THE ROYAL COLLEGE OF SURGEONS OF ENGLAND

Response to the Department of Health consultation document entitled Postgraduate Medical Education and Training: The Medical Education Standards Board

‘The Royal College of Surgeons of England is an independent professional body committed to promoting and advancing the highest standards of surgical care for patients’

Mission Statement of the College

The Royal College of Surgeons (RCS) response to the principles of the consultation document are set out below. Specific issues raised by the document are discussed in Appendix 1.

1. CASE FOR CHANGE

The RCS does not accept the assertion that postgraduate medical education is “not fit for purpose”. The RCS regrets the failure to recognise the dynamic and enthusiastic developments in the delivery of education and training that have been, and continue to be made by the Royal Colleges of Surgeons and the Specialist Associations. Details of our contribution are set out in Appendix 1.
The RCS would welcome the NHS “having a say” in the training of doctors. However, it wishes to point out that all those who work voluntarily on behalf of their College as Tutors, Advisors, Council members, or on Government and other committees, practise daily as surgeons in the NHS. They are closely in touch with the realities, are neither isolated nor remote, and their contribution is highly cost effective. Had advice from this College regarding trainee and consultant numbers, and facilities in surgery been acted upon, the current problems in service provision, and its inevitable impact on education and training would not have arisen.
The RCS accepts the need for some improvement to the present arrangements, and agrees that a single Board replacing the Specialist Training Authority (STA), including responsibility for training and certification of General Medical Practitioners (GPs) as well as Hospital Doctors is desirable (although no evidence is presented). However, such an arrangement would enhance the NHS and its Executive’s understanding of the inevitable conflicts between the maintenance of standards and the quality of training and service provision. It would also enable better co-ordination between the different agencies that have responsibilities for the delivery of training and service.
The RCS acknowledges that, in trying to ensure that satisfactory training standards are achieved in a hospital service that has been poorly resourced and understaffed for years, it has made recommendations that have affected local services. This is not however regarded as sufficient justification for threatening College autonomy and authority, and risking the destabilisation of postgraduate medical education.

THE FUTURE REGULATION OF POSTGRADUATE MEDICAL EDUCATION

There is a need to bring general practice into a common structure for training and to ensure that the planning of postgraduate medical training relates to the requirements for service provision.
It is essential that those responsible for setting standards, and their delivery, and those responsible for service provision discuss the often complex and conflicting issues that arise in a system that is acknowledged by all to be short of both doctors and facilities.
It is essential that there are clear lines of accountability and responsibility.
The RCS supports meaningful patient involvement in a reorganised system of postgraduate training and education and has demonstrated this through its well-established Patients Liaison Group.
The RCS would however reject any proposal that places under political control the responsibility for setting the standards for the clinical care of patients and the education, training and examination of the next generation of surgeons. This is a professional responsibility trusted and respected by both public and profession and should be formally delegated, if not statutorily accorded to the Colleges.
If the declared intention is to strengthen and give more executive power to a reconstituted STA to co-ordinate and ensure that standards are both set and met without diminishing the autonomy and influence of the Medical Royal Colleges, then the RCS would support the development of a “Postgraduate” Medical Education Standards Board.
The RCS considers that the proposed size of the Board is appropriate, but that it should have a medical majority (i.e. 60% medical and 40% lay) and preferably a medical chairman. Furthermore the Board should be appointed by the Appointments Commission in a way that ensures adequate representation of major stakeholders. The Board should elect the chairman.
The RCS believe that accountability for the work of the Medical Education Standards Board (MESB) should be open and transparent. This would best be achieved by reporting direct to Parliament rather than to Government, or where appropriate the equivalent bodies of the Scottish Parliament and Northern Ireland and Welsh Assemblies. This would provide the public with a much greater sense of accountability than if the MESB were accountable to Ministers and so avoid the inevitable conflict of interest between service and training.

3. CONCLUSIONS

Patients and the public trust the profession to maintain high standards of education, training and care. The profession and this College in particular have a proven track record of this for over 30 years (Appendix 1). Although professional bodies need to work closely with the NHS, there must be safeguards against the temptation for Government (of whatever complexion) and the NHS to compromise overall standards and quality of training for financial or political reasons.
To establish a Medical Education Standards Board, as proposed in the consultation document, functioning along the lines suggested would so radically change the structures and processes for postgraduate education and training of surgeons that it risks destabilising the whole process. This would lead to a further fall in morale risking a deterioration in both medical training and patient care.
The RCS would however support a Board with responsibility for the education and training of General Medical Practitioners and formally delegated, preferably statutory, authority given to the Medical Royal Colleges for professional matters of training and standards of practice. It would need to have the authority to ensure that Colleges were meeting defined standards of training and education.
The RCS values its current lay input into the work of the College. The RCS looks forward to engaging in constructive dialogue to develop a robust and realistic future structure and strategy for training the next generation of NHS and Academic surgeons, which carries the confidence and trust of both patients and the profession.
The RCS is not prepared to give up its well deserved delegated statutory rights, from STA, for determining which surgical trainees have completed their education and training to a standard which allows a Certificate of Completion of Specialist Training (CCST) to be awarded so qualifying them to apply for appointment as consultant in the NHS.
The RCS will be communicating its response to its Fellows and Members, and to the Public.

Sir Peter Morris
President
1.03.02