Annual Review of Competence Progression (ARCP)
Introduction
Scope of the Policy
Frequency of the ARCP
Panel Objectives
Composition of the ARCP Panel
Collecting the Evidence
How the Panel Works
Revalidation
Outcome of the ARCP
Additional or Remedial Training
Review of the Outcome 2
Appealing Outcome 3, 4 and Withdrawal from Programme
Introduction
Postgraduate Doctors in training are required to undertake an Annual Review of Competence Progression (ARCP) to demonstrate that they have obtained the necessary competencies to move to the next stage of their training.
The Annual Review Process is a formally defined process within the curriculum in which a trainee’s progress in the training programme is assessed and measured using a range of defined and validated assessment tools, along with professional and triangulated judgements about the trainees’ rate of progress.
Scope of the Policy
The ARCP policy is applicable to all trainees taking up appointments in Specialty Training within Severn and Peninsula Postgraduate Medical Education. This includes:
- Core Trainees (CT)
- Specialist Trainees (ST)
- General Practice Specialist Trainees (GPST)
- Trainees in combined Clinical and Academic training (ACF, CL)
- Less than full time Trainees (CT, ST, GPST, LAT)
- Trainees on Out of Programme (OOP)
It does not include Foundation Doctors (FY1 and FY2).
This policy is written to complement the process delineated in ‘A Reference Guide for Postgraduate Specialty Training in the UK (Gold Guide)’. It is recommended that trainees review the Gold Guide in addition to this policy.
Frequency of ARCP
All trainees in a training post will be required to undertake the ARCP process on an annual basis.
The trainees ARCP can be conducted more frequently if there is a need to deal with performance and progression issues outside the annual review.
The annual review process for trainees in less than full time training will take place at the same frequency as full-time trainees i.e. once per calendar year. The panel should take particular care to consider that progress has been appropriate to the training time undertaken, and that the estimated time for completing the training programme is reviewed.
Panel Objectives
The panel has the following objectives:
- to consider and approve the adequacy of the evidence and documentation provided by the trainee, which at a minimum must consist of a review of the trainee’s educational portfolio including a structured report from the educational supervisor(s), documented assessments (as required by the specialty curriculum) and achievements;
- to consider the time out of training during the assessment period and from entry to the programme (see GMCs position statement on time out of training) and determine whether training duration needs to be extended or not;
- provided that adequate documentation has been presented, to make a judgement about whether the trainee’s progress has been satisfactory and whether they can progress to the next level of training.
- to consider suitability to progress to the next stage of training or confirm training has been satisfactorily completed
- to provide advice to the Responsible Officer regarding Revalidation of the trainee.
Composition of the ARCP Panel
The composition of the panel must comply with the Gold Guide.
The panel should consist of a minimum of three panel members appointed by the training committee or equivalent group, one of which must be the Postgraduate Dean (or nominated deputy) or a Training Programme Director. Other appropriate members include:-
- Chair of Specialty Training Committee
- College / Faculty representative
- Educational Supervisors
- Associate Deans
Where more than one specialty is being assessed in the same panel (for example dual training or sub specialty training in parallel with main specialty training) or where the trainee is on an integrated academic programme, the panel will include relevant specialist/sub-specialist input.
The panel should have input from a lay member and external trainer who should review at least a random 10% of the outcomes and supporting evidence and any recommendations from the panel about concerns over progress.
Where academic training is also being assessed there should be a minimum of one academic representatives present on the ARCP panel, who should not be involved with the trainee’s academic programme.
Where it is likely that the trainee will receive an unsatisfactory outcome requiring an extension to the indicative time for completion of the training programme, the Training Programme Director should inform the relevant School Manager to enable, where possible, the Postgraduate Dean (or nominated deputy) to attend the panel.
Collecting the Evidence
Trainees will be given at least six weeks notification of the date of their ARCP. This will allow sufficient time for trainees to obtain structured reports from their educational supervisors.
Documentation must be received at least two weeks before the date of the ARCP. Trainees will not be “chased” to provide the documentation by the required date but should be aware that failure to do so will result in the panel failing to consider their progress.
