m4 - chief operating officer’s report · procurement process in september 2016, we have selected...

Council meeting, 14 December 2016

Agenda item: M4

Report title: Chief Operating Officer’s Report

Report by: Susan Goldsmith, Chief Operating Officer [email protected], 020 7189 5124

Action: To consider

Executive summary This report provides an update on our operational performance and Council priorities including the following items: Matters arising from the Performance and Resources Board in September and November 2016:

European Foundation for Quality Management roll out plan.

Contact Centre Service Level Agreement changes.

Data Strategy Programme.

Digital Media Strategy.

Fitness to Practise provisional enquiries.

Other operational matters arising: MPTS Operational Framework.

Revised Professional and Linguistic Assessments Board test.

Recommendations Council is asked to consider the report (and Annex A, Annex B, Annex C and Annex D).

mailto:[email protected]

Council meeting, 14 December 2016 M4 – Chief Operating Officer’s report

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Issue

1 This report provides an update on our operational performance, Council priorities and other operational matters arising.

Operational KPIs

2 All operational key performance indicators, at Annex A, were met up to the end of October 2016 other than the exception set out below:

3 2015/16 Income and expenditure [% variance] is at Annex B.

October saw an actual surplus of £5.8m compared to a budgeted surplus for the period of £1.3m. Income is currently in line with budget expectations but expenditure is 5% under budget due to a range of factors, including lower panel and assessment costs than expected and continued delivery of operational efficiencies. Some costs, including direct staffing, are forecast to move closer to budget in the remainder of the year. Our latest forecast outturn for year end is a surplus of £2.5m. A principle reason for the variance from the surplus figure reported in October is a charge of £2.4m related to the pension scheme, which was agreed with Council with at its closed session in November 2016.

4 We can now report on our annual KPI relating to our engagement activity with external policy influencing partners. This year’s survey was sent to 65 of the GMC’s top policy influencing partners, as identified by our external relationships teams*, with 33 completed responses (50.7%) which is an improvement on last year’s response rate (41.3%). The results show that 90.9% of respondents agreed that their engagement with us during 2016 had a positive influence on their impression of the GMC.

Council Priorities

5 As of October 2016, the majority of Council priority work has a green status other than the exception set out below. A summary of the position is at Annex A.

6 Red – ‘Council priority 5: Revalidation review’

The progress on the Review of Revalidation is reported as red as the publication date of the report has been delayed from December 2016 to mid-January 2017. This is to make sure there is sufficient time to engage with key stakeholders before publication.

* The UK Government, Parliament & Stakeholder Relations team, the Devolved Offices and the European & International team.


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A communications plan has been drafted and during January 2017 there will be a joint session with Sir Keith Pearson and the GMC to brief key stakeholders on the report. We will also hold a press briefing prior to publication.

7 The following activities are now complete with more detail in Annex A:

Implement PLAB review.

Whistleblowing – FtP post-Hooper Review pilot.

Operational risk reporting

8 The GMC’s approach to risk in decision-making is outlined in Annex D along with the current Corporate Risk Register. There are no specific matters arising to report at this meeting.

Performance and Resources Board meeting updates

9 The Performance and Resources Board met on 27 September 2016 and:

a Considered and agreed a plan for rolling out the next phase of European Foundation for Quality Management (EFQM) across the organisation, linked to the development of our new Corporate Strategy. EFQM is a widely-used methodology for the assessment of key strengths and potential gaps in relation to an organisation’s stated vision and mission. I have used this model with other organisations across sectors to identify priority areas to support the achievement of strategic aims and the delivery of excellence in operational activities.

b Considered an approach and options for changing our Contact Centre service level agreements (SLAs) for responding to calls and emails. Our aim is to improve the current SLA for answering emails by easing the call answering SLA. Our current call answering SLA is far more ambitious than the industry standard and we feel that repositioning it will allow us to divert resources from calls to emails while still maintaining a high standard of service for calls. It was agreed to change the call SLA from 90% of calls answered within 15 seconds to 80% of calls answered within 20 seconds albeit with additional monitoring and analysis of call abandon rates to understand if this is impacting customer service levels and the email SLA from 95% of emails responded to within five days to 90% of emails responded to within four days for a 12 months transitional period before moving to 80% of emails responded to within three days.

http://www.efqm.org/


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The changes will be implemented from 1 January 2017 and monitored through the Performance and Resources Board in 2017.

c Considered an update on our progress in delivering the Data Strategy Programme and options for further work in 2017. The development of our data strategy since 2014 has helped us to identify, analyse and better understand trends and areas of risk, making use of both external and our own data. This work includes the pilot of our UK Medical Education Database (UKMED) aimed at bringing UK undergraduate and postgraduate data together into one central place for research applications. The Board committed to developing ways of sharing our data capabilities for the benefit of our stakeholders and the public during 2017 and further understanding the commercialisation opportunities open to us.

10 The Performance and Resources Board also met on 1 November 2016 and:

a Noted an update on our Digital Media Strategy, which I updated Council on at the 27 September 2016 meeting. This project is aimed at transforming the way we engage with our audiences to give us digital-first and ‘user-centred’ content and processes for customer-facing services. Since then, following an open procurement process in September 2016, we have selected Sitecore for the new content management system (CMS) and Mando as our implementation partner. Work has already started on several pilot projects to look at transforming both content and process, for example our online complaints form. Over the next few months we will be developing detailed plans for the next phases of delivery, which will include the launch of our new website in Q3 2017. The Performance and Resources Board will consider these plans at its meeting on 1 March 2017.

b Noted an update on Fitness to Practise provisional enquiries. In certain cases where a doctors’ fitness to practise is called into question, we are able to open an initial, ‘provisional enquiry’ to determine whether a full investigation is necessary. Our target to conclude a provisional enquiry cases is 63 days - cases of this nature in our standard investigation process typically take between 183-234 days. In July 2016, we launched a pilot to extend provisional enquiries to cases where doctors are alleged to have made a one-off mistake involving poor clinical care (Single Clinical Incidents – SCIs). A full review of this extended pilot will be concluded next year when sufficient numbers of complaints have been through the process but early indications are that these complaints are often made to us about incidents that happened very recently. This can mean that the Responsible Officer (RO) is often either not aware or has received notification at the same time as the GMC leading to either extended timeframes for evidence gathering and/or the promotion to full investigation where we cannot assure ourselves about

http://www.ukmed.ac.uk/

http://www.sitecore.net/en-gb

http://mando.agency/


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the doctor’s reflection and insight / any steps taken to avoid recurrence. We continue to monitor the pilot and will return to PRB and Council with the results next year.

The Board also discussed the 2017 plan to pilot an approach to single clinical concerns (SCCs) – where there is more than one incident but a single doctor, single patient and single course of treatment. We will report back to Council in due course on the progress of these provisional enquiries pilots.

Other operational matters arising

MPTS Operational Framework

11 The annual review of the MPTS Operational Framework has now been completed. The GMC/MPTS Liaison Group reviewed and agreed amendments to the Framework at its meeting on 5 December 2016 that reflect changes in GMC and MPTS ways of working over the course of 2016 and which add clarity around the role of the GMC’s executive boards in relation to the MPTS and the statutory committee. The Framework is being finalised to reflect the agreed changes and this will bring the document up-to-date as of 1 January 2017. The Liaison Group also agreed to change the timing of the review from annual to biennial.

Revised Professional and Linguistic Assessments Board (PLAB) test launched

12 The independent PLAB Review* was published by the GMC in September 2014 and included a range of recommendations for enhancing and updating the PLAB assessment. Following the review, a project group was established and we have now delivered 22 of the 23 recommendations. The recommendations included increasing the reliability of the Part 2 exam; extending the scope of the test to include wider ethical and professional values and principles; and providing more meaningful feedback to candidates. The one recommendation not implemented was a change of name to the PLAB test due to the development of the medical licensing assessment.

13 On 7 September 2016 the first candidates took the new PLAB 2 exam and the administration of the assessment went well with initial data suggesting that the new format is robust and highly reliable. Similarly, on 14 September 2016 the first group of candidates also undertook the revised version of the PLAB 1 written assessment which been amended to include new questions on professionalism and ethics. Candidates also receive enhanced feedback on their performance in the exam.

* PLAB is a two part exam taken by international medical graduates who want to apply for registration with a licence to practise. For more information see www.gmc-uk.org/doctors/plab.asp

http://www.gmc-uk.org/PLAB_review_final.pdf_57946943.pdf

http://www.gmc-uk.org/doctors/plab.asp

M4 - Annex A Council Priority Report

Data accurate as of 16 November 2016

M4 – Chief Operating Officer’s Report


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Council Priorities Previous Period

Current period

Delivery Risk

Trend

Next period

1 Implementation of the Change Programme All items on track: Accommodation and extension of new ways of working;

Pensions; People – Redundancy, recruitment, knowledge transfer; GMC Services. G G G

2 Taking forward legislative reform / the legislative programme arising from the Law Commissions’ report

All items on track: S60 Reforms; ISG Phase 3; Legislative Reform - Engage and influence key stakeholders to press for alternate routes for legislative reform including Section 60 Orders. G G G

3 Understand the context in which doctors practise

All items on track: Promoting Professionalism event programme in 2016; Hold Regional KIG Dinners in England in 2016; Organise and host UKAF meetings in Northern Ireland / Wales / Scotland; Implementation of Confidentiality Project; Standards App (now green due to decrease in overspend) R G G

4 Medical Licensing Assessment All items on track or complete: Medical Licensing Assessment; Implement

PLAB review (complete). G G G

5 Revalidation review

Most items on track: Revalidation operations; Evaluation of Revalidation; Skills & competency testing for doctors without a prescribed connection; Review of revalidation (the revised delivery date means the current period has a red rating). G R G

6 Respond to the Shape of Training review All items on track: Credentialing; Generic Professional Capabilities. G G G

7 Fairness and proportionality

All items on track: Interim Orders Tribunal Research (now reporting as green from amber due to resource being secured); Deliver the E&D strategy 2014-17; Differential Attainment – Research; Standards for Curricula and Assessment. A G G

8 Supporting doctors, patients and relatives involved in fitness to practise investigations

All items on track or complete: Monitor & TDA Information Sharing; Vulnerable Doctors project; Whistleblowing (formerly Hooper report) (complete). G G G

9 Communications strategy and engagement All items on track: Communications and Engagement Work 2016; Board

Engagement through 2016; Digital media strategy. G G G

10 Develop the Register and deliver Data Strategy Phase 2

Most items on track: DS1 Unstructured qualitative data; DS2 Common & core dashboard development; DS3 Sharing GMC data externally; DS4 Organisational approach to key data capture; LRMP development (reporting as amber due to resource) R G G

11 Speeding up fitness to practise procedures All items on track: FtP Operations; Provisional Enquiries roll-out / further

piloting. G G G


A1


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Key to RAG ratings

Progress

Cost

Resource

Overall RAG status

Green - Project on track compared with initial time scales Amber - Change to project time scales but without overall change to end deadline Red - Change to overall end deadline Complete / cancelled

Green - Project cost within 5% tolerance of original cost Amber – Project cost is under / over spending by between 5% - 10% Red – Project cost is under / over spending by more than 10% Complete / cancelled

Green – Relevant skillsets and FTE resource secured to deliver the project Amber – Relevant skillsets and FTE resource are not secured / being secured but this will not impact on the project delivery overall Red – Relevant skillsets and FTE resource are not secured / being secured but this will impact on the project delivery overall Complete / cancelled

Green – 3 greens or 2 greens + 1 amber Amber – 3 ambers or 1 green + 2 ambers Red – Any combination with a red for the progress or resource RAG or the cost RAG has an overspend of £50k or more Complete / cancelled

As part of continuous improvements to our reporting processes, we have recently made a change to the way we report on costs for projects. The usual criteria for reporting on project costs remain in place (as above) with a slight change to the reporting of overall status: • Where there is an overspend of £50k or more, this will change the overall RAG status to red. In addition, all Council priority and Change Programme projects will now be re-forecast on a monthly basis instead of quarterly. This approach will allow us to report more accurately on project costs, while highlighting only those areas which need genuine attention - a more proportionate and risk-based approach.



