The recent amendment to the Medical and Health (Licence to Practice and Revalidation) Rules 2014, require the adoption of revalidation procedures as defined by the Board.
Registration is not only required by law, but also is a pre-requisite by insurers of medical indemnity and therefore practice without registration can result in severe penalties, which may include imprisonment and civil damages.
Any registered medical practitioner (a Doctor) who wishes to practise in Gibraltar is required to be part of a clinical governance system with annual appraisals and reporting systems back to their own individual Responsible Officer.
Clinical Governance System & Responsible Officer
Clinical governance is the system through which organisations are accountable for continuously improving the quality of their services and safeguarding high standards of care by creating an environment in which clinical excellence can flourish.
The Medical and Health (Responsible Officers) Rules 2014 recognizes the role in Gibraltar of Designated bodies (DB) as bodies that deliver and assure the quality of clinical governance processes for doctors. The Responsible Officer Rules currently list at the Schedule, as Designated bodies, the GHA, Postgraduate medical deaneries established in the UK and bodies which employ or contract with medical practitioners.
The Designated body is required to appoint one or more Responsible Officers (RO).
The RO will satisfy him/herself that the Designated body operates clinical governance systems that promote and protect the interests of patients and creates an environment which supports doctors in meeting their professional obligations. The DB will put in place Policies and Protocols that are adhered to and regularly monitored and revised, if necessary. It is the intention that the GMRB will have oversight of the DB’s clinical governance systems to make sure that they are fit for purpose.
All doctors in Gibraltar will need to have a prescribed connection with a DB.
This connection is usually obvious and Rule 9 of the Medical and Health (Responsible Officers) Rules 2014 describes the likely circumstances by which a medical practitioner will form a prescribed connection. It is important that each doctor knows who their DB is as this will almost certainly dictate who their RO is.
Good Medical Practice
The Board has adopted the General Medical Council’s guidelines, Good Medical Practice (March 2013) as its own code for registered medical practitioners.The General Medical Council’s current professional guidance may be obtained from its website:
Scope of practice
Most doctors who engage in the appraisal process are accustomed to detailing their scope of practice at the start of the appraisal. This ensures that the subsequent appraisal takes account of all aspects of that doctor’s medical practice so that training and reflection has been assessed appropriate to the individual doctor’s activities. When the appraiser makes a recommendation to revalidate, that recommendation is based on the declared scope of practice. If the doctor engages in other professional activities that are not declared within their scope of practice, there is no supervision or review of this activity and could even result in harm to the patient.
It is therefore vital that your scope of practice is fully declared to your appraiser and on your GMRB registration application. In effect, if your appraiser sees an activity as a separate professional activity, this should be included in your GMRB registration application form under the scope of practice or further expanded in the comments section at the end.
As an example, if you are a GP, you only need to note GP. However, if you carry out minor surgery lists, cosmetic procedures etc these should be added separately in your scope of practice.
Or, if you are an ENT Surgeon and you do some sessions as a GP, they should both be noted.