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GMC to provide Human Factors training for fitness to practice investigators

The General Medical Council (GMC) has announced that all of their fitness to practice decision makers, clinical experts and case examiners will receive Human Factors training.

Human Factors

Human Factors is a social science that focuses on maximising understanding of the behaviour of people, their interactions with one another and their environment, with the aim of optimising performance.

The move is part of a collaboration between the GMC and Oxford University’s Patient Safety Academy. The Patient Safety Academy will also start working with the GMC’s Employer Liaison Service with the aim of strengthening investigations at a local level, in the hope that fitness to practice concerns can be resolved locally as often as possible.

The GMC believes that integrating Human Factors into fitness to practice investigations will mean that system and environment issues are always considerations when looking at a doctor’s conduct or performance.

Human Factors are already part of the safety investigation protocol in many other high risk, high reliability industries such as civil aviation. It is hoped that the training will allow investigators to better understand system issues when they are a relevant consideration in investigating a doctors’ fitness to practice.

Fitness to practice process

The fitness to practise process investigates the conduct of individual registrants. That system undoubtedly risks unfairness by decontextualising the doctor’s actions from the complex system in which doctor practices.

The intrinsic limits on the system’s ability, or appetite, to investigate the wider context of events came into sharp focus in professional discussions around the Bawa Garba case. There, it was held in the Court of Appeal that an MPT was fully entitled to consider systemic failings as part of the doctor’s personal mitigation.

Where a registrant’s conduct has not met the expected standard it is crucial to understand whether circumstances, outside of their control, impeded or foreclosed the possibility of those standards being attained.

Benefits for professionals and patients

The GMC’s innovation is welcome. It offers significant benefits for professionals and patients. The extent to which those benefits will be realised remains to be seen. Having seen the positive impact which awareness of Human Factors in the context of local investigations, this development is a cause for cautious optimism.

We are specialists at providing assistance and support to doctors at every stage of a fitness to practice investigation. If you would like to discuss these changes or any other related matters, please contact a member of our healthcare team.


This briefing is for guidance purposes only. RadcliffesLeBrasseur LLP accepts no responsibility or liability whatsoever for any action taken or not taken in relation to this note and recommends that appropriate legal advice be taken having regard to a client's own particular circumstances.

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