A2

Operational KPIs



# Area BAU Operational KPIs [monthly] Aug Sep Oct RAG for

Next period

Commentary

1 R&R Decision on 95% of all registration applications within 3 months 98 98 100 G On track

2 R&R Decision on 95% of all revalidation recommendations within 5 days 97 98 96 G On track

3 R&R 90% of calls answered within 15 seconds 93 95 95 G On track

4 E&S Respond to 90% of ethical/standards enquiries within 21 working days 94 92 100 G On track

5 E&S 80% of enhanced monitoring concerns where action plan is being adhered to 98 98 92 G On track

6 E&S 90% of visits completed in within agreed timescales 100 100 100 G On track

7 FtP Conclude 90% of fitness to practise cases within 12 months 92 91 93 G On track

8 FtP Conclude or refer 90% of cases at investigation stage within 6 months 94 93 93 G On track

9 FtP Conclude or refer 95% of cases at the investigation stage within 12 months 95 95 97 G On track

10 FtP Commence 100% of IC hearings within two months of referral 100 100 100 G On track

11 MPTS Commence 90% of tribunal hearings within nine months of referral 93 100 100 G On track

12 MPTS Commence 100% of IOP hearings within 3 weeks of referral 100 100 100 G On track

13 R&QA Rolling twelve month staff turnover within 8-15% 11.55 11.08 10.09 G On track

14 R&QA 2015/16 Income and expenditure [% variance] 5.59 5.42 5.16 R

At the end of October income was £200k higher than expectations. Demand for PLAB tests has been higher than expected, registration fees (mainly EEA and IMG) and CCT applications have been higher than expected, partially offset by lower investment income and slightly lower ARF fees (due to natural variations in the timing of doctors joining and leaving the register). Expenditure was £4,290k lower than budget. Headcount was under budget in the first half of the year due to normal staff turnover and, in some cases, challenges in recruiting suitable replacement staff. Savings have been generated in MPTS linked to the section 60 implementation, and in FTP on legal reports, performance assessor training and external legal costs. In overall terms there is a surplus of £5,770k at the end of October against a budgeted surplus of £1,280k, which is a favourable variance for the GMC.

15 R&QA IS system availability [%] 100 100 100 G On track

16 S&C Monthly media score 68 474 411 N/A



A4

# Area BAU Operational KPIs [monthly] Aug Sep Oct Next period Commentary

17 S&C Doctors and medical students surveyed who said they would change their practice as a result of attending a RLS or DO event [%] Q3: 70% Quarterly figure.

18 OCCE Respond to x% of corporate complaints within 10 working days N/A N/A N/A N/A Threshold for KPI still to be determined as part of the ISO implementation process – work ongoing in 2016 but will be reported to Council when completed.



A5

# Area BAU Operational KPI [Annual] Previous period

Current period Commentary

19 S&C Percentage of policy influencing partners who agreed their engagement with us during 2016 had positive influence on their impression of the GMC as an organisation and a positive effect on their work and the work of their organisation.

92.3%1 90.9%2

In 2016, we surveyed a greater number of influencing partners than in 2015 (65 compared to 63 in 2015), which could account for percentage decrease this year. The list of top influencing partners who we asked to complete the survey also differed from the previous year.

20 S&C Level of confidence in the GMC’s regulation of doctors (from biennial tracking survey) 79%3 N/A Biennial figure not available until later in the year.

21 R&QA Staff engagement score³ 78% Annual score

22 S&C Award in Employers Network on Equality and Inclusion (annual) Silver Award Silver Award N/A

23 S&C Inclusion in Stonewall Equality Index as ‘Top 250 Employer’ (annual) N/a 285

We achieved 285th place out of 415 organisations. Stonewall’s feedback was that organisations taking part in the index for the first time would usually place within the top 300. We did well in a number of areas, including: 1. Having policies in place to ensure that LGBT staff are treated fairly. 2. Collecting equality data on LGB staff. 3. Engaging with the wider LGBT community, for example, through our participation in PRIDE and work with the Gay and Lesbian Association of Doctors and Dentists (GLADD).

Business As Usual – Operational KPIs (annual / biennial)

1. This percentage is based on a 41.26% response rate to the annual survey that went to our top 63 policy influencing partners as identified by our external relations teams; European and International Affairs, the Devolved Offices and UK Government, Parliament and Stakeholder Relationships teams.

2. The percentages for the current 2016 period are based on a 50.7% response rate to the annual survey that went to our top 65 policy influencing partners as identified by our external relations teams: the Devolved Offices, European and International Affairs, and the UK Government, Parliament & Stakeholder Relations teams. 2. 79% of patients/public who had heard of the GMC are confident in its regulation of doctors

3. Staff engagement will be reported once per year as and when staff survey results are analysed



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Detailed Appendix

Data accurate as of 16 November 2016



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1) Implementation of the Change Programme Overall Priority Status

Previous Period

Current Period Trend Next period

G G G

Linked Strategic Aim(s)

• Strategic aim 5: Work better together to improve our overall effectiveness, our responsiveness and the delivery of our regulatory functions.

Delivery Activities

Last Current Forecast

Iain McMillan

Project

BAU

Overall status last report

Progress Cost Resource Overall

Status Trend Forecast overall status

GMC Services G G G A G G

Summary comments

Significant interest from the market and progressing well on plans. Additional external advice being taken to ensure the optimal delivery mode. Appropriate resources currently being identified to fit within the financial envelope of the budget.



A8

10


Previous Period


G G G



Delivery Activities

Last Current Forecast

Andrew Bratt

Project

BAU




Pensions G G G G G G

Summary comments

The consultation period ended on 31 March 2016 (commenced 18 January 2016). Following feedback from the consultation process and advice from advisers, a number of recommendations were presented to Council on 7 June 2016 and the pension scheme trustees on 21 June 2016. Both parties have agreed to the pension reform proposals. Work on the legal aspects of the change programme is now well underway, and this involves updating the Trust Deed and Rules for the pension scheme and revised contract of employments. Work on the Trust Deed and Rules is now advanced and in final stages. The revised Trust Deed and Rules will be presented to Trustees on 29 November 2016 and a copy will be made available to the employer. Notice of changes to contract of employments have been issued to all members of the scheme. Some members were content to have the changes documented in a letter only – this has been completed. Others have requested a revised contract of employment and it is intended that these will be issued in the next few weeks. Amendments to internal and external IS software is also required and the parties involved have been notified. Work on Agresso has been discussed and testing has commenced and no major problems are anticipated.



A9

11


Previous Period


G G G



Delivery Activities

Progress Last Current Forecast

Andrew Bratt

Project

BAU




People: Redundancy, recruitment, knowledge transfer G G G G G G

Summary comments

Our recruitment is progressing very well and is on schedule. There are 38 staff where notice has been served or notice is pending within the change programme. We have 61 staff where redundancy has taken place. 59 staff have started access to Penna. 22 staff have resigned from the at risk group, no redundancy payment required (no change). 11 staff have been redeployed (increased from September). 11 staff have relocated/relocating to Manchester (increased from September). 116 posts have been filled (85% of change programme recruitment). Currently we have 8 posts live. We have 9 post yet to go live. All transition leads are managing their activities in line with their transition plans and all provided positive updates at the Transition Lead meeting in October 2016.



A10

12


Previous Period


G G G



Delivery Activities


Steve Jones

Project

BAU




Accommodation and extension of new ways of working

G G A G G G

Summary comments

Manchester changes: The desk re-stack is progressing well; 19 out of 20 phases of furniture reconfiguration work has been completed with approx. 580 desks being changed and

associated equipment tested. The fit out work continues; seven construction phases out of 14 have been completed and a further five are progressing well. Nine meeting rooms with

equipment have been completed with some offices removed and replaced with additional seating. All construction phases are complete on the 2nd floor. Touchdown spaces have been installed on 2nd and 3rd floors. Soft furnishing for break out areas has started to be installed. London changes: The fit out work has started with four of the seven phases underway. The majority of staff have been relocated to the 1st floor while this work is taking place.

Finance – forecast variance value - £160,991 underspend, forecast variance - 5.43%, Finance status – Amber, Overall status – Green

Click to go back to main table M4 – Chief Operating Officer’s Report


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13

2) Taking forward legislative reform/the legislative programme arising from the Law Commissions’ report

Overall Priority Status

Previous Period


G G G


• Strategic Aim 3: Improve the level of engagement and efficiency in the handling of complaints and concerns about patient safety. • Strategic Aim 5: Work better together to improve our overall effectiveness, our responsiveness and the delivery of our regulatory

functions.

Delivery Activities


Anthony Omo

Project

BAU




S60 Reforms G G G G G G

Summary comments

The final audit review report for the S60 implementation is still pending. The draft report shows that there are no resulting actions for Fitness to Practise. For MPTS, we are waiting for the final version of audit review report to be signed off before undertaking any action. The draft report shows two actions identified for MPTS. The actions are to review the current processing targets for the Interim Orders Tribunal reviews on paper to ensure they remain relevant, and to consider other benefits of implementing all S60 changes.


Anthony Omo

Project

BAU




ISG Phase 3 G G G G G G

Summary comments

This is a project to explore the benefits of the organisation facilitating meetings between doctors and patients in cases where the patient has suffered serious harm. It is anticipated that such meetings would complement our existing complaint handling procedures rather than being an alternative to an existing sanction. Scoping and desk research for the project were continued by the supporting policy officer in October. Engagement sessions were held on 25 October 2016 and 3 November 2016 to gather the views of teams across the directorate. These will be used to help create two possible models (straw men) for consideration by the Assistant Director of policy, business transformation and safeguarding, alongside the scoping paper highlighting the relevant policy issues.



A12

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2) Taking forward legislative reform/the legislative programme arising from the Law Commissions’ report


Previous Period


G G G


• Strategic Aim 3: Improve the level of engagement and efficiency in the handling of complaints and concerns about patient safety. • Strategic Aim 5: Work better together to improve our overall effectiveness, our responsiveness and the delivery of our regulatory

functions.

Delivery Activities


Paul Buckley

Project

BAU




Legislative reform G G G G G G

Summary comments

Department of Health (England) (DH(E)) Consultation: We are meeting with other regulators to discuss cross-regulator policy positions, bill handling etc. DH(E) have shared two drafts of their consultation document and we have provided feedback. Section 60 orders : We are scheduled to meet with DH(E) officials on 14 December 2016 to discuss issues arising from policy instructions we sent earlier this year. We continue to highlight the need for legislative change for the Medical licensing assessment and Brexit. A decision has been taken to focus our influence on the above consultation at present.



A13

15

3) Understand the context in which doctors practise


Previous Period


R G G


• Strategic aim 2: Help raise standards in medical education and practice.

Delivery Activities


Paul Buckley

Project

BAU




Promoting Professionalism event programme in 2016

G G G G G G

Summary comments

The Medical Professionalism Matters report is in draft and design stage, and we have had initial sign off of direction from the advisory group. A workshop is in development for the conference. The evaluation of the project so far is due to be completed by the end of year.


Paul Buckley

Project

BAU




Hold Regional KIG Dinners in England in 2016 G G G G G G

Summary comments

The next seminar is scheduled for 7 December 2016 in London. As of October, we’ve currently had eight acceptances and the second wave of invitations are about to go out. We are in the process of booking the dinner venue.



A14

16



Previous Period


R G G



Delivery Activities


Paul Buckley

Project

BAU




Organise and host UKAF meetings G G G G G G

Summary comments

All UK Advisory Forum meetings have now been delivered with a wash up meeting arranged for mid November. The report has been submitted to Strategy and Policy board for the meeting on 1 December 2016.


Judith Hulf

Project

BAU




Confidentiality project G G G G G G

Summary comments

Papers have been prepared for Council’s closed session on 9 November 2016. A communications plan and core script have been prepared for launch. And re-circulated revised gunshot and knife wounds explanatory guidance to the police and the Royal College of Emergency medicine for comment.



A15

17



Previous Period


R G G



Delivery Activities


Judith Hulf

Project

BAU




Standards App R G R G G G

Summary comments

The project team have spent the past couple of months refining and improving the display of the content on the app. This has involved identifying various bespoke solutions to a number of issues affecting how our guidance is structured and published on the website. This future proofing approach will be shared with colleagues around the business, and has already been successfully applied to the new Confidentiality guidance due to be launched next year. The project was reported as red last month due to a £50,942 overspend, and is now overall green due to the decrease in overspend. Finance – forecast variance value - £29,174 overspend, forecast variance - 34.32%, Finance status – Red, Overall status – Green To note: Project has been financed over two GMC fiscal years - the project cost over those years has been delivered to the original budget.



