Strategy and Policy Board, 1 December 2015 Agenda item: 3 Report title: Devolved Office Review Report by: Rachel Podolak, Head of Welsh Affairs, Strategy and Communication, [email protected]02920 495 363 x5251 Considered by: Directors’ meeting Action: To consider Executive summary This paper provides a high level summary of the recent Moore Stephens Review of the Devolved Offices and lists the strategic questions arising. An action plan is included for consideration. Recommendations The Strategy and Policy Board is asked to: a Consider the findings of the Moore Stephens Review Report, at Annex A. b Consider the strategic questions arising. c Approve the proposed next steps and action plan, at Annex B.
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Strategy and Policy Board, 1 December 2015
Agenda item: 3
Report title: Devolved Office Review
Report by: Rachel Podolak, Head of Welsh Affairs, Strategy and Communication, [email protected] 02920 495 363 x5251
Considered by: Directors’ meeting
Action: To consider
Executive summary This paper provides a high level summary of the recent Moore Stephens Review of the Devolved Offices and lists the strategic questions arising. An action plan is included for consideration.
Recommendations The Strategy and Policy Board is asked to: a Consider the findings of the Moore Stephens Review Report, at Annex A. b Consider the strategic questions arising. c Approve the proposed next steps and action plan, at Annex B.
Strategy and Policy Board, 1 December 2015 Agenda item 3 – Devolved Office Review
2
Background
1 Since establishment in 2003 (Scotland) and 2005 (Wales and Northern Ireland), the Devolved Offices have largely grown organically. The scope of the offices has expanded to support a much wider portfolio of colleagues and teams as the GMC’s role and size has expanded and diverging policy issues emerged in each country. Alongside this, the way the GMC works in each country via the Employer Liaison Service (ELS) and Education QA teams has also changed. Their activities have been described as ‘multi-dimensional’ and the political systems that they monitor and operate within are complex.
2 Apart from a small internal review in 2008, there has not been a strategic review of the offices to date. This Review was commissioned by the GMC to better understand how, given the changes noted above, each of the Devolved Offices were aligned to GMC strategy and business plans. This was achieved by:
a A series of semi-structured interviews and visits to each office.
b A review of current work and operating procedures in the context of the GMC corporate strategy and business plans.
c An internal and external stakeholder survey to understand current experiences and future needs/ expectations of each office.
3 The Report of the Review is at Annex A.
Findings
4 The Review found that:
a 97% of external stakeholders reported that the Devolved Offices were successful in achieving their purpose. This suggested that external stakeholders were satisfied that there was harmony between what they perceived to be the purpose of each office and what the office was achieving, for example, ‘having a credible link between the stakeholder and the GMC’, and for ‘building relationships’. This was supported by the internal stakeholders’ responses which suggested that the key purpose of the offices was to ‘promote standards’, ‘raise awareness’, ensure consideration of the political landscape and listen to key interest groups.
b Stakeholders have indicated that there has been limited reporting to Council on Devolved Office activities, one stakeholder commenting that reports appear as ‘one GMC operating in one health structure’. It is expected that appetite for four country information, ways of working and reporting will continue to increase as a direct result of our work on SoMEP, Data Strategy, National Training Survey,
Strategy and Policy Board, 1 December 2015 Agenda item 3 – Devolved Office Review
3
discussions driven by Council, the success of the UK Advisory Forums and the divergence of the health and political systems across the UK.
c More work is being devolved to be managed/supported locally by the Devolved Offices. While positive and in line with an increasingly devolved health system, this raises questions about the sustainability of current ways of working, the associated resource model and the need for improved succession planning.
d Each office should introduce its own risk register in line with the new GMC risk management framework.
Strategic questions arising
5 The Review highlights operational issues that the Devolved Offices will take forward with the support of the Director and Assistant Director for Strategy and Communication.
6 However, it also raises key strategic questions for consideration by the wider GMC:
a Does the GMC sufficiently understand what it means to be ‘relevant’ in each country and is it clear on the accountability, responsibility and authority of the devolved offices and how this aligns to stakeholder expectations or perceptions? Is the GMC sufficiently mitigating the risk of being perceived as ‘London-centric’?
b Are the Devolved Office goals clear and are they linked to purpose and desired impact? What will be the impact of moving to a four-country regulation model, on existing structures and how would the Devolved Office strategy and plans fit within this approach? (This linked to the observation of a lack of ‘England’ office/function).
c Is there sufficient reporting on the four-country dimension internally and to Council?
d What is the GMC’s operational model for supporting its activities in each country? Does meaningful information exist to understand the risk of not being joined up, in fact as well as appearance, in each devolved country?
e Is there an opportunity for Devolved Offices to be involved in new projects and initiatives from an early stage in order to provide relevant country specific input and to enable their anticipation of work and resource planning?
f What opportunities exist to provide country specific information and data for public consumption?
