BRITISH ASSOCIATION
OF PAEDIATRIC SURGEONS

RESPONSE TO THE CONSULTATION DOCUMENT:

PGMET: THE MEDICAL EDUCATION STANDARDS BOARD.

The British Association of Paediatric Surgeons welcomes the opportunity to comment on the proposed changes to postgraduate medical education through the Medical Education Standards Board (MESB). We regret the failure of the document to recognise the existence of the Specialist Associations, which play an important role in postgraduate training and education, both independently and through the Royal Colleges. It is clear that the Specialist Associations would be represented only indirectly on the MESB; nonetheless their existence must be recognised.

The case for change

We agree that there is a need to review and improve the present arrangements for postgraduate medical education and training (PGMET), but the argument for the radical changes proposed by the Government has not been substantiated. In particular, the comments about the past and current provision of PGMET are dismissive of the work done by the Surgical Royal Colleges and the Specialist Associations in setting and assessing standards in training, through, for example, the Joint Committee of Higher Surgical Training with the Specialist Advisory Committees or Boards, the Joint Committee for Intercollegiate Examinations through the specialist Intercollegiate Boards, and a national network of regional advisors and tutors. The high quality of British PGMET is recognised internationally and used by others, including Europeans, as a model of excellence. Reference to modern PGMET as an apprenticeship-based model reflects a lack of appreciation of the continuing process of assessment and development of PGMET by the Royal Colleges and Specialist Associations, to ensure that high standards are maintained and that training is relevant to the needs of the NHS. We support closer NHS involvement in PGMET, but not at the cost of compromising the excellence of the current arrangements.

The proposals

These changes are radical and will lead to a major upheaval in the provision of NHS services as well as postgraduate training and education. Nonetheless, we believe there are positive aspects of these proposals including:

  • The concept of an NHS University, provided that the educational mandate for this is honoured by ensuring a staffing ratio that allows service provision to be met as the prime function of the NHS, and at the same time ensures that training and education are surplus to the requirements of this service but are nonetheless identified as an additional workload for those involved in service delivery. If this is achieved, this will remove the current tensions between service delivery and training requirements. A positive factor in relation to this is the decision to transfer 100% of funding for training posts to Postgraduate Medical Deans.
  • We support the proposal to include the training and education of General Practitioners within the ambit of the MESB. In addition, developments that make it easier to change career path are welcomed.

The following are our comments on other proposals:

MESB membership – Whilst the overall size of the MESB is appropriate, there is a serious imbalance between medical and lay representation. With medical representation restricted to only twelve members, it will be impossible for the Board to work in a representative fashion. There will be under-representation geographically as well as in terms of the major representative specialties including general practice. We therefore recommend that 60% of Board members should be medical.

Although nationally a relatively small group, surgery has a high national profile both in the profession and with the public; we therefore believe strongly that the Surgical Royal Colleges, and through them the Specialist Associations, must be included on the Board.

It is not clear how and by whom Board members will be appointed. The process should be independent of Government.

We welcome patient representation on the Board.

To ensure openness and independence, the Chair of the MESB must not be a lay appointee but should be elected by the Board.

Accountability: The proposed line of accountability of the MESB to Ministers and Parliament places the Board directly under the influence of the Secretary of State for Health. This leaves the Board vulnerable to political priorities, and could aggravate service / training tensions. The Board should be responsible directly to Parliament, preferably to a cross-party committee.

Funding: The suggestion that the MESB should be self-funding is unrealistic. The achievements of the current system have depended on significant support from charitable funds and voluntary contributions by surgeons in a wide variety of ways. The proposal to review the central funding of the Royal Colleges could compromise their ability to function effectively.

Standards: It is proposed that the Colleges will continue to play a major role in undertaking SAC visits and in setting examinations. However, the ultimate arbiter would be the MESB, thus potentially undermining the present independence of the Royal Colleges and their ability to make effective criticisms where this is due.

Giving priority to the needs of the NHS risks undermining standards of training. The adverse effects on service delivery of withdrawing training recognition could be avoided if there was separation between service delivery and training. It is acceptable that the NHS has a central role in training but not the overall control envisaged in the new arrangements.

The possibility of the MESB interfering with the independence of the GMC is a cause for concern. See paragraph 65 and 69, where it is suggested that the Board will be able to require the GMC to register a doctor on to the appropriate register.

Mode of operation: There is very little detail about the committees supporting the MESB, outlined in the flow-chart.. There must be a defined role for the Specialist Associations in this matrix.

Quality assurance: We propose that the Audit Commission is the appropriate body for independent external quality assurance of the MESB.

Summary We believe that the public trusts the profession to maintain high standards of training and care, and recognises the strong commitment of surgeons to the well being of their patients. The independent role of the Royal Colleges and Specialist Associations in setting standards is fundamental to this trust.

Our principle concerns with the draft proposals are:

  • Failure to recognise the contributions of the Specialist Associations.
  • Inadequate medical representation on the MESB.
  • Accountability to the Secretary for State, which would lead to overall Government control and leave PGMET and certification subject to political priorities.

There is a risk that perceived problems with training are held responsible for service deficiencies due to inadequate resources; equally, service shortcomings should not be addressed by compromising standards of training. Adequate funding of both NHS service and training is essential.

We acknowledge the need to review PGMET, and are willing to participate in constructive discussions to take this forward.

David Lloyd
President
The British Association of Paediatric Surgery

22nd January 2002