A16

18

4) Medical Licensing Assessment Overall Priority Status

Previous Period


G G G



Delivery Activities


Judith Hulf

Project

BAU




Medical Licensing Assessment G G R G G G

Summary comments

The Medical Licensing Assessment project continues to progress well. In October we held a successful first meeting of our Expert Reference Group and also a workshop on revising the outcomes for graduates. Council considered a revision of the draft consultation document by email circulation in October. Consultation planning is under way. The Steering Group agreed to the creation of a Programme Board to replace the Steering Group and Executive Board. On schedule to start consultation by year-end. Finance – forecast variance value - £143,375 underspend, forecast variance - 28.70%, Finance status – Red, Overall status – Green


Una Lane

Project

BAU




Implement PLAB review G C C C C

- -

Summary comments

The implementation of the project has been delivered on time in September 2016, with the launch of the updated Part 1 exam and the newly developed Part 2 exam. A post implementation review is planned for 2017.



A17

19

5) Revalidation review Overall Priority Status

Previous Period


G R G


• Strategic aim 2: Help raise standards in medical education and practice

Delivery Activities


Una Lane

Project

BAU




Evaluation of revalidation G G G G G G

Summary comments

We are working with UMbRELLA to agree the questions for the targeted surveys (to locums, SAS doctors, doctors working in the independent sector, and doctors without a connection). We will be finalising the arrangements for these surveys during November. UMbRELLA updated us on the next phases of work; a third interim report is due from January 2017. UMbRELLA, and we, anticipate that this will be a progress report rather than one containing substantive findings (which will be contained in the final report due in early 2018).


Una Lane

Project

BAU




Revalidation operations G G G G G G

Summary comments

The team continue to meet their published SLAs. The overall number of revalidation recommendations received has decreased, but this is expected and due to how doctors were scheduled for revalidation. However, there is a higher proportion of recommendations requiring manual intervention which take longer to process. The team has made adjustments to their operational processes to make sure they continue to meet the SLA. We continue to make decisions to withdraw licences where doctors have failed to engage with revalidation. We have now withdrawn the first licences from doctors who have failed to undergo the revalidation assessment. A small number of doctors have appealed this decision.



A18

20


Previous Period


G R G



Delivery Activities


Una Lane

Project

BAU




Skills & competency testing for doctors without a prescribed connection

G G G G G G

Summary comments

As of 31 October 2016: We have issued 857 notices to doctors to sit the assessment. Number of doctors who have sat the assessment - 39 Number of doctors who have met the required standard - 30 Number of doctors who have not met the required standard - 9 Number of doctors awaiting results - 0 Number of assessments booked but not yet sat - 45 All doctors who are required to sit the assessment with a revalidation date in 2016 have now received their notices. We are now looking to move to a business as usual process when inviting doctors for the assessment by the end of the year. The October Strategy and Policy Board signed off amendments to the Guide for doctors to the Licence to Practise regulations, which included a change to the guidance for doctors who do not meet the required standard in the assessment. This amendment has been made following legal advice that there is the option for us to initiate licence withdrawal if the doctor does not meet the required standard. We will develop further guidance outlining how and when we will exercise this discretion. The amended Guide for doctors has now been published on our website.



A19

http://www.gmc-uk.org/Revalidation_guidance_for_doctors.pdf_54232703.pdf

21


Previous Period


G R G



Delivery Activities


Una Lane

Project

BAU




Review of Revalidation G R G G R G

Summary comments

Sir Keith Pearson has now met with Terence Stephenson and Niall Dickson to review the draft report. He will also meet with Charlie Massey on 4 November 2016. Following this, the draft report will be presented to Council at their closed session on 9 November 2016 for review. The final report will be received by Council at its public session on 14 December 2016. We have revised the publication date of the report from December 2016 to mid January 2017. This is to make sure there is sufficient time to engage with key stakeholders before the publication, taking into account the holiday period post December Council. The overall status will return to green as this timeframe change has been agreed at the Performance and Resources Board Sir Keith has scheduled brief calls with key stakeholders in November to provide them with the headline messages from his review, and during January 2017 he will formally brief key stakeholders on the report having shared it with them in advance. It is intended that, following his briefing, there will be an opportunity for the GMC and stakeholders to discuss their respective responses to the recommendations and consider how to work together to implement them. We will be holding a press briefing prior to publication of the report.



A20

22

6) Respond to Shape of Training review Overall Priority Status

Previous Period


G G G



Delivery Activities


Judith Hulf

Project

BAU




Credentialing G G G G G G

Summary comments

It has been agreed that the project will be taken forward with an evaluation phase taking six to nine months, with a view to setting up an internal working group. Project support has been established and we plan to set up a working group in the next month as well as start to plan out the next phase of activities. A business case has now been developed.


Judith Hulf

Project

BAU




Generic Professional Capabilities G G G G G G

Summary comments

Academy co-chair and sub-group leads held discussions and prepared papers on areas of content for the handbook - curriculum, assessment, trainer support, communication strategy - for the November working group meeting.



A21

23

7) Fairness and proportionality Overall Priority Status

Previous Period


A G G


• Strategic aim 1: Make the best use of intelligence about doctors and the healthcare environment to ensure good standards and identify risks to patients.

Delivery Activities


Paul Buckley

Project

BAU




Interim Orders Tribunal Research A G G G G G

Summary comments

We have now secured the necessary resource to complete the redaction of the documents that will be provided to the researchers. There are no further delays identified and , provided the redaction resource becomes available when anticipated, the activity should now progress as planned.


Paul Buckley

Project

BAU




Deliver E&D Strategy 2014 - 17 G G G G G G

Summary comments

Next meeting of the programme board is scheduled for 5 December 2016 and they will consider the quarterly progress update. The Black and Minority Ethnic forum met on 8 November 2016.



A22

24

7) Fairness and proportionality Overall Priority Status

Previous Period


A G G


• Strategic aim 1: Make the best use of intelligence about doctors and the healthcare environment to ensure good standards and identify risks to patients

• Strategic Aim 2: Help raise standards in medical education and practice

Delivery Activities


Judith Hulf

Project

BAU




Differential Attainment - Research G G G G G G

Summary comments

Initial draft data packs (collating local equality and diversity data) are being developed and discussions are underway with deaneries/Local Education and Training Boards who will pilot these. The additional research timelines have been agreed and the focus group with Royal Colleges will take place in November 2016.




Judith Hulf

Project

BAU




Standards for Curricula and Assessment G G R G G G

Summary comments

Consultation on draft standards closed on 28 October 2016, with 69 responses including 20 from college/faculty bodies. Report on expert consultancy advice was sent back for final changes before publication. Second draft of assessment guidance was developed and will be shared externally for further review, development and engagement in November and December. Discussions about processes and implementation are ongoing with operational teams. Finance – forecast variance value - £8,869 underspend, forecast variance - 50.42%, Finance status – Red, Overall status – Green

A23

25

8) Supporting doctors, patients and relatives involved in fitness to practise investigations


Previous Period


G G G


• Strategic Aim 2: Help raise standards in medical education and practice • Strategic Aim 3: Improve the level of engagement and efficiency in the handling of complaints and concerns about patient safety. • Strategic Aim 5: Work better together to improve our overall effectiveness, our responsiveness and the delivery of our regulatory

functions

Delivery Activities


Anthony Omo

Project

BAU




Monitor & TDA Information Sharing G A G G G G

Summary comments

The Trust Development Authority and Monitor (now known as NHS Improvement) are working together to come to an agreed approach on information sharing following their merger. Once this agreement has been reached, we will be able to build our process to understand when to share and receive information with them. We are hopeful of having an agreed approach from them by the end of 2016.


Anthony Omo

Project

BAU




Vulnerable Doctors G G G G G G

Summary comments

Training for all Fitness to Practise (FTP) staff will start to be delivered in November 2016, and will continue to early 2017. Phase 2 (creation/implementation of specialist team in FtP) to be delivered by July 2017 - Phase 3 (operationalising the complex processes and system changes) by December 2017.



A24

26

8) Supporting doctors, patients and relatives involved in fitness to practise investigations


Previous Period


G G G


• Strategic Aim 2: Help raise standards in medical education and practice • Strategic Aim 3: Improve the level of engagement and efficiency in the handling of complaints and concerns about patient safety. • Strategic Aim 5: Work better together to improve our overall effectiveness, our responsiveness and the delivery of our regulatory

functions

Delivery Activities


Anthony Omo

Project

BAU




Whistleblowing G C C C C

-

-

Summary comments

The project to launch the Fitness to Practise whistleblowing process following the review by Anthony Hooper is now complete and being piloted. We will continue to monitor these cases to establish an end point for the pilot. Once the pilot has completed, we will carry out an evaluation.



A25

27

9) Communications strategy and engagement Overall Priority Status

Previous Period


G G G


• Strategic aim 4: Work more closely with doctors, medical students and patients on the frontline of care

Delivery Activities


Paul Buckley

Project

BAU




Comms & Engagement work 2016 G G G G G G

Summary comments

We are drafting a statement to publish on the website around our Public and Patient Involvement work. It's been decided to focus on three key audiences for the audience plans as an initial pilot of this work. We will have completed 3 additional strategic audience plans by the end of 2017 (patients and the public, doctors in training and medical students). The strategic plan for Responsible Officers has been completed following a successful pilot earlier in 2016


Paul Buckley

Project

BAU




Board engagement through 2016 G G G G G G

Summary comments Project board have signed off the review document and it will be included as an annex when the Communications & Engagement strategy reports on progress.



A26

28

9) Communications strategy and engagement Overall Priority Status

Previous Period


G G G


• Strategic aim 4: Work more closely with doctors, medical students and patients on the frontline of care

Delivery Activities


Paul Buckley

Project

BAU




Digital Media Strategy G G R G G G

Summary comments

Opened an Invitation to Tender (ITT) for a partner to support on content pilot programmes and development, developing our supporting principles and embedding the strategy through internal communications. A supplier is expected to be appointed in November. Six priority content project pilots were identified to which we could apply our new content principles. Work with IS to plan the workplan for 2017 commenced. Handover to the new Marketing Communications team will be complete by November. The planned work for 2016 is progressing and we are now in a position to look ahead in partnership with IS to agree activities for 2017. Finance forecast variance will be brought back on track following the appointment of a supporting delivery partner in November. Finance – forecast variance value - £60,000 underspend, forecast variance - 100%, Finance status – Red, Overall status – Green



A27

29

10) Develop the Register and deliver Data Strategy Phase 2


Previous Period


R G G



Delivery Activities


Paul Buckley

Project

BAU




DS 1. Unstructured qualitative data G G R G G G

Summary comments

The Regional Liaison Service (RLS) have an agreed a business process to record intelligence, and have begun to pilot this. The Central Analytics team are reviewing options for evaluation in early 2017. Finance – forecast variance value - £30,905 underspend, forecast variance - 22.60%, Finance status – Red, Overall status – Green


Paul Buckley

Project

BAU




DS 2. Common & core dashboard development G G R G G G

Summary comments

We have responded to the Care Quality Commission (CQC) Q3 information request for their inspection using an extract of the Organisation dashboard. We are working with the CQC to agree the format and mechanism for sharing the full extract of data in future. In parallel, we are working towards developing an extract/dashboard to share with Responsible Officers and Employer Liaison Advisers (ELA) so they have oversight of the information being shared. Finance – forecast variance value - £30,905 underspend, forecast variance - 22.60%, Finance status – Red, Overall status – Green



A28

30



Previous Period


R G G



Delivery Activities


Paul Buckley

Project

BAU




DS 3. Sharing GMC data externally G G R G G G

Summary comments

We are sharing GMC data externally through the organisation dashboard extract now. We are liaising with the systems regulators on how best to share this data with them. PRB have agreed to delay a decision on the external release of Agora until the end of Q1 2017. However, we have met the wider objective of sharing GMC data externally through the extract of the organisation dashboard. Finance – forecast variance value - £30,905 underspend, forecast variance - 22.60%, Finance status – Red, Overall status – Green


Paul Buckley

Project

BAU




DS 4. Organisational approach to key data capture

G G R G G G

Summary comments

This workstream has been put on hold until the Central Analytics Team is in place. All previous agreed work will be completed, however no new agreements will be made at this time. Finance – forecast variance value - £30,905 underspend, forecast variance - 22.60%, Finance status – Red, Overall status – Green



A29

31



Previous Period


R G G



Delivery Activities


Paul Buckley

Project

BAU




LRMP development R G G A G A

Summary comments

The consultation period ended on 7 October 2016 (commenced on 5 July 2016). Although the project is currently on track, we have received a significant amount of responses already to the consultation, in excess of 7,000. This will result in a significant challenge in terms of analysis and reporting to Council in December. Which is why we have decided to extend the deadline of the project and will report on key themes from the consultation in December, with a further full update and final analysis report in the new year. We have now secured resource to deliver the interim report to Council in December, but will need further resource to help with the analysis of the consultation. We still have a tight deadline to deliver a full report in February 2017 due to the large volume of responses.