Strategy and Policy Board, 1 December 2015 Agenda item 3 – Devolved Office Review
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Next steps
7 Subject to the Board’s approval, the proposed next steps include:
a To share the final Review Report with Council.
b To instigate an evening seminar with Council in advance of devolved country elections in 2016.
5. Highlights from the internal stakeholders responses 23
6. Appendices 26
General Disclaimer The content of this report is confidential and not for distribution to anyone other than the GOC. Disclosure to third
parties cannot be made without the written consent of Moore Stephens LLP.
Confidential 2 GMC DO Review 2015
1. Executive Summary
Introduction
This engagement was commissioned by the GMC to better understand how each of the devolved offices was aligned
to GMC strategy and business plans. This was achieved by:
ascertaining how each devolved office operates on a day to day basis through a series of semi-structured
interviews and visits to each office
current work and operating procedures in the context of the GMC corporate strategy and business plans
the purpose which underpins activities
an internal and external stakeholder survey to understand current experiences and future needs/ expectations
of each office.
In the intervening period since this work was commissioned there have been a number of internal discussions and a
paper submitted to the Council away day recognising the ongoing debate about devolution across the UK, and the
integration of health and care as well as devolution powers to English cities following the example of Greater
Manchester1. In the context of the findings of this review, where appropriate, this report acknowledges and in some
places refers to these discussions.
Internally the offices are referred to as the devolved offices (DO), although in practice they are very much part of the
whole. The offices are not in fact devolved or decentralised as the term perhaps suggests, but are satellite offices of
the GMC that are strategically located in each devolved country. For this report the term ‘DOs’ is used
interchangeably with ‘offices’.
It is not the intention of this report to recommend changes to the DOs or question whether they should exist at all. The
results of this review indicate there is a significant degree of support for and value gained from the offices. Where
observations have arisen, these have been framed as key questions for the GMC to consider and are summarised in
section 2. Main findings are reported in section 4, and the questions arising are also embedded within the narrative
report. Highlights from the survey completed by internal stakeholders have been provided in section 5. Section 3
outlines the approach taken to the review.
This report is supported by a separate pack for each DO which draws together key themes from the interviews held
with various stakeholders and summary highlights from the external stakeholder and DO staff surveys.
“Background to the genesis of GMC in Northern Ireland, Scotland and Wales”2
In 1999 the rollout of devolution began in Northern Ireland, Scotland and Wales. Healthcare policy was devolved to
each country with healthcare professional regulation also fully devolved to Northern Ireland. As a result, the GMC
commenced operations in a Scottish Office in late 2003. The Welsh and Northern Ireland offices followed in early and
late 2005 respectively. This made the GMC the first, and still only, UK wide healthcare regulator with a physical office
and staff in each UK country.
Since establishment the offices have largely grown organically. The scope of the offices has expanded to support a
much wider portfolio of colleagues and teams as the GMC’s role and size has expanded and diverging policy issues
emerged in each country. This included the addition of postgraduate education and training, the introduction of
revalidation, reform of the fitness to practise procedures and greater use of GMC data as new areas to support.
Increased focus on direct engagement with doctors and patients has also placed additional demands on the offices.
Apart from a small internal review in 2008, there has not been a strategic review of the offices to date. The offices are widely credited as paving the way for the establishment of the Employer Liaison Service across the
UK and more particularly the Regional Liaison Service in England. Unlike these services the Devolved Offices did not
have significant support in advance to design models, processes and systems.”
1 Agenda Item 2, Council Away day, 1 - 2 July 2015 2 This quoted section was provided by the Heads of DOs as a summary of the office journey
Confidential 3 GMC DO Review 2015
.
Sitting within the Strategy and Communication Directorate, the offices have grown from one or two people in each
location to a total of 14 staff across the three locations. Their activities have been described as ‘multi-dimensional’
and the political systems that they monitor are complex. Table A indicates the relative size of the register across the
devolved countries, data relating to the public purse and local offices3.
awareness of the role and functions of the GMC, ensuring
the views of key interest groups figure in the development
of policy and guidance.”
“To reflect local issues, by having a credible link between
the stakeholder (usually senior colleagues and decision
makers) and the GMC. Being in country sends an important
signal."
“Picking up local intelligence from an operational and
political point of view.”
“Build effective relationships with key stakeholders [in each
country].”
“Ensure consideration of full political landscape of the UK
taking into account specific sensitivities.”
“To be a local point of contact, to act as a listening point.”
“Ensuring a consistent UK message/ voice and that
views/different experiences across the UK are fed into our
decision making and policy thinking.”
“Being the ‘human face’ of the GMC, a communication
conduit.”
“Ensuring good relationships with key interest groups.” “Without a local presence would run the risk of being too
Westminster focused.”
