “registered, not 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 take 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 what the 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 steamer ships.

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. 

www.rcgp.org.uk/training-exams/practice/the-induction-and-refresher-scheme-portfolio-route.aspx 
If 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 in the UK for another five years. I am working again in London as if I never left.  I gained useful experience working overseas for UK practice, and like to think, as does my appraiser, that my 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.

The key 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 requirements a doddle.

Here are my suggestions

 
  • Do not voluntarily give up your license to practice when you have decided to work abroad.  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. 
  • Health 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. 
  • When 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.
  • Keep up 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.
  • Check 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.
  • When you go 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 costs. 
  • The other 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.

   This works.

Update December 2015

The 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 practice; 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 officers: .
“2.3.2 Information from overseas practice or practice that does not require a licence
Doctors may 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.
Where this 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.”

Beware 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 practice, 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 work three months a year in the UK to get all the required data; thus excluding the regular overseas returning super-specialists and most overseas working. Forcing 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 overseas.
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: 
  • 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.
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 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)

8 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 gaining experience 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. 
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

 Gerry Bulger     Message me at https://bulger.co.uk/message.htm  

  1. Australia experience
  2. Indonesia  2010
  3. Thailand 2011
  4. Northern Territories 2011 


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Dr Gerard Bulger BSc MBBS DCH FRACGP FRCGP


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