A30

32

11) Speeding up fitness to practise procedures


Previous Period


G G G


• Strategic Aim 3: Improve the level of engagement and efficiency in the handling of complaints and concerns about patient safety.

Delivery Activities


Anthony Omo

Project

BAU




FtP Operations G G G G G G

Summary comments All FtP SLA’s were met.


Anthony Omo

Project

BAU




Provisional Enquiries roll out G G G G G

G

Summary comments

The pilot to expand our use of provisional enquiries has gone live. We are now in the monitoring phase, tracking the progress of these enquiries before a decision is taken to roll the process out as BAU. An interim evaluation looking at the progress of phase 1 of the pilot (Single Clinical Incidents) has now completed. As only a small number of enquiries have concluded to date, it was agreed that we should continue to pilot provisional enquiries for SCI's for an additional period of time to gain more experience of the pilot process before deciding whether to expand to SCC's (Single Clinical Concerns). It is likely that the pilot will be expanded early next year. The pilot's performance will be reported as a Corporate Priority project to the Performance and Resources Board.



A31

Council meeting 14 December 2016

Chief Operating Officer’s Report

M4 – Annex B

2016 Income and Expenditure

Revenue Budget

1 The income and revenue expenditure figures to the end of October 2016 are:

Operational financial Summary as at October 2016

Budget Jan - Oct

Actual Jan - Oct Variance

Budget Jan - Dec

Q3 Forecast Variance

£000 £000 £000 % £000 £000 £000 % Income Annual retention fees 78,552 78,209 (343) (0)% 94,787 94,105 (682) (1)% Registration fees 3,547 3,926 379 11% 3,817 4,163 346 9% PLAB fees 1,384 1,899 515 37% 1,796 2,393 597 33% Certification fees - CCT 2,213 2,394 181 8% 2,474 2,608 134 5% Certification fees - CESR/CEGPR 732 677 (55) (8)% 853 823 (30) (4)% Interest income 873 548 (325) (37)% 1,048 732 (316) (30)% Other income 911 759 (152) (17)% 1,370 975 (395) (29)%

Total Income 88,212 88,412 200 0% 106,145 105,799 (346) (0)% Expenditure by cost type Direct staffing costs 46,836 46,349 487 1% 56,326 55,871 455 1% Indirect staffing costs 2,904 2,269 635 22% 3,598 3,100 498 14% Office costs 4,882 4,064 818 17% 5,934 5,157 777 13% Accommodation costs 5,656 5,348 308 5% 6,847 6,608 239 3% Legal costs 4,285 4,038 247 6% 5,141 4,886 255 5% Professional fees 1,356 1,295 61 4% 1,748 1,888 (140) (8)% Council & members costs 429 388 41 10% 502 462 40 8% Panel & assessment costs 13,328 11,862 1,466 11% 15,999 14,371 1,628 10% Depreciation 6,195 5,998 197 3% 7,575 7,263 312 4% New Initiatives Fund 145 145 0 0% 250 209 41 16% PSA Levy 612 583 29 5% 736 698 38 5% Consultancy 35 35 0 0% 700 83 617 88% Pension payment 0 0 0 0% 0 2,400 (2,400) 100% UKMLA 269 268 1 0% 500 356 144 29% Unallocated efficiency savings 0 0 0 0% (45) 0 (45) 100% Total Expenditure 86,932 82,642 4,290 5% 105,811 103,352 2,459 2% Surplus/deficit 1,280 5,770 4,490 334 2,447 2,113

Council meeting 14 December 2016 M4 – Chief Operating Officer’s report

A2

2 There is a surplus at the end of October of £5,770k, compared to a budgeted surplus for the period of £1,280k. Income is currently in line with budget and expenditure is 5% under budget.

Principal variances – operational income and expenditure

3 Annual Retention Fee income is marginally under budget, reflecting normal variations in the timing of doctors joining and leaving the register compared to our budget assumptions.

4 Professional Linguistic Assessments Board (PLAB) income is higher than budgeted as

we held two additional PLAB 2 test days in January and June and three additional days in July due to high demand and we expect this to continue in the remainder of the year. There has also been an increase in demand for PLAB 1 tests. Income from new International Medical Graduates (IMG) registrations is higher than budget, most likely linked to the additional PLAB 2 tests earlier in the year. There has also been an increase in European Economic Area (EEA) applications.

5 Certificates of Completion of Training (CCT) volumes are currently higher than

budgeted and we expect that the additional income will continue to the end of 2016.

6 Interest income is under budget due to the delay in placing funds under management. 7 Direct staffing costs are forecast to move closer to budget in the remainder of the

year. Recruitment costs are forecast to increase in the remainder of the year, and staff training costs are expected to move closer to budget by the end of the year. Staff travel is forecast to remain under budget.

8 Within office costs, savings on stationery (following the contract retender) and IT support contracts are expected to continue throughout the year. Savings are also being made in Fitness to Practise through the greater use of e-communications. Project costs in Strategy & Communication are expected to move closer to budget by the end of the year.

9 Accommodation costs are under budget as successful rent negotiations on Hardman Street result in an ongoing financial benefit. Spending on hearing security and general maintenance costs are also lower than budgeted to date. We have also successfully applied for charity rate relief on car parking spaces at Hardman Street and St James’ Building.

10 Legal costs are lower than budget as more work, particularly Rule 12, has been handled by the in-house legal team rather than external lawyers. We are also currently under budget on barristers’ fees - these can vary significantly depending on the mix and complexity of cases and we have made a prudent forecast that costs will move closer to budget over the reminder of the year.


A3

11 Panel & assessment costs are under budget as Fitness to Practise have had a drive to reduce the volume of legal reports, and the volume of performance assessments is forecast to be lower than budgeted. MPTS hearing costs are forecast to be over budget by 123 days due to an increase in the average hearing length. This is offset by savings on Legally Qualified Chairs work, reduced transcription costs and a reduction in the average expenses claimed by associates.

12 Depreciation is slightly under budget due a difference between the forecast and actual capital spend in 2015, which has implications for 2016 depreciation charges.

13 The Professional Standards Authority levy is confirmed and is slightly lower than expected.

14 Efficiency targets are held on a separate line initially and then reallocated to specific budget heads as projects are identified. Efficiency savings relating to the section 60 order have been incorporated in the MPTS budget. The target level of savings is forecast to be achieved.

15 The forecasts for the New Initiatives fund and the consultancy fund reflect the low level of bids received.

Capital expenditure

16 In addition to our revenue expenditure on day to day operational business, the GMC incurs capital expenditure on major projects and assets that will generate benefits over a number of years. The standard accounting treatment is to spread capital costs over the lifetime of the asset, rather than accounting for the whole cost in the year of acquisition. This is achieved through an annual depreciation charge to the revenue account.

17 Capital expenditure to the end of October 2016 is:

Capital Programme as at October 2016

Budget Jan - Oct


Budget Jan - Dec

Q3 Forecast Variance

£000 £000 £000 % £000 £000 £000 % IT projects 4,117 3,981 136 3% 5,415 5,415 0 0)% Accommodation projects 295 243 52 18% 585 585 0 0% Total 4,412 4,224 188 4% 6,000 6,000 0 0)%

18 Costs are forecast to be in line with budget.


A4

Change Programme

19 Costs and savings relating to the relocation of work to Manchester and the pension reforms are separated from the operational budget as a standalone programme:

Reform Programme summary as at October 2016

Budget Jan - Oct


Budget Jan - Dec

Rolling Forecast Variance

£000 £000 £000 % £000 £000 £000 % Pensions - Revenue costs 127 65 62 49%

150 150 0 0%

People - Revenue costs 2,265 1,583 682 30%

4,067 3,297 770 19% People - Savings (800) (1,419) 619

(1,440) (1,867) 427 30%

Accommodation - Revenue costs 493 448 45 9%

757 636 121 16% Accommodation - Capital costs 1,141 1,128 13 1%

2,210 2,170 40 2%

Revenue total 2,085 677 1,408 68%

3,534 2,216 1,318 37%

Capital total 1,141 1,128 13 1%

2,210 2,170 40 2%

Total 3,226 1,805 1,421 44% 5,744 4,386 1,358 24%

20 Pension costs to date relate to external advice on the reform of the pension scheme.

21 People revenue costs are currently under budget as the actual profile of redundancy and recruitment costs differs from our original budget assumptions. People savings have been achieved ahead of expectations as some at-risk staff left the GMC early, which also results in lower redundancy costs. Some dual running costs will move from 2016 to 2017, and some of the funds set aside as a contingency have been dropped from the forecast. Recruitment and training costs are also under budget.

22 Accommodation costs to date include lease advice, architects fees and the data centre relocation. Revenue costs are forecast to be under budget due to savings in ongoing data centre costs due to a change in approach, and capital costs are forecast to be in line with budget.

Summary

23 There is an operational surplus at the end of October of £5,770k compared to a budgeted surplus for the period of £1,280k. Our latest forecast to the end of the year is a surplus of £2,447k.



M4 – Annex C

Appeals and Judicial Reviews The table below provides a summary of appeals and judicial reviews as at 25 October 2016:

Open cases carried forward

since last report

New cases Concluded cases

Outstanding cases

s.40 (Practitioner) Appeals

16 8 6 18

s.40A (GMC) Appeals

3 1 0 4

PSA Appeals 1 0 0 1

Judicial Reviews

6 3 4 5

IOP/IOT Challenges

2 0 1 1

Explanation of concluded cases

1 Appeals:

a 4 appeals dismissed.

b 1 appeal withdrawn.

c 1 appeal struck out.

Council meeting, 14 December 2016 M4 – Chief Operating Officer’s Report

C2

2 Judicial Reviews:

a 1 permission refused.

b 1 dismissed (by consent).

c 1 successful (decision quashed).

d 1 struck out.

3 GMC Appeals – 1 new appeal issued; 4 outstanding in total.

4 PSA Appeals – no new appeals, 1 appeal outstanding.

5 IOP/IOT challenges – There have been no new IOT challenges since the last report.

Any new applications in the High Court challenging the imposition of interim orders since the last report with explanation; and total number of applications outstanding

Of the two outstanding IOT challenges, one dismissed, order maintained, and the other is currently awaiting a hearing date.

New referrals by PSA to the High Court under Section 29 since the last report with explanation, and any applications outstanding

There have been no new PSA referrals since the previous report.

Any other litigation of particular note

6 We continue to deal with a range of other litigation, including cases before the Employment Tribunal, the Employment Appeals Tribunal and the Supreme Court.

7 The table below provides a detailed breakdown of outstanding Doctor (s.40) appeals as of 25 October 2016.

No Case Decision appealed Current status

1 A Appeal against Medical Practitioners Tribunal decision.

Hearing listed for 12/01/2017.

2 Ab Appeal against Medical Practitioners Tribunal decision.

Awaiting hearing date.


C3


3 Ad Appeal against Medical Practitioners Tribunal Service

Appeal remitted to High Court following GMC’s successful appeal to Court of Appeal against previous High Court decision to allow appeal. Awaiting listing for disposal in the High Court.

4 Al-A Appeal against Medical Practitioners Tribunal decision.

Awaiting listing date.

5 Al Appeal against Medical Practitioners Tribunal decision.


6 B Appeal against Medical Practitioners Tribunal decision.


7 Ca Appeal against Medical Practitioners Tribunal Sanction.

Appeal has been stayed by the Court of Session pending the outcome of the Supreme Court Appeal in the case of HK v General Pharmaceutical Council which is listed for hearing at the Supreme Court on 10 November 2016

8 Cha Appeal against Medical Practitioners Tribunal decision.


9 Cho Appeal against Medical Practitioners Tribunal decision.

Hearing date vacated. Appeal stayed for an initial period of 3 months to determine whether the Appellant will be permitted to appeal to the Court of Appeal against the original conviction.

10 I Appeal against Medical Practitioners Tribunal decision.


11 M Appeal against Medical Practitioners Tribunal decision.



C4


12 N Appeal against Medical Practitioners Tribunal decision.


13 Od Appeal against Medical Practitioners Tribunal decision.


14 Om Appeal against Medical Practitioners Tribunal decision.


15 S Appeal against Medical Practitioners Tribunal determination.


16 Sh Appeal against Medical Practitioners Tribunal decision.

Hearing listed for 29/03/2017 for two days.