Confidential 10 GMC DO Review 2015
External affairs and risk management
Engaging with the profession,
patients, medical students and educators
Operational support of all
GMC directorates in country
Overall, the responses to the surveys were positive about the value that each office brings internally to the GMC and
to external stakeholders. Internal stakeholder responses include the value of having strong relationships, strong
communication skills, and helping avert potentially difficult situations.
Chart 3
We asked external stakeholders How
successful did they see the devolved
office being in having fulfilled its
purpose? Out of 32 responses only one
individual answered ‘not successful’ and this
was in the context that the individual
interacted directly with the GMC in London
and not the local office.
Overall external stakeholders reported that
the devolved offices were successful in
achieving their purpose(s). This suggests
that external stakeholders are (in the main)
satisfied that there is harmony between what
they perceive to be the purpose of each
office and what the office is achieving, for
example, “having a credible link between the stakeholder and the GMC”, and for “building relationships”. This is
supported by the internal stakeholders responses which centre on “promotion of standards”, “raising awareness”,
ensuring consideration of the political landscape and listening to key interest groups.
Purpose and priorities
Purpose should also be linked to the activities needed to achieve desired impact, and for the offices this appears to
relate to ‘supporting patient safety and good medical practice’ as a result of having a relevant and physical presence,
helping the GMC fulfil its statutory role, and providing intelligence and advice internally.
Their purpose translates in to three broad categories or work streams as per the annual plans (see Figure 1).
Elsewhere (GMC website) presents ‘our’ priorities for being in each country (see Table D).
Figure 1 Table D
Do you think the devolved offices have been successful in fulfilling their purpose?
Successful
Unsuccessful
Neutral
Raising awareness of the role and functions of the
GMC
Ensuring the views of all key interest groups are
considered in the development of our policy and
guidance
Monitoring developments in health policy, legislation
and structures in each country
Liaising with the Scottish Parliament, Northern Ireland
and Welsh Assemblies regarding changes in medical
regulation
Providing a point of contact for all interest groups
The roll out of the GMC’s Welcome to UK Practice
Programme
Confidential 11 GMC DO Review 2015
The GMC’s priorities for being present in each country appear activity focused, while the purpose (see above) and
work streams per the annual plans (Figure 1) which drive day to day office activity appear quite broad. The purpose
and workstreams are a reflection of the offices activities today, which have expanded organically and reactively (this
point is discussed in the next section).
While there is likely to be synergy, there is merit in conducting an exercise which aligns the priorities as published on
the website to the offices work streams per the annual plans; it may provide insight into whether or not the offices are
doing more or less than what was originally intended.
Purpose and goals
The strategy and plan for each office appear to follow the following thought process (see Figure 2):
Figure 2
What is not clear is the reflection of the directorate’s goals, the goals5 for each office, and risk identification. Goals, by
their very nature, can be of longer term, and should link to purpose and desired impact.
We have worked on the assumption that there is proper cascading of the GMC’s strategic aims to the directorate
goals and in turn, the goals of the DOs, which supports objective-led activities. Such an approach helps mitigate the
risk of the offices becoming ‘orphan offices’ or ‘going native’ (identified by some internal stakeholders as a risk). This
leads to the following key question:
KQ1. Are the Devolved Office goals clear and are they linked to purpose and desired impact?
Purpose and relevance
The purpose of the devolved offices clearly states that they ‘ensure that the GMC continues to be a relevant and
physical presence in Scotland, Wales and Northern Ireland’.
A small number of stakeholders commented on being relevant in each country. The risk of being perceived as
London-centric is a real one (this point is discussed elsewhere in this report) - some external stakeholders observed
that accountability, responsibility and authority of the offices was not clear, that there is perhaps a perception of
reliance on the centre to agree GMC’s position on important matters. This last point relates to the degree of
(perceived and actual) autonomy that the offices have in relation to decision making on a day to day basis which is
also linked to relevance. The implication is that relevance in each country is undermined as decisions are controlled
via the centre. This raises the following question:
KQ2. Does the GMC sufficiently understand what it means to be ‘relevant’ in each country and is it clear
on the accountability, responsibility and authority of the devolved offices and how this aligns to
stakeholder expectations or perceptions?
5 Goals are, by definition, observable and measurable with an end result and supported by having one or more objectives to be achieved within an agreed timeframe.
Purpose WorkstreamsGMC
Strategic aims
Priority projects Objectives
Projects/ Business as
usual
Confidential 12 GMC DO Review 2015
Strategy, planning and risk assessment
Healthcare professional regulation model
The GMC’s strategy is underpinned by the purpose that it exists to help protect patients and improve medical practice
across the UK. This is set out in its Corporate Strategy (2014-17) and provides the starting point for developing the
individual DOs plans which are discussed below. The Corporate Strategy is UK wide and does not reflect a four
country approach.
