Local education providers (Trusts and GP practices) should report any trainees’ involvement in any conduct, capability or formal serious incident/significant event investigations or formal complaints to NHSE Education North East. Local education providers are required to report issues to the NHSE Education North East Revalidation Team at the time they occur as part of the “Live flow” process so that trainee problems can be managed and support offered to them.
Information from live reporting will be triangulated at the ARCP with the self-declarations made by trainees when completing the “Enhanced Form R”.
The GMC has issued guidelines for incident reporting which must be followed. However, it was felt useful for NHSE Education North East to produce additional guidance to assist local education providers to understand the reporting process.
The underlying principle for reporting issues is that the NHSE Education North East revalidation team should be notified about anything which causes concern that the trainee may not be meeting the requirements of “Good Medical Practice”. The GMC define a significant event as:
‘A significant event (also known as an untoward or critical incident) is any unintended or unexpected event, which could or did lead to harm of one or more patients. This includes incidents which did not cause harm but could have done, or where the event should have been prevented.’
In most instances it will be the identification of the need for a formal investigation which will trigger the notification, which will inevitably depend on the professional judgement of the individuals involved within the clinical and educational teams and practice/trust processes. Issues such as simple prescribing errors which it is felt can be resolved as part of normal educational management do not need to be reported.
Where a concern is raised and an investigation takes place the trainee and their educational supervisor must be fully informed of this. The trainee will be expected to reflect on the events and, supported by their educational supervisor, produce an educational plan to address any developmental needs identified. Once actions arising from the plan have been completed the concern can be considered resolved and “closed” for the purposes of revalidation.
This may come to light in a variety of ways including:
- Involvement in a serious incident
- Being the subject of a complaint
- Conduct which suggests an issue with the trainee’s probity or professional behaviour which results in either:
- a formal investigation by the LEP into clinical events
- an investigation by the LEP as employer of the trainee (for FP), or a referral to the lead employer trust (LET) (for specialty and GP trainees) of a concern which is felt to warrant investigation by them as there may be a disciplinary implication
NHSE Education North East’s Thresholds for reporting guidance document can be accessed here.
Some illustrative examples based on recent cases are given below. This list is not exhaustive and if in doubt do not hesitate to discuss with the NHSE Education North East Revalidation Team whether details of the concern should be notified to them.
| Issue |
Recommended Action |
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Ward Pharmacist notes prescribing error by Foundation trainee. No patient harm incurred.
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Review of error by clinical supervisor. Trainee reflects on this in eportfolio and identifies how to avoid errors in the future. No need to notify NHSE Education North East Revalidation Team.
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Specialty trainee prescribes wrong formulation of insulin. Patient suffers severe hypoglycaemic episode.
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The trust will need to consider this as an issue of patient safety and investigate it as a SI. Consequently the NHSE Education North East Revalidation Team should be informed, although ultimately with a suitable educational plan it may be resolved for the trainee.
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| Foundation trainee makes repeated prescribing errors, which do not result in patient harm, but seem to be recurrent |
The Educational supervisor should be made aware of this and its management should be Documented in the trainee’s portfolio. It is possible that this will lead to an adverse ARCP outcome, but is not an issue which needs to be reported to the NHSE Education North East Revalidation Team at this point as it will be managed by educational processes as long as the individual is seen to be making progress and remains within the training programme. However, if it appears that the problem is failing to improve despite remediation this could imply that the trainee is not fit for practice and requires a more formal assessment of capability and so the NHSE Education North East Revalidation Team should be notified.
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Specialty trainee is named in a SI though was probably simply an uninvolved bystander.
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The trust will be conducting a formal investigation and so the NHSE Education North East Revalidation Team should be informed. This will enable support to be offered to the trainee if required. If the investigation confirms that the trainee had no practical involvement then the record will be closed without further action (though the trainee should be encouraged to reflect on the events as a learning experience).
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A practice receives a complaint from a patient describing poor communication and brusque attitude by a GP trainee in hospital placed with them.
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A practice receives a complaint from a patient describing poor communication and brusque attitude by a GP trainee in hospital placed with them.
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The trust becomes aware that a speciality trainee has accepted a caution from the police because of antisocial behaviour.
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The trainee should be reminded of their responsibility to inform the LET as their employer. The NHSE Education North East Revalidation Team should be informed, and will share this information with the LET. Details of the caution will be recorded on the revalidation database but will not necessarily become a revalidation issue unless the behaviour is repeated.
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Speciality trainee is found to be breaching trust rules and avoiding payment by using a colleague’s parking permit.
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The NHSE Education North East Revalidation Team should be informed as this raises concern about the trainee’s probity. They will inform the LET as this is a potential disciplinary issue.
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Trust becomes aware that trainee previously placed with them is publishing adverse comments about their experience there on a social media site.
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The NHSE Education North East Revalidation Team should be informed as this raises concern about the trainee’s professional behaviour. They will inform the LET as this is a breach of social media policy and a disciplinary issue.
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