17 Sq Appeal against Medical Practitioners Tribunal decision.

Hearing took place 17-21/10/2017. Judgment to be handed down on 3/11/2016

18 V Appeal against Medical Practitioners Sanction.

Appeal remitted to High Court following GMC’s successful appeal to Court of Appeal against previous High Court decision to allow appeal. Awaiting listing for disposal hearing in the High Court.

8 The table below provides a detailed breakdown of outstanding GMC (s.40A) appeals as

of 1 September 2016.


1 J Appeal against Medical Practitioners Tribunal decision.

Hearing listed for 29-30/3/2017

2 C Appeal against Medical Practitioners Tribunal Service

Hearing listed for 9/3/2017

3 S Appeal against Medical Practitioners Tribunal Service



C5


4 N Appeal against Medical Practitioners Tribunal decision.


9 The table below provides a detailed breakdown of outstanding PSA (s.29) appeals as of 1 September 2016.


1 S Appeal against Medical Practitioners Tribunal decision.


10 The table below provides a detailed breakdown of outstanding Judicial Reviews as 25 October 2016.

No Case Claim Current status

1 AM Judicial Review to challenge GMC guidance of assisted suicide case

Hearing in the Court of Appeal was listed for 21 or 22 November 2016. The Appellant has, however, recently died. The claim will therefore be withdrawn by consent. Awaiting order confirming concluded.

2 B Judicial Review against the GMC’s decision not to grant restoration to the register.

Permission was granted by the Court of Appeal for the Dr to appeal against the previous dismissal of their claim by the High Court. The hearing before the Court of Appeal is listed to be heard on either 14 or 15 February 2017.

3 I Judicial Review to challenge the GMC’s decision to restore the doctor’s name to the register.

The GMC has filed its Acknowledgment of Service and a decision on permission is currently awaited.


C6

No Case Claim Current status

4 S Judicial Review of decision that the Dr does not benefit from EPS for the purpose of applying for registration under s.19 MA.


5 T Judicial Review to challenge the decision to impose a Warning on the Claimant’s registration.


Council seminar 14 December 2016


M4 – Annex D

Corporate Risk Register 1 Corporate risk register

2 Risk appetite statement

of 15

Inherent business risks and how we manage them

Like

lihoo

d

Impa

ct

Ass

essm

ent

Like

lihoo

d

Impa

ct

Ass

essm

ent

8

Del

iver

y pa

rtne

rs The flow of information between the GMC and other bodies who contribute to our overall impact in protecting patient safety is limited and harm is consequently caused to patients

P.BuckleyH

ighl

y lik

ely

Maj

or

Criti

cal

• GMC processes and systems have other relevant checks/controls

• Individual process controls exist around major interfaces

• Systems regulators: CQC; Healthcare Inspectorate Wales; Healthcare Improvement Scotland; Regulation & Quality Improvement: Deaneries and LETBs Medical Royal Colleges Public protection agencies NHS agencies / employers

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Strategy & Policy Board• Developing joint explanatory guidance with the Nursing and Midwifery Council on duty of candour (March 2015)

Internal Audit• Data Strategy Phase 1 (March 2015, green/amber)

-

9

Dat

a

Breach of the Data Protection Act (DPA) and/or Human Rights Act (HRA) may result in financial loss and/or reputational damage

N.Roberts

Hig

hly

likel

y

Maj

or

Criti

cal

• Certified to ISO 27001, IG Toolkit v.11 and the Payment Card Industry information security standard PCI

• Information Security Working Group oversees controls

• Security incident reporting process in place

• All staff have performance objective to promote information security supported by mandatory training programme

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Information Security Working Group

Internal Audit• BSI/ IS027001 review (September 2015)• Penetration testing (August 2015 - no rating)• BSI/ ISO27001 review (September 2014)

Other Assurance • Certified to ISO27001• Certified to payment card industry information standard toolkit• Annual information security risk assessment

-

12

Exte

rnal

env

ironm

ent

Our response to emerging risks is untimely or inappropriate creating a perception or ineffective performance

P.Buckley

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Understand and respond to political and health environment - skilled and resourced teams consider and manage developments in the external environment including: Strategic Regulation Policy (Horizon Scanning, Inquiries & Reviews); Relationships and Campaigns; Public Affairs; Media; and Intelligence Unit(s).

• Council membership, devolved offices, RLS, Patient Safety Intelligence Forum (PSIF), and Advisory Forums provide insight across all UK countries and inform our work programme.

• Engagement programme of Chair and Chief Executive

• Performance monitoring and reporting

• Risk management framework - escalations

• Research agenda

• Refresh of policy and process for handling Inquiries and Reviews (IROC)

• Post Implementation Review on the effectiveness of SIPG

• Quarterly UKAF meetings in the devolved countries

• JWIG, meeting of GMC colleagues who provide services within a country.Q

uite

like

ly

Mod

erat

e

Sign

ifica

nt

Council• Chief Exec report to each meeting covers the external environment & strategic engagements

Performance & Resources Board• Emerging risks in this environment considered at each meeting

Internal Audit• Risk maturity benchmarking effectiveness (January 2016, green)• Operational Risk Management (June 2015, green/amber)

Other Assurance • Professional Standards Authority (PSA) Performance Review 2014/15 Standards of good regulation met

Hyponatraemia inquiry due to report in 2017

ID Risk Controls in place to mitigate risk

Risk pre-controls

Fun

ctio

n /

Act

ivit

y

Owner

Strategic aim 1 - Making the best use of intelligence

CommentAssurance

Residual risk with controls in place

Council and/or Board Review

D2

Council meeting, 14 December 2016 M4 - Chief Operating Officer's Report

of 15


Like

lihoo

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Impa

ct

Ass

essm

ent

Like

lihoo

d

Impa

ct

Ass

essm

ent


Risk pre-controls

Fun

ctio

n /

Act

ivit

y

Owner CommentAssurance



21

Legi

slat

ion

Mandatory reporting on whistleblowing concerns: Due to delays in the government sharing draft legislative framework and guidance we are delayed in preparing for implementation which may result in there being insufficient time to work with the Government to ensure that the wording of the legislation is workable and ultimately in a failure to comply with a legal duty to produce an annual report on whistleblowing issues from April 2017. The delay in systems changes means data recording will not be available to cover the whole reporting period for the first 12 months the duty is effective, damaging public confidence.

A.Omo

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Cross-directorate project board established to prepare for the new legal duty

• Policy staff liaising with government officials to monitor delays in circulating amended draft regulations for comment

• Cross-directorate impacting completed

• Review of capacity of existing IS intelligence tools to meet anticipated requirement

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Council • Regular updates via COO report

Strategy & Policy Board • Update on response to the independent review of whistleblowing March 2016, update via circulation in June 2016

We are developing a documented process and procedures (April 2017)

• We are still waiting to receive draft guidance from (BEIS) to clarify requirements for system changes.

Next steps: • Prioritisation of IS resources to implement any system changes required to ensure legal compliance when the requirements are clear• Liaison with other regulators within health sector to establish a shared approach

22

Exte

rnal

env

ironm

ent

Continued stretched resources and finances in the health environment create the potential for increased patient safety incidents which could strategically impact the GMC’s role as the regulator upholding professional standards for doctors and trainees and create operational pressures on fitness to practise referrals and education monitoring services.

S.Goldsmith

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Monitoring and forecasting of Fitness to Practise case loads

• Monitoring of centre for workforce information re NHS staff shortages and skills gaps, and other external sources of quantitive and qualitative data, through horizon scanning (Central Analytics Team)

• Ongoing engagement with DH(E ), Health Education England, and other stakeholders

Unl

ikel

y

Mod

erat

e

Low

Council• Fitness to Practise performance against SLAs reported to each Council through the COO report

Performance & Resources Board

• Enhanced monitoring figures and fitness to practise caseload volumes reported to each meeting through the COO report• Media monitoring reported at each meeting

2

Educ

atio

n -

qual

ity a

ssur

ing

prov

ider

s

Our quality assurance processes do not support compliance with standards for education, training and curricula with a potential impact on patients and below expectation educational outcomes for doctors

J. Hulf

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Documented process and procedures to investigate and monitor concerns

• 'Checks' and thematic quality assurance enable short focussed visits to explore specific issues

• Trained and available staff and Associates

• Enhanced Monitoring Information Published on our website quarterly

• Relationships with other delivery partners

• Sharing of information across the organisation (PSIF and RLS, ELS via Joint Working Intelligence Group)

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Council• Operational KPIs reported each meeting

Performance & Resources Board• Enhanced monitoring activity volumes reviewed each meeting

Strategy & Policy Board• Report of the Education Quality Scrutiny Group (Oct 2015)

Patient Safety Intelligence Forum • Considers patient risk dimension at each meeting

Internal Audit• Adoption of new standards in regional QA visit (May 2016, green) • Review of regional quality assurance visits (July 2015, amber) • Medical Education quality assurance arrangements (September 2014, substantial)

Other assurance

• Professional Standards Authority (PSA) Performance Review 2014/15 Standards of good regulation met

-

Strategic aim 2 - Raising standards in medical education and practice

D3


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4

Rev

alid

atin

g do

ctor

s

We revalidate an individual who is not fit to practise with an impact on patient safety and our reputation

U.Lane

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Documented process and procedures

• Regular performance monitoring and reporting

• Trained and available staff

• Local clinical governance systems identify and address performance concerns

• Employer controls help protect patient safety

• Daily downloads of the register are sent to primary and secondary healthcare organisations

Unl

ikel

y

Mod

erat

e

Low

Council• Operational key performance indicators (KPIs) reported each meeting

Performance & Resources Board • Activity volumes and service target performance reviewed each meeting

Internal Audit• Revalidation compliance scheduled

Other assurance• Professional Standards Authority (PSA) Performance Review 2014/15 Standards of good regulation met• Shaping the future of medical revalidation - Autumn report (January 2016)

-

7

Ethi

cal s

tand

ards

& g

uida

nce

Low awareness and use of our ethical guidance by doctors limits the impact on raising standards of medical practice with a consequent impact on patient care

J.Hulf

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt• Internal oversight group

• Established, documented proceduresPublic consultation used to develop and validate guidance


• Extensive outreach and engagement activities to promote ethical guidance

• Proactive communications strategy and website improvements

• Use of the digital strategy and new products to enhance doctors’ use of the guidance, including e-books ( launched Feb 2016) and app (soft launch March 2016).

Unl

ikel

y

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erat

e

Low

Council• Council to summarise Standards issues and how to maximise impact of the guidance (June 2015)

Strategy & Policy Board• Regular updates during guidance development (ongoing)• Agreement to provide cosmetic guidance update (Feb 2016)

Annual tracking survey 2015 indicates good awareness of our guidance

• Working with the Continuous Improvement team on Guidance development and capacity building project during 2016

Strategic aim 3 - Improving handling of complaints and concerns about patient safety

1

FtP

- in

vest

igat

ing

conc

erns

Application of key controls and processes lead us to reach the wrong conclusion in investigating a doctor’s fitness to practise with an impact on patient safety, registrants, witnesses and/or the reputation of the GMC

A.Omo

Qui

te li

kely

Maj

or

Criti

cal

• Documented process and procedures


• Trained and available staff (general)

• Training programme for decision makers

• ELA engagement with ROs ensures all relevant information is considered during investigations

• ELA engagement with ROs to help identify and manage concerns (pre-investigation)

• Reform agenda to drive process improvements


• English Language process introduced

• Dr meetings Pilot now live and BAU

• New Section 60 rules mean that the GMC can appeal against MPTS decisions.

• R4(4) Pilot also now BAU and being expanded to include single clinical incidents, so more investigation undertaken earlier in the process.

• Stream 2 process replaced by Notify Employer/Notify RO.

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or

Sign

ifica

nt

Council• Operational key performance indicators (KPIs) reported each meeting• FtP Annual Statistics Report (June 2016)

Performance & Resources Board• Activity volumes and service target performance reviewed each meeting

Internal Audit• Implementation of Section 60 requirements (March 2016, green)• Management of increased volume of FTP cases (September 2014, substantial)• Integrity of FTP information and reporting (September 2014, substantial)• Decision-making compliance (September 2015, Green/Amber)

Other assurance• Professional Standards Authority (PSA) Performance Review 2014/15 Standards of good regulation met

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5

Adju

dica

tion Patient safety is impacted and/or

reputational damage is caused by not providing an effective and timely adjudication process

H.Matthews

Qui

te li

kely

Maj

or

Criti

cal

• Documented process and procedures (Adjudication Manual)


• Trained and available staff (including MPTS induction)

• Panellist training and assessment (including Induction programme)

• S60 changes implemented to bring further assurance to MPTS process including binding case management decisions.