There is recognition and understanding internally that because of increased divergence in the health and care
systems between the four nations within the UK, there are impacts on GMC’s ability to demonstrate a UK wide
approach to regulation. There is also increasing recognition internally for the need to be nuanced, and GMC’s
response to divergence to be nuanced.
During Council’s away day (July 2015) members were invited to consider a paper on the ‘future shape of regulation’
and in particular asked to consider ‘healthcare professional regulation in the devolved context’. There is a likelihood
of Scotland asking for healthcare professional regulation to be devolved, and the paper reflects that Wales could
follow. Internal debate confirms that there is an appetite to move to a four-country healthcare professional regulation
model, and this is supported by Council driving the expectation that information reported to them should have a four-
country dimension, which includes impact and data analytics by country.
As part of the move to a four-country regulation model the GMC will need to consider the impact on its current
organisational structure and the positioning of England within this model alongside Northern Ireland, Scotland, and
Wales. While the devolved nations each have GMC representation via the offices, in contrast England does not. The
‘England response’ is absorbed within the GMC’s current set-up, primarily through the teams within London and
Manchester. A move to four-country regulation raises the following questions:
KQ3. What will be the impact, if moving to a four-country regulation model, on existing structures and how
would the DO strategy and plans fit within this approach?
Devolved office strategy and plans
Each office has, through an annual office strategy and plan that is underpinned by the directorate plan, made a
commitment to contributing to the achievement of all 5 strategic aims, though it could be challenged as to whether or
not this needs to be the case and is appropriate. While there is no requirement to share plans outside the directorate,
one internal stakeholder indicated that they did not have sufficient sight of DO plans to enable them to understand
their planned workload and others have commented that they recognise that there is increasing demands on the
offices. Sharing the DO plans (and in our opinion vice versa) with key internal stakeholders would enable early and
useful conversations with colleagues about planned activities. It would also enable each party to understand the
reasons for pursuing initiatives that have impact in each country. The GMC should consider the following question:
KQ4. Do internal stakeholders have sufficient sight of the DOs plans (and vice versa) to enable a robust
conversation about workload priorities and enable more effective planning?
How the existing annual plans are broken down
Within the plans the offices have set out a number of objectives against priority projects (these are not the same as
the GMC priorities for being present in each country as mentioned above). The priority projects are a reflection of
wider GMC activities for which each office provides local support and the objectives are a reflection of planned
activities. Table E illustrates the high number of priority projects and objectives the offices are working with in 2015.
Confidential 13 GMC DO Review 2015
Table E
Northern Ireland Scotland Wales
Number of priority projects 13 12 13
Number of objectives 34 32 35
Objectives should be a reflection of what needs to be achieved and the timescale in which it should be achieved. This
is broadly clear within the plans for each office, although could be better defined in terms of how objectives will be
measured and by when.
Each plan also contains an overview of ‘business as usual and project support’ activities which are mapped across
the GMC directorates. From the manner in which they are outlined it is not clear which activity is business as usual
and which is project support, nor in their present layout are they linked to objectives or priority projects. However, it is
clear that these activities form part of the workstream ‘operational support of all directorates in country’ (as outlined in
Figure 1). Table F shows the scale of business as usual and project support activity (as outlined in the annual plans)
across the GMC.
Table F
Northern Ireland Scotland Wales
Strategy and
Communications
29 28 26
Education and Standards 22 22 23
Fitness to Practise 9 9 9
Registration and
Revalidation
5 5 5
Operations 9 7 8
OCCE 4 3 4
Internal stakeholders recognise the demand on the DOs time and both stakeholders and the offices themselves gave
a sense of them ‘doing too much’. This is supported by the number of objectives committed to by each office, in total
101, while still supporting business as usual and project support activities that may be driven by teams across the
GMC. It is not clear whether this approach or the scale of business as usual and project support provided
operationally is sustainable for the offices.
KQ5. Is the current workload and way of working sustainable for each office? Risk assessment in planning
The 2015 DO plans do not identify risks to their achievement. It is evident that the DOs are increasingly working in
complex environments, with multidimensional perspectives, and risks are included within the Directorate risk register.
However, risk assessment should begin when plans and objectives are agreed at all levels within an organisation,
without this formal step in the process there is a risk that the offices are not fully considering the impact and likelihood
of risks materialising. This highlights the need to consider:
KQ6. Is there visibility and understanding of the (internal and external) risks to achieving the DO plans?
Confidential 14 GMC DO Review 2015
Future planning
Adopting a different approach to developing the annual plan could provide a more effective platform for operational
activity. This would involve using the existing alignment of the GMC’s strategic aims to the DOs priority projects, but
introducing the directorate’s goals, and the development of the DOs goals. This would support the alignment of the
GMC’s priorities with the DOs for being in country, and provide a clear foundation for the development of ‘work
streams’ and activity-led objectives, risk identification and management, and a reflection of the performance
indicators or measurements the office will use to determine success in achieving objectives and ultimately goals. This
model is outlined in Figure 3.