Trainees must submit, as part of their documentary evidence for each annual review, an up to date Form R Part A, giving accurate demographic details for use on the database, and an up to date Form R Part B Self-Declaration for Revalidation.
How the Panel Works
The ARCP is not an assessment of the trainee but an assessment of the documented and submitted evidence that is presented by the trainee.
The panel should systematically consider the evidence as presented for each trainee against the specialty curriculum assessment framework and make a judgement based upon it so that one of the outcomes is agreed.
Trainees should not be present while the panel consider the outcome of the assessment.
Trainees may be requested to be present on the day of the review to meet with the panel after their discussion of the evidence, if required to clarify information, and to discuss the next steps and their future training requirements.
Where the Training Programme Director, educational supervisor or academic supervisor has indicated there may be an unsatisfactory outcome (Outcomes 2, 3 or 4) the trainee must be informed prior to the panel of the possible outcome and must meet with the panel after the panel has considered the evidence and made its judgement.
Panels will consider whether the core training programme end date or the provisional CCT/CESR (CP)/CEGPR (CP) date should be reviewed and adjusted, if necessary, taking into account such factors as:
- statutory leave, sickness or other absence of more than 14 (normal working) days in any year
- prior agreement with the Postgraduate Dean for training time to be paused (for the “clock to be stopped”)
- a change to or from LTFT training
- time out of programme for experience (OOPE), time out of programme for research (OOPR) or time out of programme for a career break (OOPC)
- rate of acquisition of competences that might bring forward the CCT date
- for dual trainees or trainees undertaking sub-specialty training alongside main specialty training, whether both should continue to be pursued
- the academic component of joint clinical/academic programmes
- failure to demonstrate achievement of competences (Outcome 3) as set out in the specialty curriculum
- failure to comply with the requirements for maintaining a training number
Revalidation
It is important to note that whilst ARCP and Revalidation are intertwined, they are not interdependent. ARCP outcomes should continue to be issued following the review of submitted evidence and are separate to the review of revalidation paperwork (except if paperwork is absent or late which will result in an automatic outcome 5).
The role of the ARCP panel in revalidation is to confirm whether there is any fitness to practise concerns which would affect the revalidation of the trainee, such as unresolved investigations, health or probity issues. This includes the WHOLE scope of the trainee’s work including locum work, voluntary work etc.
The information which is provided to the panel for revalidation is:
- Form R Part B – the trainee’s self-declaration for revalidation
- Wider Scope of Practice Form – if a trainee declares on their Form R that they are working as a doctor in areas other than their training programme, they must also complete a “wider scope of practice” form. The trainee must have this form counter-signed by their Supervisor in that area of work and have reflected on that work in their e-portfolio.
- Educational Supervisor’s Report – includes a question as to whether the educational supervisor is aware of any unresolved investigations, health or probity concerns which may affect revalidation (generally this question is now included within the e-portfolio, but if not, trainees are asked to provide a paper copy). The Educational Supervisor should also confirm that the trainee has reflected on any incidents in their e-portfolio.
- Exception Report – Trusts/Area Teams will complete an Exception Report with details of any incidents or complaints. They will already have informed the Responsible Officer if there are any current fitness to practise concerns about the trainee. The reasons for the panel to see this information are to ensure that the trainee has reflected and learned from any such incidents as part of the educational process, and to be aware of any investigations that are still open.
Trainees who have been out of programme during the review period of the ARCP need to ensure that they have collected suitable evidence to support revalidation. Please refer to the Revalidation Guidance for Trainees Taking Time Out of Programme for more information.
The key roles of the panel are:
- to review any involvement in incidents and complaints and ensure sufficient reflection and learning has taken place.
- to review the whole scope of practice and ensure sufficient evidence is recorded.
- to consider whether the panel is aware of any fitness to practise concerns which could affect revalidation.
- to state clearly on the outcome form if there are any ongoing investigations or other known concerns which may impact on a trainee’s fitness to practise.