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Council• MPTS formal report to Council (6 monthly)• Interim Order Panel service targets reported to each meeting

MPTS Advisory Committee• Quarterly reports to MPTS Advisory Committee

Internal Audit• Implementation of Section 60 requirements (March 2016 - green) • MPTS system compliance of QA arrangements (February 2015, green)

Other Assurance• Professional Standards Authority (PSA) Performance Review 2014/15 Standards of good regulation met

-

6

FtP

- sa

nctio

ns

Doctors under conditions or undertakings do not comply with their sanctions and patients are harmed as a consequence

A.Omo

Unl

ikel

y

Maj

or

Sign

ifica

nt

• Case Review Team - documented processes and skilled resources

• Sanctions are listed on the List of Registered Medical Practitioners

• Notification of overseas regulators (if required)

• Publication of public hearing minutes



• Continuing development of GMC/RO relationships

Unl

ikel

y

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erat

e

Low

Internal Audit• Monitoring sanctions (September 2015, green/amber)


-

10

Legi

slat

ion The UK and European

legislative frameworks in which we operate restricts our ability to deliver functions to full effect or efficiency

P.Buckley

Hig

hly

likel

y

Mod

erat

e

Criti

cal

• Domestic legislation - active engagement with DH(E) including over the use of s.60 orders to amend the Medical Act.

• Chief Executive legislation group has been reformed to assist regulators to develop common positions around future shape of regulation

• European legislation - skilled and resourced team to monitor and represent our interests at the European level. we continue to engage with DH and BIS on the Recognition of Professional Qualifications engagement and implementation.

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Strategy and Policy Board • RPQ update (Feb 2016) • Process of specialty recognition in the recognition Directive (May)

Performance and Resources Board

Update on IMI (Jan 2016)

Council• Chief Exec report - Legislative reform update• Chief Operating Officer's Report • RPQ update (July 2015) • Implications of the General Election and future shape of regulation (July 2015)• Session on legislative reform (Feb 2016)

Council - Members Circular• Update on Law Commission Bill (March; April; June; July 2016)

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19

Exte

rnal

env

ironm

ent

Brexit: The impact of changes resulting from the European referendum are not yet clear, providing uncertainty as to the future implications of the GMC’s work.

P.BuckleyQ

uite

like

ly

Maj

or

Criti

cal

• Review of potential impact on the legislation affecting our work being led by the European and International team

• Ongoing engagement planned with Government and key stakeholders

• Active engagement with key influencers to influence post Brexit proposals for healthcare regulation and accountability.

• Programme of active engagement and influence with the HSC through 2017,including response to inquiry on impact of Brexit on the health sector

• Establishment of cross-Directorate Brexit working group to scope challenges and opportunities for the GMC and to define legislative priorities

• Liaison with UK and European regulators to ensure influence and leadership of key networks is maintained

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Council• Short discussion at Council on 29 September

Other• HSC response shared with Council

On 3 November 2011, the High Court ruled that Parliament must

vote on whether the UK can trigger Article 50. The government is

appealing.

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20

Exte

rnal

env

ironm

ent

The GMC's regulatory effectiveness, credibility and reputation may erode over time if we don't keep abreast of widening political agendas in the devolved nations and England and adapt accordingly, as highlighted by the outcome from the EU referendum and national elections.

P.BuckleyQ

uite

like

ly

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erat

e

Sign

ifica

nt

• Understand and respond to political and health environment - skilled and resourced Devolved Office teams consider and manage developments in the external environment with consideration at regular 4 country strategic risk meeting • Full implementation of DO Review • Develop an action plan to implement outcomes of Council seminar paper "The vote to leave the EU and regulating in a four country and international context" July 2016

Quite likely M

inor

Low

Council• Regular milestone for Council review to be agreed

Performance and Resources Board• PRB agreement of risk September 2016.

-

3

Reg

iste

ring

doct

ors

We register an individual who is not properly qualified and/or fit to practise with an impact on patient safety and our reputation

U.Lane

Qui

te li

kely

Maj

or

Criti

cal

• Documented process and procedures: UK graduates EEA IMG Specialist and GP applications



• Information exchange with competent authorities informs our processes



Unl

ikel

y

Mod

erat

e

Low

Council• Operational key performance indicators (KPIs) reported each meeting

Performance & Resources Board• Activity volumes and service target performance reviewed each meeting

Strategy & Policy Board• Review & Appeal options - specialist apps (April 2016)

Internal Audit• Adoption of Recognition Professional Qualification Directive 2013/55/EU (March 2016, green)• UK Graduate Application (May 2015, green) • Approved Practice spotcheck (November 2015)• Operational readiness for English language testing (October 2014, substantial)• Fraud prevention of detection phase 2 (October 2014, substantial)


-

13

Med

ia

Low awareness of our role and how we conduct our business leads to media coverage which damages our reputation

P.Buckley

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Skilled and resourced media team to handle media enquiries

• Communications activities to raise awareness of our role: ○ Co-ordinated campaign planning with policy directorates ○ News bulletins to stakeholders and key audiences in 4 countries ○ Proactive media and social media campaigns about our role

• Professional and active corporate presence on all main social media channels

• GMC processes and systems have other relevant checks/control: ○ Daily media monitoring ○ Social Media monitoring

• Governance - media principles agreed by Chair & Chief Executive

• Development of Media Strategy includes audience plans

Qui

te li

kely

Min

or

Low

Council• Receive of daily media cuttings• Receive GMC press releases-'Informal session on the work of the media team (April 2016)'• Media performance reviewed at each Council

Performance & Resources Board• Media performance reviewed at each Board

Internal Audit• Writing with impact and tone of voice (July 2016, green/amber)

Other Assurance• Tracking Survey publication April 2015

Strategic aim 4 - Working more closely with doctors, medical students and patients

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Strategic aim 5 - Working better together to improve our effectiveness in delivery of regulatory functions

11

Gov

erna

nce Our governance arrangements

may not enable the Trustees to discharge their accountabilities effectively

S.Jones

Hig

hly

likel

y

Maj

or

Criti

cal

• Governance arrangements in place including Council, executive and external engagement.

• Performance management system for members and staff

• Business planning & budget setting process

• Risk Management Framework

• Performance monitoring & reporting

• Policies and procedures

• Internal audit

• Council member training and annual appraisal in place

• Regular governance reviews

Unl

ikel

y

Mod

erat

e

Low

Council• CE and COO reports at each meeting• Review of performance data at each meeting• Report of the Audit and Risk Committee (June 2016)• Report of the Remuneration Committee (December 2015)• Report of the Performance & Resources Board (December 2015)• Report of the Strategy & Policy Board (December 2015)• Council forward work programme 2016 (December 2015)• Review of Council effectiveness (ongoing)

Internal Audit

• Change programme risk management (June 2016, green)• Equality and diversity review (June 2016, green)• Risk benchmarking review (January 2016, green) • Operational risk management (June 2015, green/amber)• Review of whistleblowing arrangements spotcheck (March 2015)• Gifts of hospitality spotcheck (March 2015)• HR performance data reporting (February 2015, green)• Integrity of FTP performance information (September 2014, substantial)• Review of governance arrangements (September 2014 - not rated)

Other Assurance• External audit of financial accounts, 2016, 2015, 2014• Review of internal audit (January 2014)

-

14

Fina

ncia

l con

trol

s (f

raud

) an

d ex

pend

iture

Our anti fraud procedures and process may not prevent internal or external parties from committing fraud against the GMC resulting in monetary loss.

N.Roberts

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Business planning & budget setting process to ensure funds are allocated appropriately

• Monthly management reporting and review

• Financial controls including delegated authorities by the PRB

• Fraud-control processes including policy, training, response plan, public interest disclosure policy and anti-fraud and corruption policy.

• Oversight of Investment Policy by Investment Sub Committee

Unl

ikel

y

Mod

erat

e

Low

Council• Annual Report & Accounts 2015 (June 2016)• Fitness to Practise Annual Report 2015 (June 2016)• Financial performance reported as part of COO report each meeting

Audit & Risk Committee• Review of annual accounts (April 2016)

Performance & Resources Board• Financial performance reviewed at each meeting

Internal Audit• Anti fraud arrangements (May 2016, green) • Financial controls review (October 2015, green) • Procurement review (March 2015, green) • Fraud prevention of detection controls (October 2014, substantial)• Anti fraud and corruption arrangements (September 2014, sound)

Other Assurance• External audit of financial accounts 2016, 2015, 2014

-

15

Wor

k pr

ogra

mm

e de

liver

y

The volume and complexity of the programme of work we seek to undertake exceeds our capacity to successfully deliver

N.Dickson(S.Goldsmith)

Qui

te li

kely

Maj

or

Criti

cal

• Business planning & budget setting process

• Risk Management (including risk escalation matrix incorporating SLA variation triggers)

• Monthly monitoring of delivery progress and reporting

• Centralised Corporate Business Planning team embed processes and systems across Directorates

• Trained and skilled staff in project management

• PPM methodology and reporting: update on risks and project delivery every two weeks via highlight reports with daily availability of progress for all including Portfolio Lead, Sponsor, Project Manager, PMO and COO

• CBPM stage gate reviews for all projects

Unl

ikel

y

Mod

erat

e

Low

Council• Delivery progress update as part of COO report at each meeting• 2016 Business Plan & Delivery (Dec 2016)

Performance & Resources Board• Business plan delivery reviewed at each meeting

Internal Audit• Change Programme Risk Management (June 2016, green/amber)• Programme Management Office spot check (May 2016)• Change Programme planning (March 2016, green/amber) • Operation risk management (June 2015, green/amber)• Business planning (May 2014, substantial)• Pilot of meeting with doctors (February 2014, sound)

2017 Business Planning underway

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16

Staf

fing

Difficulties in the recruitment and retention of staff with the required skills and experience may challenge our ability to deliver our functions effectively.

N.Roberts

Qui

te li

kely

Maj

or

Criti

cal

• Talent and leadership programmes builds capacity

• Corporate record keeping systems and requirements enable central record for corporate memory

• Directors and ADs identify unique knowledge, skills and relationships to ensure suitable mechanisms in place to record/transfer

• Annual performance management cycle and learning and development function identify staff training needs and prioritise and support staff development as required

Unl

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y

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erat

e

Low

Council• Council receive an annual HR report

Council - Members Circular• Niall decision to step down (Jan 16)• CE recruitment (April 2016)• Senior Staff Appointments/Changes (June; July)

Performance & Resources Board• Staffing volumes monitored at each meeting (including absenteeism, turnover, key staff changes)

Internal Audit• HR appraisal review (June 2015, green/amber) • HR conducting annual review of succession planning

Other assurance• Internal checks are carried out on the quality of the performance management system throughout the year

-

17

Busi

ness

Con

tinui

ty

An external incident which effects our infrastructure and/or staffing levels may prevent us from delivering our key functions

N.Roberts

Qui

te li

kely

Maj

or

Criti

cal

• Business continuity plans in place including periodic testing - focussed on core business as usual areas to ensure patient safety protection

• Alternative routing procedures and systems in place to manage faults when they arise • Investment programme in resilience components to proactively avoid faults

• Testing of process recovery

• Information security processes protect against IS failures

Unl

ikel

y

Mod

erat

e

Low

Business Continuity Working Group - (2 monthly)

Annual report to PRB for review• Annual update from Business Continuity Working Group to PRB

Internal audit• Penetration testing (June 2016, no rating)• Business Continuity arrangements (August 2015, green) • Penetration testing (July 2015, no rating) -

18

Ope

ratio

n of

DB

pens

ion

sche

me

Adverse economic events create a significant deficit in the Defined Benefit (DB) Scheme which the employer needs to cover

N. Roberts

Qui

te li

kely

Maj

or

Criti

cal

• Maintaining adequate reserves

• Future liabilities restricted by scheme closure and benefits changes

• Full implementation of Trustees de-risking investment strategy

Unl

ikel

y

Mod

erat

e

Low

Council is consulted by Trustees on the scheme’s investment strategy and the triennial valuation.Council decides the pension provision the employer offers

Internal audit• Trustees have the scheme audited on an annual basis.• The employer has access to actuarial adviceOther assurance• Ernst and Young provide independent advise on the investment strategy and fiduciary manager• Trustees have actuarial and investment advice investment

-

D9


Current active risks and how we are reducing them

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1A

Util

isin

g da

ta

By not effectively sharing the information we hold throughout the organisation or broader health service, we could contribute to a risk to patient safety

P.Buckley

• Data Strategy

• Patient Safety Intelligence Forum

• Quality Architecture Project Group

• Quarterly surveillance groups consider risk with CQC

• Existing specialist data teams and siebel analytics capability

• Regular (8 weekly) intelligence sharing meetings in place (Regional Information Forums)

• MoUs: Healthcare Inspectorate Wales, TDA and RQIA, Health Improvement Scotland -'DO protocol for escalation processes - JWIG meeting brings together DOs, RLS, Reval & Education to share information.