Figure 3
Priorities (per GMC intention)
Office goals
Work stream 1
Work stream 2
Work stream 3
Activity led-objectives and
risk identification
KPIs/ measurements
GMC Strategic Aims and Directorate Goals
Devolved office purpose
GMC projects/ Business as usual
Risk management
Confidential 15 GMC DO Review 2015
Operational activity
Day to day activities
The DO teams have perceived a lack of understanding by the rest of the organisation of what they actually do rather
than what they think they do - this is not borne out by the survey results or the interviews. Generally there is a good
understanding of the value that the teams bring internally, but there may be additional benefit to gain by increasing
internal engagement with others across the GMC.
Examples of the offices’ day to day activities include:
monitoring external affairs and political healthcare landscape,
maintaining relationships with key external stakeholders,
engagement with doctors and patient groups,
helping the GMC manage risks around consistency and relevance of its communications and policies,
arranging and hosting GMC events,
providing operational and facilities support to visiting GMC staff, and
dealing with or redirecting enquiries.
Day to day operations are managed through regular DO meetings, activity planning and monitored regularly through
dashboards. Various logs are in place to capture engagement, communications and activities. There are monthly
communication meetings, meetings with directors and key staff from around the organisation are invited to attend
meetings with the DOs. Each office has developed their own office manual for administration and day to day office
maintenance, although have common processes or procedures.
The offices have agreed a portfolio approach to ensure coverage of the different directorate activities. This means
that on a monthly basis, the DO Heads and officers engage in regular meetings with relevant directorates. This
approach helps the DOs with sharing workloads while maximising efficiency. It also provides an opportunity to share
the work of the DOs and ensure their role and activity is understood.
As there are a number of common activities across the offices there may be further opportunities to gain efficiencies.
The DOs should consider:
KQ7. Is there an opportunity to further streamline some of the systems and processes that underpin and are
common to each office?
Internal drivers of activity
Some of the offices day to day operational activity is driven from the centre. For example, there are initiatives to
improve the GMC’s communication with its stakeholders, so there is an increase in the number of communications
that are driven by the Strategy and Communications Directorate’s priorities and cross directorate policy initiatives. For
the devolved countries the offices are pivotal to ensuring that all of these are targeted and handled appropriately.
It is important therefore that the DOs are engaged early enough in conversations on policy and communications that
may have an impact on each country. Criticism was raised that the DOs often arrive to the table when decisions have
already been made and equal frustration on the part of the DOs that they are an ‘after thought’ in policy and
communication development. This supports the view (highlighted through interviews with a small number of external
stakeholders) that policy is possibly driven by England’s priorities and do not necessarily take into consideration the
political systems of the other three countries until it is time to be implemented. A four-country dimension would mean
that divergent health and care systems would be considered at the start of planning initiatives. The GMC and the DOs
should consider:
Confidential 16 GMC DO Review 2015
KQ8. Is there an opportunity for DOs to be involved in new projects and initiatives from an early stage in order
to provide relevant country specific input and to enable their anticipation of work and resource planning?
Risk management implemented
Some risk management activity is evident through the weekly monitoring mechanism and there is consideration of
risk through the use of RAG ratings for different activities (e.g. risk areas raised as part of weekly reporting versus
stating the health of a stakeholder relationship), but the offices do not maintain individual risk registers.
GMC’s Risk Management Framework endorses the position that visibility of risks (including inherent risks which are
discussed elsewhere in this report) should be at all levels of operational activity. Without risk registers:
KQ9. How effective are the DOs in identifying and managing their (internal and external) risks?
Non DO activities within each country
External stakeholders also interact with other key GMC services. Interviews and survey results confirm the value of
these interactions.
Central teams have assigned country leads, and activities in each of the devolved nations may stem from different
drivers, e.g. FTP, Revalidation, Education and Standards. While these activities are not the responsibility of the DOs,
they may be involved or partake in some activities that are priorities for the regulatory directorates. The DOs
engagement has also changed with the introduction of the clinical fellows and more recently liaison advisors.
The offices work with each of the directorates and provide operational support where necessary, although some
activities will be independent of the DOs involvement. The offices are keen to be kept updated of GMC activities and
meetings occurring in their relevant countries of responsibility. Some of these activities will be instigated by the DOs
or by London or Manchester staff. Whilst less frequent now, in the past there have been criticisms that the DOs were
not sighted on key meetings within the devolved countries.
A lack of coordinated approach in each country increases the risk of not being joined up and emphasises directorates
working in silos.