- to complete the Revalidation section on ARCP Outcome Form
It is not the responsibility of the panel to make a recommendation for revalidation – this rests with the Responsible Officer.
Fitness to practise issues will be escalated to the Director of Medical Education and Head of School and be investigated either by the Trust HR department or the relevant Trust Clinical Governance process. Such concerns will also be reported to the Responsible Officer.
Outcomes from the ARCP
The outcome of the ARCP will be recorded on the ARCP Outcome Form.
The panel will award one of the following outcomes for each trainee:
Outcome 1: Satisfactory Progress – Achieving progress and the development of competencies at the expected rate.
Outcome 2: Development of specific competencies required – additional training time not required.
Outcome 3: Inadequate progress by the trainee – additional training time required.
Outcome 4: Released from training programme with or without specified competencies.
Outcome 5: Incomplete evidence presented – additional training time may be required.
Outcome 6: Gained all required competencies – will be recommended as having completed the training programme and for award of CCT or CESR / CEGPR(CP)
Outcome 7.1: Satisfactory progress in or completion of the LAT / FTSTA.
Outcome 7.2: Development of specific competencies required – additional training time not required LAT / FTSTA placement.
Outcome 7.3: Inadequate progress by the trainee – additional training time required LAT / FTSTA placement.
Outcome 7.4: Incomplete evidence presented – LAT / FTSTA placement.
Outcome 8: Out of programme for research, approved clinical experience or a career break (OOPR / OOPE / OOPC)
Note: OOPT must be an annual review and would therefore be reviewed under Outcomes 1 – 5.
The ARCP panel would not issue an outcome when the trainee is absent due to statutory leave: maternity leave or sick leave or where training has been suspended.
The outcome recommended by the panel will be made available to the following:
- Relevant Royal College or Faculty
- Training Programme Director
- Medical Director / Director of Medical Education
- The GMC
Where the documentary evidence provided is incomplete, no decision should be taken about the performance or progress of the trainee. The failure to produce timely, adequate evidence for the ARCP panel will result in an Incomplete Outcome (Outcome 5) and will require the trainee to explain to the ARCP panel the reasons for any deficiencies in the documentation. The ARCP panel should complete the supplementary documentation detailing additional evidence required and timescale for completion.
Where there is an unsatisfactory outcome (Outcomes 2, 3 or 4) the supplementary documentation for trainees with an unsatisfactory outcome report must be completed by the ARCP panel and made available to the parties listed in paragraph 8.4 above. The trainee must be given the right to review / appeal against an unsatisfactory outcome.
Outcome 2
Where a trainee is awarded an Outcome 2, the report must set out the specific competences the trainee must achieve and the timescales for this agreed with the trainee. The specific competences identified must be demonstrable and realistic objectives. It is not expected that the rate of overall progress will be delayed or that the prospective date for completion of training will need to be extended or that a period of additional remedial training will be required.
Outcome 3
Where a trainee is awarded an Outcome 3, an additional report indicating how a remedial programme will be delivered, the intended outcome and proposed timescales will be required.
The additional training must be agreed with the trainee, the employer and new trainers providing it. Full information about the circumstances leading to the additional training requirement must be transmitted to the employer, including any areas of weakness and any negative reports. The information will be shared with the trainee but agreement to it being shared with the employer and trainers is a requisite to joining the training programme.
Outcome 4
Where the trainee is given an Outcome 4, the trainee is released from the training programme if there is still insufficient and sustained lack of progress, despite having had additional training to address concerns over progress. The panel should ensure relevant competences achieved are documented. The trainee will be required to give up their National Training Number.
Additional or Remedial Training
The panel may identify the need for additional training time (Outcome 3) which will extend the indicative date for completion of the training programme. In the hospital and non-GP community specialties this will be up to one year within the total duration of the training programme (up to six months for core training and one year across both core and higher specialty training where the programme is uncoupled), and in general practice this will be up to six months, because of the shorter duration of the training programme.
