The General Medical Council (GMC), the oversight body of medical professionals in the United Kingdom, recently published its report. Audit of decision-making in the Physical Process of the General Medical Council in July 2021 (“Report”).


The auditor was commissioned to answer that question. “Are the decisions made by the GMC staff in relation to the evidence presented at the time of the decision based on the key points of competency to practice our conduct in accordance with the guidelines for decisions?”

Fieldfisher was appointed to conduct this audit and chose to work with lawyer and academic Annie Sorby, a professor of medical law and ethics at the University of Edinburgh. Annie developed a strong sampling method with the following in mind

1. The category of case in which key decisions were made (e.g., types and sources of charges); And

2. Characteristics of the medical professionals in question (e.g., the region in which the medical professional first acquired their medical qualifications and gender).

Fieldfisher specialists review sample issues and audit key decisions in the GMC guidelines. The purpose of the audit is to determine if each decision is within the scope of the policy or if there is a valid reason to withdraw from the policy.

The following are some examples of GMC guidelines used to determine the fairness of decisions.

  • The application of the fact-finding test (ie, whether the case is sufficient to act on the physician’s record and whether the case can be verified at the required level, which means that the alleged incidents may occur more than once);
  • When and how to take medical professional qualifications to practice history;
  • Conditions in which jobs can be offered;
  • Issues of warning or counsel, etc.

GMC Decision Stages

The audit focuses on the GMC decisions, in contrast to the preliminary screening (ie, Triage, Interim Inquiry and Case Investigator) decisions of the final Inquiry (which is conducted by an independent court). The GMC pre-screening process is a bit different from the process in Ireland and therefore needs some explanation.

  • The ‘Triage’ stage GMC is used to determine whether a complaint or question raises a medical professional’s eligibility to practice. Complaints related to practice qualifications will be closed immediately (eg disagreements about late appointments or content of medical records). Complaints that do not raise some serious issues do not need to be fully investigated unless they are part of the same concern. GMC will refer those complaints to the practicing officer (RO) or employer.
  • Since 2014, GMC has conducted ‘transient questionnaires’ (PEs) on a number of criteria. These requests can be processed quickly and will help GMC decide whether to close the complaint or open a full investigation. GMC aims to complete temporary inquiries within 63 days, compared to six months for a full investigation. A.D. By 2019, 70% of such cases will be closed without a full investigation.
  • If the case is raised for further investigation by the case investigator following a tripartite / interrogation stage, the examiner must conduct a preliminary examination to determine if there is a substantial situation to determine whether the practitioner is qualified for practice. Approves a certain degree of action on registration.

To summarize, here are some key decisions made in the sample case study.

Tag level

  • Decisions to close the case immediately;
  • Decisions made to the case for investigation and the decision of the case investigator.

Temporary query level:

  • Decisions to close;
  • Decisions to close and notify RO / Employed Registrar.
  • Decisions made to the case for investigation and the decision of the case investigator.

Case Investigator Level:

  • Decisions about whether there is a realistic expectation that a medical professional will be justified to a certain degree of eligibility for practice.


Following a detailed audit of 119 cases, the decisions made on the main points from November 01/2011 to October 31, 2011 were confirmed in accordance with the GMC guidelines. In the 119 cases, 80 decisions, 15 interim investigations and 24 case investigations were taken from a sample frame of 14,936 GMC decision-makers.

The key findings from the audit are as follows.

  • Auditors found no biased evidence in their interpretation of the guidelines they use to practice GMC decision-making.
  • In each case, they have seized it, despite obstacles we can scarcely imagine. “
  • Although not identified in the directive, auditors did not need to move the audit to a secondary level, which analyzes everything that arises from the policy.


This audit is part of an ongoing program to ensure that GMC fitness processes are fair, consistent and robust. The audit is important because the decisions made by the GMC staff at key stages of their investigation are in line with the guidelines for assisting them in making these decisions. The full text of the GMC report is available. over here.

In our experience, it can be very helpful to invite outside experts to conduct a supervisory and compliance audit. If these are done by lawyers, you may be granted special privileges, and may focus on resolving any of the organization’s priorities, although in this case GMC will always be comforted with the intention of publishing the audit report. He made himself available for such an examination.