Introducing an operational model for each country (including England) will support a four-country approach – and may
be a matter of formalising ‘joined-up’ operational delivery in each country. Practically, this may involve formal
structures around how services work with each other, and at country level, extending the use of the intranet for
internal stakeholders (another survey comment), and using the GMC website for relevant signposting for external
stakeholders (for example the Memorandum of Understanding with the Care Quality Commission has a long list of
‘whom to contact’ and ‘for what’, something similar for the DOs could be useful). It would help the GMC to identify:
KQ10. What is the GMC’s operational model for supporting its activities in each country?
Confidential 17 GMC DO Review 2015
Engagement
How external stakeholders are engaged with
External stakeholders have indicated that they may engage with the GMC in a variety of ways; informal and formal
meetings with members of staff in the DOs, finding out who to contact within the GMC via the offices, through the
Quality Improvement Framework, regular face to face engagement with the ELAs, sharing of information and
involvement at the UK Advisory Forums (UKAF) are a few of the examples given. Many external stakeholders
commented positively on the accessibility of the Chair and Chief Executive at the UKAF events.
Stakeholders commented on the GMC in each country as well the GMC as an organisation. A few stakeholders
indicated engagement was also directly with the GMC in London or Manchester which was in addition to contacts with
the DOs. One stakeholder indicated very little or no engagement with the DO due to direct links with the GMC office
in London. A small number of stakeholders indicated their preference to go directly to the DOs, which supports the
value they place on the relationships established.
With the addition of the new post of liaison advisors (LA) in each office, which will replicate the Regional Liaison
Service (RLS) in England, direct engagement with customer groups will grow. The addition of the LAs will enable the
model of engagement to align with the RLS in England. A perceived criticism from one stakeholder was that the roll
out of the LA arrangements was 3 years behind the RLS model, and implied a lack of investment in the devolved
countries.
This review highlights the importance of understanding the relationships that each office has with its external
stakeholders. Each office has identified its stakeholders and indicated the ‘health status’ of the relationship. However,
the wider strategy behind these relationships is not clear. For example, what is the risk behind a relationship that is
assessed as ‘red’? How should this be managed? By whom and how will it be monitored during the year?
The importance of understanding the strategies behind relationship management becomes increasingly important
when engagement with the same stakeholder may occur through different teams across the GMC (which is discussed
above). Different engagements raise the risk of not appearing joined up in terms of messages and consistency (as
raised above) – this was commented on by a small number of internal stakeholders, and raises the following
question, which should be considered alongside question 11:
KQ11. Does meaningful information exist to understand the risk of not being joined up, in fact as well as
appearance, in each devolved country?
How engagement is captured
The offices have developed processes around capturing engagement, and also use the GMC’s Relationship
Management System (RMS) to capture contact. At least one office mentioned that detailed contact notes are not
maintained, while another office, in comparison, does maintain more detailed notes. Additionally, RMS has been
described as ‘clunky’ and not user friendly, it is therefore unlikely to be used to its full potential.
Different spreadsheets have been developed for different projects or purposes although are underpinned by a
common principal, to capture engagement. Each office maintains a number of different spreadsheets for capturing
different types of activities. This is discussed above, under the operational activity (see question 8).
Confidential 18 GMC DO Review 2015
Impact
When external stakeholders were asked what the offices do well, words such as engagement, networking,
relationships, supporting the introduction of revalidation, liaison, and communication were used. However, in contrast
one stakeholder indicated that while the GMC sends an important ‘signal of wishing to be a UK body, there is a risk of
perceived tokenism [with the office in country] while the organisational centre of gravity remains in [London]’.
Discussions with a small number of external stakeholders supports this view, particularly that there is a sense of
some policy decisions being driven by England priorities. This has been raised elsewhere in the report, and requires
the following consideration:
KQ12. Is the GMC sufficiently mitigating the risk of being perceived as ‘London-centric’?
Demonstrating impact
During the visits the question of whether the GMC via the offices was achieving impact, and how this was captured
was tested. The GMC gathers meaningful data and intelligence, and is putting in place systems to allow better
sharing of information internally. However, there is a view that this still needs to be filtered at country level. For
example, the State of Medical Education in Practice (SoMEP) report was commented on as being useful by external
stakeholders, but only when it was broken down by the office for the specific country. There is an appetite for
information that is relevant for each country – there was an overarching comment that ‘more local information would
be better, and would help bodies inform their own strategies’.
KQ13. What opportunities exist to provide country specific information and data for public consumption?
The level of engagement achieved across all key groups during 2014 are outlined in Table G.