Exceptionally this additional training time may be extended at the discretion of the Postgraduate Dean, but with an absolute maximum of two years duration in hospital and non-GP community specialties and one year in general practice, during the total duration of the training programme. This does not include additional time which might be required because of statutory leave such as ill health or maternity/adoption/paternity leave.
For a trainee working less than full time the extension to training will be on a pro-rata basis where training requirements for progression have not been met. However if an extension to training is required solely on the basis of exam failure then an extension will be on a fixed term basis and not pro rata.
Review of Outcome 2
Trainees awarded an Outcome 2 have the opportunity to request a review. Requests for a review must be made in writing and with supporting evidence to the Chair of the ARCP panel or a nominated alternative within ten working days of being notified of the panel’s decision. The trainee may provide additional evidence which must be received as part of the request for a review.
A further review (which may be virtual) by members of the original panel should take place within 15 working days of receipt of the request from the trainee. The panel should be quorate to change the outcome.
The decision of the panel following the review is final and there is no further appeal process.
Appealing Outcome 3, 4 or Withdrawal of Training Number
Trainees have the right to appeal if they receive an outcome which results in a recommendation for:
- An extension of the indicative time to complete the training programme (Outcome 3) or
- The trainee to leave the training programme with identified competences achieved, but without completion of the programme (Outcome 4).
- Withdrawal of the trainee’s training number
Trainees will be asked to indicate at the annual review panel that they understand the panel’s recommendation. Appeals should be made in writing to the Postgraduate Dean within 10 working days of the trainee being notified of the panel’s decision.
The request for appeal should specifically state the grounds for appeal. These may include: relevant evidence not being available to the Panel, concerns about the ARCP process, concerns about misinterpretation of facts.
On receipt of the appeal request the Postgraduate Dean will arrange a review of the original recommendation; this will follow process outlined for a review of an outcome 2.
Where the review panel does not alter the decision of the original ARCP panel, the Postgraduate Dean will confirm with the trainee that they wish to proceed to an appeal hearing and this will then be arranged.
Appeal Hearing
A formal Appeal Hearing should normally take place where practicable within 15 working days of the completion of the review.
Trainees may support their appeals with further written evidence relevant to the grounds of the appeal but this must be received at least five working days before the appeal panel meets so that the panel is able to consider it in detail. All documentation presented to the appeal panel must also be made available to the trainee.
Members of the original ARCP Panel must not take part as members of the Appeal Panel.
The Appeal Panel should include:
- Postgraduate Dean (or nominated deputy) as chair
- College / Faculty representative from outside NHS England working across the South West
- a Senior doctor within NHS England working across the South West and from the same specialty as the trainee,
- a Senior doctor from within NHS England working across the South West and from a different specialty to the trainee,
- a Senior trainee from a different specialty to the trainee,
- a lay representative.
A representative from the Human Resources Directorate of the employer or NHS England working across the South West will be available to advise the Chair on, for example, equal opportunities matters.
Administrative support should also be available to make a written record of the proceedings of the Appeal. A verbatim record will not be taken by the Administrator.
Trainees have a right to address the appeal panel. They may attend with a representative (e.g. a friend, colleague or representative from their professional body) or send a representative to the appeal in their place. Trainees must inform the panel within five working days before the appeal whether they wish to attend the hearing. They must also provide the name and status of any representative. Alternatively, if the trainee agrees, an appeal can be dealt with on written submissions. If a trainee wishes to be represented by a lawyer, then legal representatives should be reminded that appeal hearings are not courts of law and the panel governs its own procedure, including the questioning to be allowed of others by the legal representative.
The trainee and Appeal Panel members should be provided with the following documentation within five working days of the appeal panel hearing:
- Trainee’s written appeal
- Copies of evidence used at the original ARCP; i.e. Educational Supervisor’s report, report from Training Programme Director, assessments undertaken etc.
- Historical record of the trainee’s programme to date, including ARCP outcomes
- Evidence submitted by trainee in support of their appeal
Trainees will be notified in writing within five working days (where possible) of the outcome of the appeal hearing, with a formal report being provided as soon as is practicable. The decision of the appeal panel is final and there is no further right of appeal.