Revalidation for Locum Doctors: Connection, Appraisal and Evidence

Locum doctors revalidate in exactly the same way as any other licensed doctor. NHS England's revalidation guidance says so directly, and the GMC's own guidance confirms that licence requirements apply whether you work full time or part time, in the NHS or the independent sector, as an employee, self-employed or as a locum. What differs in practice is the paperwork: you need to know who your designated body is, who will appraise you, and how to pull evidence together from several short placements.

This guide explains how locum revalidation works under the GMC's rules, which apply across the UK. Where it draws on NHS England guidance, that applies to England and is flagged as such.

The basics: what every licensed doctor must do

According to the GMC, every licensed doctor must revalidate. Your responsible officer, or a suitable person if you have no designated body, usually makes a recommendation to the GMC every five years. To get there the GMC expects you to:

• keep your connection details up to date in GMC Online, including if you gain or lose a connection, even temporarily;
• have an annual appraisal focused on Good medical practice, covering your whole scope of practice;
• collect, reflect on and discuss six types of supporting information; and
• declare all the places you have worked and roles you have held as a doctor since your last appraisal.

The six types of supporting information are continuing professional development (CPD), quality improvement activity, significant events, feedback from patients or those you provide medical services to, feedback from colleagues, and complaints and compliments. You do not have to cover every type at every appraisal, but all of them must be collected and reflected on by the time of your revalidation recommendation.

Step one: find out who your designated body is

Your designated body is usually the organisation where you do most or all of your practice, and your responsible officer is a senior doctor there. The GMC says you cannot choose your designated body, and it cannot choose to connect to you. Connections only arise once you have started work. The GMC provides a connection tool and an A-Z list of designated bodies to help you check.

For locums this is the part that causes the most confusion, because work may be spread across trusts, practices and agencies. NHS England's 2018 guidance for locum agencies and providers (version 1.0, written for England) explains how connections follow the work:

The guidance also says that some locum agencies are designated bodies and others are not, and that you have only one designated body and one responsible officer at a time. It dates from October 2018, so organisation names and structures may have changed since. Treat it as an explanation of the principle and confirm your actual connection through the GMC's tools or by asking the body concerned.

Step two: arrange one annual appraisal that covers everything

You should have one annual appraisal covering your whole scope of practice, including every role and place you worked that year. The GMC requires you to tell your responsible officer or suitable person about all practice that needs a licence, and the GMC's guidance on supporting information says your information should cover clinical and non-clinical roles and NHS, independent, voluntary and private work.

NHS England's guidance adds several practical points for locums and their designated bodies:

• You do not need to list every individual placement in detail.
• Your designated body should request your most recent and previous appraisal records, and the responsible officer may review the full history.
• The same appraiser should be arranged for no more than three consecutive years, and you should not choose an appraiser you know closely.
• Telephone or audio-only appraisal is not considered acceptable. Technology-assisted appraisal is allowed, but at least two face-to-face appraisals in a five-year cycle is considered best practice.
• Once you are under notice for revalidation (four months before the recommendation date), you should not change designated body unless the regulations require it.
• Keep personal copies of all your appraisal records.

The GMC says that if your employer or designated body changes, your revalidation submission date stays the same.

Step three: gather supporting information from short placements

Short placements can make evidence thin, so plan for it from the start. The GMC says you must keep evidence of the information discussed at each appraisal since your last revalidation, and that you will not meet the requirements by simply collecting information: you need to reflect on it. NHS England notes that doctors in short-term roles often lack employer systems that support CPD, appraisal and governance, so you may need to hold your own records.

A sensible approach is to keep a single running portfolio that includes:

• a list of every placement, agency and date worked;
• CPD records with your reflections;
• any significant events, complaints and compliments, whichever site they came from (the GMC says to tell your responsible officer about these wherever they happened);
• patient and colleague feedback; and
• your personal development plan and its review.

Revalidation is separate from any mandatory training a placement or agency asks for, but it helps to keep both sets of records in one place. A training matrix is a simple way to see at a glance what is current.

What about CPD?

The GMC does not set a number of hours or credits. Its supporting information guidance says it does not mandate the number of CPD points you should collect for revalidation, but you must carry out CPD every year, cover the whole of your practice, tailor it to your scope of practice, reflect on what you learned and discuss it at each appraisal. Royal Colleges and specialty bodies often set their own targets, which your appraiser may expect you to follow. See our CPD hub for more on recording learning.

If you have no connection at all

Some locums, particularly those working in the independent sector, may find they have no designated body or suitable person. The GMC says you should tell it through GMC Online. You may be able to identify a suitable person, a licensed doctor the GMC has approved to make your recommendation, and ask them to add you to their GMC Connect list. If not, the GMC's additional requirements apply:

• use an appraiser who meets the GMC's criteria, which includes having carried out at least five appraisals in the 12 months before yours;
• hold your appraisal in person or by video link;
• submit an annual return through GMC Online, with at least three months' notice of the due date; and
• meet the standard in the revalidation assessment if asked. The GMC describes this as a 120-question multiple-choice test, usually taken in the year you are due to revalidate.

If you plan a long break or will work outside the UK, the GMC says to consider temporarily giving up your licence.

Frequently asked questions

Do locums have a different revalidation process?

No. NHS England says locum doctors revalidate in exactly the same way as any other doctor. The difference is mainly in finding your responsible officer and gathering evidence.

Can I choose my responsible officer?

No. The GMC says you cannot choose your designated body. The connection follows where you do most of your practice.

What if I work for several agencies?

According to NHS England's 2018 guidance, you connect to the agency that has placed you in work the most over the last twelve months. You still need one appraisal that covers all your work.

How many CPD hours does the GMC require?

None are specified. The GMC says it does not mandate a number of CPD points, though you must do CPD every year and discuss it at appraisal.

What happens if I do not engage with revalidation?

The GMC says any doctor not sufficiently engaging with revalidation is putting their licence to practise at risk.

Next steps

Check your connection in GMC Online, book your appraisal early, and keep one portfolio that follows you from placement to placement. If you are a locum agency or employer rather than a doctor, a shared record of who is connected to whom and when appraisals fall due saves a lot of chasing.

This article is general information, not regulatory, legal or compliance advice. Always check current requirements with the General Medical Council and your responsible officer.