Table G
England Northern Ireland Scotland Wales
Doctors and trainees 15,536
(7.8%)
524
(7.8%*)
21
(0.1%)
323
(3.1%)
Medical students 11,005
(34.1%)
938
(69.2%)
2,428
(48.9%)
1,437
(78.2%)
Patients and public 821
(0.00%)
73
(0.004%)
239
(0.004%)
550
(0.02%) *percentage engagement within each country
There is very little information available on outcomes and impact in each country as a result of DO activity. While
engagements are key (and this is confirmed through the survey results and interviews), the quality of the outcomes
and the resulting impacts of these are not captured. A proportion of the offices’ engagement with stakeholders is
driven by GMC central activities in developing policy, guidance and communications so there is no requirement for
DOs to monitor impact. However, the offices are in a good position to understand outcomes and impacts and we
would encourage this to be explored:
KQ14. Is there an opportunity for the DOs to engage in monitoring of impact that is driven by central activity, or
monitoring their own impact?
At the office level there is an appetite for understanding impact across the different stakeholder groups. This could be
achieved by using logic frameworks for planning programmes of engagement. See Figure 4 for a simple logic
framework as an example.
Confidential 19 GMC DO Review 2015
Figure 46
6 Taken and adapted from BOND, Networking for International Development: Logical Framework Analysis
Purpose
What is the project [engagement] going to achieve?
Activities
What activities will be carried out to achieve [the engagement's]outputs and purpose?
Resources
What inputs are required (e.g. finance, people, time etc.)
Risks
What are the potential problems which could affect the success of the [engagement]?
Success
How progress and ultimate success of the [engagement]will be measured and verified?
Confidential 20 GMC DO Review 2015
Reporting
The offices report in a consistent manner, and provide periodic updates on engagement and communication, on an
individual basis as well as collectively.
The content of weekly reporting includes a retrospective look at activities completed, and a forward look at expected
activities. The content centres around projects, business as usual and ‘core functions’. There is also a section for
‘current hot topics’ and risks or issues to note which include a ‘red-amber-green’ rating. The weekly reports feed into
the Directorate’s business plan reporting.
For 2014, the content of the updates was around engagement summary (doctors and trainees, medical students, and
patients and public), feedback summary from doctors and students, top 5 requested sessions and issues affecting
doctors in [country]. These are mostly output driven activities.
The updates in 2015 have changed to Headlines for [period], Engagement including promoting professionalism,
Public and external affairs engagements, and Operational support. The 2015 content is aligned to the three ‘work
streams’ that stem from the DO’s purpose, and outline activity and outputs completed. However, these are not linked
to the objectives of each office.
While the reports show the degree of office activity, these do not provide the added value and quality of the
engagements held and activities completed by the DOs. This observation also links to reporting of impact which is
discussed in the previous section. There is perhaps a question over meaningfulness of the information reported.
KQ15. Do the DO reports provide sufficient information over the quality and added value of engagements or
activities, and/or the achievement (or progress towards achievement) of DO objectives per their approved
plans?
Stakeholders have indicated that there has been limited reporting to Council on DO activities, one stakeholder
commenting that reports appear as ‘one GMC operating in one health structure’. It is expected that appetite for four-
country information is increasing as a direct result of discussions driven by Council, and the potential to move in the
direction of a four-country approach.
KQ16. Is there sufficient reporting on the four-country dimension internally and to Council?
Confidential 21 GMC DO Review 2015
Staffing
The offices have experienced momentum, they have evolved organically from one or two persons in each office, and
are now better resourced in terms of office space, staff numbers, IT support etc. They represent less than 1% of the
GMC budget, and have grown in size and depth of activities.
Resource planning
The DOs have a coordination role which interfaces and performs as a point of contact internally. The role is presently
embedded as part of an existing staff role and will rotate between the offices. There is a ‘wish list’ for a dedicated
resource to take on the coordination role. However, there is not sufficient information available about time required for
and spent on different activities that would warrant an additional role. This raises the question of whether resource
planning is underpinned by work planning, and if there is sufficient clarity over time spent on different activities.
KQ17. Do the DOs have clarity over resource planning that is driven by their annual planning and planned work
programme?
Capacity
There is an emerging question to ask about the capacity of the DOs to manage an increasing number of projects, the
time required and tools available to monitor effective use of resources. It may be helpful for the offices to undertake
an exercise which compares ‘person hours available’ to ‘person hours needed’ to cover all expected activities and to
introduce a simple time recording tool to help understand how much time is spent on different activities, to support
annual and quarterly forward planning. This could also inform discussions on resource planning when considering
workload.
KQ18. Is there sufficient information available to understand whether the DOs can sustain the current level of or
an increase in work activities?
Small offices come with inherent risks, and this includes having single points of failure where significant reliance is
placed on key individuals, or where key individuals possess knowledge and experience which cannot be easily
replicated, or a combination of these factors. The risk of single points of failure increases when there is insufficient
consideration of succession planning.
Additionally, as a satellite office, which by fact is remote from the centre, there is a risk of ‘going native’ – this was
commented on by a small number of stakeholders.