• Existing employer controls to protect patient safety

• Systems regulators, professional regulators, professional bodies, education institutions actively overseeing patient safety

• Revision of escalation process and RLS operating model (June 2016)

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Central Analytics Team to be formed by February 2017 with responsibility for co-ordinating data sharing

Data Sharing manager developing policy tools for information sharing (Q3 2017)

Evaluation of data sharing agreements to be undertaken by CAT (TBC)

Performance & Resources Board • Resourcing the data strategy (June 2016)

Strategy & Policy Board• UKMed Data Warehouse (Feb 2016)

Council • Developing the online register (April)• Chief Operating Officer's Report (June 2015; Sep 2015)

Data Strategy Programme 2015 (Substantial)Further review planned Sep 2016

The Regulatory Policy team have implemented a Triage group for the Patient Safety Intelligence Forum (PSIF). This will take a view on what information is presented to PSIF.

MOUs have been refreshed/finalised with HIS; Monitor.

Following on from CQC meeting, IM drafted escalation policy which will be discussed at the next joint working group. Developed new contact note (data capturing form for RLAs)First phase of Data Strategy project is complete.

Redesigned the way we share intelligence - bespoke arrangements for each directorate.

Work on police disclosures being taken forward by FPD. Controls/owner to be updated subject to further discussion.

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

12- External Environment

4A

Equa

lity

& D

iver

sity We do not comply

with our statutory obligations on Equality and Diversity and Human rights, leading to unfair outcomes.

P.Buckley

• Equality & Diversity Strategy

• Directorate action plans

• Skilled and resourced team to promote E&D in our work

• Equality analysis undertaken as a component of major project activity

• Equality and diversity training for all staff and associates

• E&D Programme Board (chaired by COO)

• Audit of papers considered by SPB and Council, all found to be compliant

• Unconscious Bias training delivered to key staff involved in making decisions about doctors

• External audit found that we are broadly compliant and delivering our E&D Strategy

• Phase II Unconscious Bias training for staff and associates

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Develop guidance on culture and making fair decisions for MPTS and FtP decision makers (December 2016)

We are taking legal advice on whether we are compliant with Sections 15 and 22 of the Gender Recognition Act (GRA) 2004 in how we handle and share information about transgender patients in our FTP activities

Work on reasonable adjustments (ongoing, with workshop Oct 2016)

Joined AoMRC working group to develop guidance on making reasonable adjustments in high stakes exams

Strategy & Policy Board• Consider and update on 2016 plans & priorities (May 2016)

Council• Update via COO report (ongoing)• Seminar on Fairness & Proportionality (April 2016) • Update on implementation of our strategy (Sept 2016)

Education and Training Board• Will consider how to ensure reasonable adjustments within the continuum of medical education and training (Oct 2016)

Review E&D operationalisation (July 2016, green)

We are not consistent in our approach to making reasonable adjustments for people wanting to raise concerns with us - this is being raised with colleagues in FtP & IS.

We have received a legal challenge on our corporate position on less than full time working which has gone to the Employment Tribunal.

Unl

ikel

y

Mod

erat

e

Low 1-7

Corporate Risk that

Action Plan relates to

Comment(incl. external assurance where

relevant)

Further mitigating actions to be implemented

(with target date)

Risk target

Council and/or Board ReviewInternal Audit

coverageID Risk Owner

Fun

ctio

n /

Act

ivit

y Residual

Existing controls(incl. Local QA where relevant)

Strategic aim 1 - Making the best use of intelligence

D10



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relevant)


(with target date)

Risk target



Fun

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ivit

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Strategic aim 2 - Raising standards in medical education and practice

2A

Rev

alid

atio

n

We lose support for revalidation from key interests groups which undermines revalidation and has an impact on patient safety, our resources and our reputation.

U.Lane

• GMC processes and systems in place are robust and maturing (Since Dec 2012).

• Our guidance and processes for managing and responding to information about revalidation.

• Revalidation has direct links to Care Quality Commission inspections to share information on systems concerns.

• Patient Safety Intelligence Forum uses revalidation for identifying concerns around and a mitigation for local clinical governance issues

• Revalidation Advisory Board allows us to monitor views and experience of implementation , while providing advice and support from external key stakeholders (quarterly meetings)

• ELAs in place to support Responsible Officers and identify risks (opportunities/threats), issues and best practice

• Our continued engagement with and support of ROs through the Responsible Officer e-bulletin (quarterly) and the Responsible Officer Reference Group (bi-annual meetings)

• SOMEP 2014 and SOMEP 2015 reports included positive findings on ‘The impact of revalidation on patient safety’.

• Introduction of the annual return process for doctors with no prescribed connection to support the development of the revalidation assessment (Nov 2013)

• Revalidation Assessment implemented for doctors without connections (January 2016) • Decision Review Group established to support the organisation learn from appeals (Q4 2015)

• Proven experience in changing and responding to NHS restructures and subsequent changes to designated bodies (April 2013 and April 2015)

• Responsible Officer architecture and local systems

• Open publication of strategic evakuation interim report (Apr 2016)

• Sir Keith Pearson commissioned to conduct review and offer recommendations for improvement (Taking Revalidation Forward scheduled to report to Council Dec 2016)

• Publications of case studies and guidance n enhancing understanding of the role of patients and the public in revalidation ( January 2016)

• Publication of Manchester Business School interim Report for DH evalutaion revalidation - including survey or responsible officers (Apr 2016)

• Regular external meetings with key stakeholder organisations including: Academy of Medical Royal Colleges, Association of Independent Healthcare Organisations and the Responsible Officer Calibration and Operational Network (ongoing)

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Continued Senior management engagement with NHS England, Department of Health and other stakeholders around the future of responsible officer functions and potential legislative changes (ongoing)

Strategic evaluation (2018 - final report) Have initiated a review of current guidance for collating supporting information and plan to establish a working group with external stakeholders (project completion Q4 2017)/ DH (England) undertaking an evaluation of revalidation in England (Report early in 2017)

Recommendations from Sir Keith Pearson's Review of Revalidation to begin being implemented in 2017 .

Council:• Chief Operating Officers report - Performance against service targets and volumes of activity – fitness to practise, registration and revalidation• Strategic evaluation and MBS DH interim reportsRevalidation Assessment COO Report Feb 2016; Apr 2016 and June 2016)

Strategy & Policy Board• Report of the Revalidation Advisory Board ( February 2015; July 2015; and Oct 2015)• Revalidation arrangements for doctors in our FTP processes (May 2015)• Revalidation assessment update (Oct 2015)• Report of the Strategy & Policy Board 2015 from Chief Exec - RAB, revalidation of FTP Strategic evaluation verbal updates (Feb and Mar 2016)

Performance & Resources Board:• Operational Performance and Risk Review ( January 2015; April 2015; and June 2015,Sep 2015; Nov 2015; Jan 2016; Mar 2016; April 2016; and Jun 2016)

Review due Nov 2016

Revalidation Assessment first notices were sent in January, the first round of

assessments took place in May and the first doctors to be revalidated was in June

2016.

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ikel

y

Mod

erat

e

Low 12 - External

Environment

D11



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relevant)


(with target date)

Risk target



Fun

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Act

ivit

y Residual


10A

Med

ical

Lic

ensi

ng A

sses

smen

t

Our model for a Medical Licensing Assessment is not developed to be fit for the future, attract key interest support and able to be implemented within a reasonable timeframe with a impact on patient safety, medical students, new registrants and the reputation of the GMC with key interest groups and the public

J. Hulf

• Council have given support in principle and detailed proposals for the public consultation are being worked up for September 2016

• A formal project has been established which is subject to regular reporting

• Governance arrangements are in place with an Executive Board chaired by the CEO and Project Steering Group chaired by the COO providing leadership and oversight.

• Regular engagement takes place with the Medical Schools Council and medical schools

• Regular engagement takes place with the Medical Schools Assessment Alliance

• Sufficient resource and budget allocated

• Comprehensive engagement plan to liaise with a range of key stakeholders including all UK administrations.

• Appointment of Expert Reference Group meeting from October 2016

Qui

te li

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erat

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Sign

ifica

nt

A programme manager has been appointed with a start date of September 2016

Appointment of Consultants to review structure, governance and communications associated with the project, in preparation of appointment of the programme manager

Appoitment of 2 examinations officers with a start date of December 2016

Appointment of Consultants to draft a detailed cost and impact analysis of a range of MLA options (June - October 2016)

Council• Initial business case and agreement to develop proposals June 2015• Update report April 2015

Strategy & Policy Board• Initial business case May 2015

Review planned 2017

Unl

ikel

y

Min

or

Low 12 - External

Environment

14A

Wor

king

with

reg

ulat

ory

part

ners

In cases where there are high profile patient safety issues and potentially unsafe environments for doctors and doctors in training, there are challenges in working effectively and collaboratively with other regulatory partners causing an adverse reputational impact for the GMC

Susan Goldsmith

• Information sharing agreement in place with CQC

• Education enhanced monitoring process in place

• Internal processes to manage communications


Qui

te li

kely

Hig

h

Criti

cal

• Working towards information sharing agreements in other regulators including devolved nations

• We are currently undertaking a lessons learned exercise, including whether there are ways to improve our joint working with other regulators

Council• Acting Chief Executive's Report (June 2016), North Middlesex

Audit and Risk Committee• Verbal update from CEO (July 2016), North Middlesex

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Risks 2 - Education QA, 8 - informatio flow between GMC and other bodies, 1A - information sharing internally and externally

13A

Util

isin

g da

ta

Further historical abuse cases involving doctors come to light which call in to question the GMC’s actions at the time and impact on our reputation as a patient safety organisation.

P.Buckley

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt • Review of historical child abuse cases to be undertaken, to potentially complete in 2017. Terms of Reference currently being finalised.

The review will be overseen by the Historical Abuse Inquiries Project Group, and findings will be reported to Council.

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Strategic aim 3 - Improving handling of complaints and concerns about patient safety

D12



Like

lihoo

d

Impa

ct

Ass

essm

ent

Like

lihoo

d

Impa

ct

Ass

essm

ent

Corporate Risk that



relevant)


(with target date)

Risk target



Fun

ctio

n /

Act

ivit

y Residual


5A

EU C

ompl

ianc

e

We are do not remain compliant with the Recognition of Professional Qualifications Directive by the associated deadline (originally January 2016) with consequent reputational damage and potentially financial loss.

P.Buckley

• European and International team skilled and resourced to engage European and DH(E) officials

• RPQ project team formed with cross organisation representation (RPQ Working Group)

• RPQ implementation activity factored into business planning for 2015 (All)

• Project teams established to deliver directorate specific and cross directorate implementation activity

• Legal advice sought on whether the language checks that we have in place currently are compatible with the new language requirements in the Directive for both established and temporary & occasional registrants

• Adopted a GMC policy position on common training frameworks and tests.

• Adopted ENMCA policy position on common training frameworks

• DH assurances and our legal advice confirmed elements of directive have direct effect on 18 Jan 2016 ahead of delayed Medical Act changes due March 2016 (December 2015)

• R&R and FPD: Management of the inbound and outbound alerts through IMI alerts mechanism now live (Jan 2016)

• Temporary & occasiional application route now online with updated guidance (January 2016)

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Council • Chief Exec's Report (June 2015; Sep 2015; Dec 2015)• RPQ Update (July 2015)• Chief Operating Officer's Report ( Dec 2015)

Strategy and Policy Board• Discussion paper on Section 18 temporary and occasional registration (May 2015) • Impact of EU RPQ on acceptable overseas qualifications (Dec 2015)

Implementation review (May 2016, green)

Operational review planned Nov 2016

The European Qualifications (Health and Social Care Professions) Regulations 2016 were laid in Parliament on 28 October 2016 and are expected to come into force on 18 November.

We will consider whether this risk should be closed once the legislation is enacted.

Unl

ikel

y

Mod

erat

e

Low 12 - External

Environment

D13



Like

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d

Impa

ct

Ass

essm

ent

Like

lihoo

d

Impa

ct

Ass

essm

ent

Corporate Risk that



relevant)


(with target date)

Risk target



Fun

ctio

n /

Act

ivit

y Residual


Strategic aim 4 - Working more closely with doctors, medical students and patients

Low

3 - Registering doctors

• Other than T&O service providers, licensed doctors who are established in the UK are required to revalidate (Since Dec 2012)

• Licensed doctors who are established in the UK are also required to maintain a connection to a designated body/suitable person or take part in the annual return process (May 2014)

• English language competency requirements introduced and IELTS score increase (June 2014) and maintained following clarification of powers under revised RPQ Directive (Jan 2016)

• Legal position established on options to review declarations by s.18 (temporary and occasional) registrants

• Legal advice sought obtained on whether the language checks that we have in place currently are compatible with the new language requirements in the Directive for both established and temporary & occasional registrants. (R&R)

• ID checks conducted on all doctors prior to granting registration currently in place as an anti-fraud and security measure

• Strategy & Policy Board agreed to accept a risk of challenge on our application requirements for doctors who apply for s.18 (temporary and occasional EEA) and the monitoring of their practice (May and Dec 2015)

• Existing employer controls to protect patient safety

• Systems regulators, professional regulators, professional bodies, education institutions actively overseeing patient safety

• DH assurances and our legal advice confirmed elements of directive have direct effect on 18 Jan 2016 ahead of delayed Medical Act changes due March 2016 (Dec 2015)


• Temporary & occasional application route is now online with updated guidance - including criteria for 'temporary and occasiona'l and 'establishment' in medical practice (Jan 2016)

• Pilot approved by DH and completed by GMC with a view to establishing to assess recognition of existing entries and new additions to Annex V Recognition on the basis of coordination of the minimum training conditions. Report provided to DH (Feb 2016)

• Publicising the features of T&O registration to employers through a series of presentations in the four countries (April to Dec 2015)

• Mailings to employers publicising the features of T&0 registation including a mailing to UK Chief Executives from Niall Dickson and Terence Stephenson (Jan 2016)

6A

Free

dom

of

mov

emen

t

We register an individual who is not properly qualified and/or unfit to practise owing to the limited checks we can conduct on EEA nationals under EU legislation, with an impact on patient safety and our reputation. U.Lane

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

• Cross referencing data sources to identify doctors with temporary & occasional registration gaining full time employment or connection to a designated body (Jan 2016 onwards)

Council • Chief Exec's Report (June 2015; Sep 2015; Dec 2015)• Council session on EEA doctors (July 2015)• Chief Operating Officer's Report ( Dec 2015)

SPB• Impact of EU RPQ on acceptable overseas qualifications and Guidance for Doctors considering T&O service provision (Dec 2015)

Audit and Risk CommitteeSession on RPQ risk (May 2015)

PRB• Update on the risks and the IMI Alert Mechanism (Nov 2015

Implementation and introduction of the EU RPQ audited in

[Apr 2016] and received a green

rating The European Qualifications (Health and Social Care Professions) Regulations 2016 were laid in Parliament on 28 October 2016 and are expected to come into force on 18 November.

Unl

ikel

y

Mod

erat

e

D14



Like

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d

Impa

ct

Ass

essm

ent

Like

lihoo

d

Impa

ct

Ass

essm

ent

Corporate Risk that



relevant)


(with target date)

Risk target



Fun

ctio

n /

Act

ivit

y Residual


15A

Exte

rnal

Env

ironm

ent

Taking ill-judged action in response to the junior doctors’ industrial action could cause damage to our reputation, and impact our relationship with the profession and other key interests including our ability to engage with them effectively

S. Goldsmith

Published holding statement on 31 August 2016 and further comprehensive statement on 5 September 2016 which sought to balance doctors’ responsibilities with a commitment to work to improve doctors’ professional lives beyond contract issues. The statement also underlined our work in protecting the quality of education and training. The statement was well received by the NHS and others and contributed to the BMA decision not to proceed with the first round of strikes. H

ighl

y lik

ely

Maj

or

Criti

cal

The statement has raised our profile around this issue and we are continuing to monitor all media activity

Strikes planned are due to proceed and we will continue to monitor as the situation evolves

Flexibility review - first stage meeting planned for October

Discussion with Council in September's Council meeting

Hig

hly

likel

y

Mod

erat

e

Sign

ifica

nt

Risks 2 - Education QA, 8 - informatio flow between GMC and other bodies, 1A - information sharing internally and externally

9A

Patie

nt s

afet

y an

d re

sour

ces The requirements of

the EU Recognition of Professional Qualifications Directive creates a strain on our resources and/or capacity with an impact on patient safety.

S. Goldsmith

• European and International team skilled and resourced to engage European and DH(E) officials.

• RPQ project team formed with cross organisation representation (RPQ Working Group).

• RPQ implementation activity factored into business planning for 2015 and 2016.

• Close working relationships with other regulators via AURE and ENMCA to ensure joint concerns are brought to UK politicians’, UK and EU officials attention in a timely manner.

• Strategy & Policy Board agreed to accept a risk of challenge on our application requirements for doctors who apply for s.18 (temporary and occasional EEA) and the monitoring of their practice (May 2015).

• DH assurances and our legal advice confirmed elements of directive have direct effect on 18 Jan 2016 ahead of delayed Medical Act changes due April 2016 (Dec 2015)


• Temporary & occasional application route now online with updated guidance (Jan 2016)

• Trained and available staff weekly monitoring

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Develop an EU engagement strategy to focus engagement with key stakeholders (Department of Health, Department for Business Innovation & Skills, the European Commission and other European Regulators) on the risks to patient safety arising from primary and secondary legislation changes (S&C) (Sept 2015)

Cross referencing data sources to identify doctors with temporary & occasional registration gaining full time employment or connection to a designated body (Jan 2016 onwards)

Guidance for T&O service providers (Dec 2015)

Council • Chief Exec's Report (June 2015; Sep 2015; Dec 2015)• Council session on EEA doctors (July 2015)• Chief Operating Officer's Report ( Dec 2015)

Strategy & Policy Board• Discussion paper on Section 18 temporary and occasional registration (May 2015) • Impact of EU RPQ on acceptable overseas qualifications (Dec 2015)/ Guidance for T&O service providers (Dec 2015)

See RPQ review above

The European Qualifications (Health and Social Care Professions) Regulations 2016 were laid in Parliament on 28 October 2016 and are expected to come into force on 18 November. U

nlik

ely

Min

or

Low

3 - Registering doctors

15 - Work programme delivery

17 - Business Continuity

D15



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lihoo

d

Impa

ct

Ass

essm

ent

Like

lihoo

d

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ct

Ass

essm

ent

Corporate Risk that



relevant)


(with target date)

Risk target



Fun

ctio

n /

Act

ivit

y Residual


11A

Chan

ge P

rogr

amm

e

Due to the increased pressures on the business, the implementation of the corporate Change Programme may be delayed or inefficiently executed. This would lead to underachievement of the anticipated benefits of the programme.

S. Goldsmith

• Existing financial control measures are robust –links to risk 14

• Corporate Business Planning and budgeting controls apply to BAU and the Change Programme combination – links to risk 15

• The high level governance structure for oversight of programme risks and delivery is well embedded in existing GMC structures (i.e. PRB, ARC and Council) – links to risk 11

• Workforce planning controls exist and have been tested with previous re-location challenges – links to risk 16

• Existing stakeholder engagement plans provide the platform for the Change Programme communications – links to risks 12 and 13

• External specialist input and scrutiny provided through Pension Trustee Board

• Change Programme Performance and Resources Board meetings to be established with full Project Management Support for oversight and performance reporting (December 2015)

•Overall Change Impact Assessment for the Change Programme to be developed (December 2015)

• Detailed risk analysis and individual project risk registers

• Communication strategy for Internal and external stakeholders in place

Qui

te li

kely

Mod

erat

e

Sign

ifica

nt

Ongoing lease negotiation advice sought from property advisers

Agreement on lease arrangements ongoing (December 2016)

Further analysis of risks across the programme to be undertaken to implement recommendations from audit of programme risk management in July 2016 (Ocober 2016)

Change programme papers and presentations have been discussed at:

• Council away day (July), seminar and meetings (September, November and December 2016) • At every Council and Audit and risk committee a verbal progress update is given by the COO.• At every PRB change board meeting there is a full update on each portfolio provided by the portfolio lead.

Initial implementation (March 2016, green/amber) PMO spot check (May 2016, green/amber) ▪ ▪ Programme risk management planned July 2016 PMO follow up planned Nov 2016

Unl

ikel

y

Mod

erat

e

Low

14 - inadequate forecasting and financial control, 11- governance arrangements, 16- recruit, retain or manage transition of staff, 12-responding to emerging issues, 15- volume/complexity of programme and capacity to deliver.

12A

GM

C Se

rvic

es

When GMC services transitions from selling currently provided services to growing activity, appropriate resources will be required to ensure effective delivery at the appropriate standard.

S. Goldsmith

• Allocation of resources decisions made in context of 2016 business planning• Incorporated as business as usual activity • Appointed lead of GMC Services establish governance model linking into that currently adopted by the GMC. Proposal and business case for taking forward initial pilots (June 2016) Q

uite

like

ly

Mod

erat

e

Sign

ifica

nt Review of options for capacity to bid and deliver - paper to COO by November

Regular updates to COO on projects - ongoing

Change programme papers and presentations have been discussed at:

•Monitored at each PRB change programme meeting - Reporting to PRB in April 2016 and Council June 2016• Council away day (July 2016), seminar and meetings (September 2016, November 2016 and December 2016)

Unl

ikel

y

Mod

erat

e

Low

Strategic aim 5 - Working better together to improve our effectiveness in delivery of regulatory functions

D16


Council meeting 14 December 2016

D17

Risk appetite statement

Introduction 1 The GMC is an independent organisation that helps to protect patients and improve

medical education and practice across the UK.

We decide which doctors are qualified to work here and we oversee UK medical education and training.

We set the standards that doctors need to follow, and make sure that they continue to meet these standards throughout their careers.

We take action to prevent a doctor from putting the safety of patients, or the public's confidence in doctors, at risk.

2 Every patient should receive a high standard of care. Our role is to help achieve that by working closely with doctors, their employers, patients and educators to make sure that the trust patients have in their doctors is fully justified.

Protecting patients underpins everything we do 3 Given our patient safety focus, we have a low risk appetite overall in

relation to our activities.

4 However, we also recognise that to function as a modern, outward-facing organisation working in a digital, 24/7 environment, and to respond successfully to the strategic and operational challenges described in our Corporate Strategy and annual business plans, we are exposed to and must accept a certain level of risk.

5 Risk is sometimes – wrongly - associated solely with taking action, the implication being that doing nothing avoids any risk. But often there is more risk in failing to respond or pre-empt an issue, even in circumstances of great uncertainty.

Why we consider risk in our decision-making 6 If we do not assess risk properly then we are more unlikely to achieve what we set

out to do. In seeking to embrace opportunities which have the potential benefit in the medium and longer term to strengthen patient and public protection, improve


D18

patients’ experience of medical care, enhance the learning environment for students and trainees and improve standards of medical practice. It is therefore incumbent on us to carefully consider the risks which may impact on a successful outcome to achieve the benefits of taking a particular course of action.

7 An example of this is seizing the opportunity to develop and implement a data strategy as we believe in the longer term understanding the data and intelligence we and others in the health system hold, will support a more proportionate, risk based and targeted approach to future regulatory activities.

8 In developing our approach to the use of data we need to be mindful of all the risks but balance them with the goal of better protecting patients, guiding doctors, supporting medical education and reducing the burden of regulatory action.

How we balance risk and opportunity 9 We acknowledge that within our general approach to setting risk appetite, one size

does not fit all. To address this, we consider a number of factors in the opportunities and risks involved when making decisions for different activities and projects.

10 Considering the impact on a broad spectrum of factors provides a framework for us to map not only individual decisions but also to see the collective impact of several decisions. The outcome is then used to inform the resources and capacity we will need if we are to translate the decisions in to action.

11 We have shown this diagrammatically below.

m4 - chief operating officer’s report · procurement process in september 2016, we have selected...

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