The DOs are exposed to these risks and therefore the following key question arises:
KQ19. Is there sufficient thinking around succession planning for each office?
Confidential 22 GMC DO Review 2015
[BLANK PAGE]
Confidential 23 GMC DO Review 2015
5. Highlights from the internal stakeholders responses
Total number of respondents: 23 Overall response: positive
Themes from the responses: The feedback was positive. It is clear that the DOs provide significant value to individuals that are engaged
but their objectives could be more clearly communicated to the wider organisation.
The DOs have a lot of demands on their time and can be limited by resource in their small teams.
As a UK wide regulator the DOs have an important role in developing local knowledge and driving important
local relationships that may not have been achieved from England only.
Highlights from the feedback include:
The role of the DOs: They promote the GMCs standards and position. They also pick up local intelligence from an operational
and political point of view.
To ensure we consider the full political landscape of the UK and ensure we have taken into account
legislation in all four countries and specific sensitivities.
Providing a two way link between the GMC and the devolved legislatures.
Raising awareness of the role and functions of the GMC, ensuring the views of key interest groups figure
in the development of our policy and guidance.
Ensuring we have a consistent UK message/voice and that views/different experiences across the UK are
fed into our decision making and policy thinking.
Ensure that we have good relationships with our key interest groups.
Contribution to the GMC achieving its objectives: Increased our influence and impact with key stakeholders, their presence is in itself a manifestation of our
commitment to our role as a UK wide regulator.
Ensuring the organisation is compliant with local standards.
Allowing us to effectively respond to the wider devolution agenda.
Championing the GMC’s UK-wide objectives and profile.
Promoting professionalism and working to influence policy.
At a practical level they have provided meeting facilities and support.
Discharging their objectives: Instrumental in supporting and embedding political change.
The DOs provide a means of engaging with both senior members of the healthcare system and politicians.
Confidential 24 GMC DO Review 2015
Highlights from the feedback include:
The development and roll out of Revalidation is a good example, as it had to reflect the differences in
healthcare structures and political supervision in each of the four countries.
Through developing strong relationships with key stakeholders that we would be unable to maintain from
London.
Very effective, and will become more so with the additional resources allocated.
Really effective and seem to work effectively with the Employer Liaison Service which also works in the
devolved country.
Priorities going forward: Two way stakeholder engagement.
Developing important networks and managing who takes the lead, whether from London or the relevant
DO.
Ensuring greater collaboration and joint working across the four countries.
Informing the organisation's response to greater devolution.
Deepen our knowledge of the national/regional landscape.
Promoting the GMCs standards and being champions for patient safety.
Engagement / interaction with the DOs: This can be difficult as the DOs appear to have their own set agenda/objectives and therefore resources
are allocated to these objectives and not, at times, available for other work or support.
I really value my involvement with them. We enjoy a very positive, open and mutually supportive working
relationship.
My personal relationships with my DO are excellent and I am made extremely welcome whenever I visit
the office or telephone colleagues there.
On the whole positive. This can depend on DO capacity which is influenced by the sheer range of GMC
matters which the offices have to cover and to some extent the strength of the staff's relationships with the
people and knowledge of the issues that Standards may want to engage with.
I’ve always found the teams in the devolved offices to be very approachable and keen to work with us on
delivering facilities services.
We are working on a framework to provide guidance on how we work together and on what.
Added value to internal stakeholders:
Strong local knowledge, perspective and sound advice.
Strong communication skills.
Close personal relationships.
Dealing with potentially difficult situations which has adverted more serious issues.
Challenges in working with DOs: Resource: time / capacity.
Lack of input into DO year plan.
Clarity of local stakeholder management activities- right person for right subject matter.
Ability to see the bigger picture.
Sometimes lack of clarity or disagreement about distribution of work between two teams.
What would you like to see the offices do differently? Have a stronger voice in our communications and engagement planning activity.
Possibility of carrying out more operational activities (with appropriate staffing levels).
The January training course was excellent – could we mainstream this into induction as an e-learning
module?
Share more information, and in a timely manner with the ELS and other individuals across the
organisation.
Be more cost focused and commercial.
Confidential 25 GMC DO Review 2015
Highlights from the feedback include:
Is the role of the devolved offices sufficiently understood? There are colleagues who just don’t know about the DOs work and it is everyone’s responsibility to see
that we are a UK wide regulator.
The roles are not sufficiently clear.
We're all too busy working in our own areas to understand fully what others do. But once you engage with
the team there is no doubt as to the value they add.
The DO's are often seen simply as satellite offices and their impact on key statutory functions is unclear.
The Employer Liaison Service is well aware of the role and the benefits of the DOs.
Probably only with those members of staff who come into direct contact with the devolved offices as part of
their work.
What could be done differently to improve internal engagement with the DOs:
The AD responsible for the devolved offices and the offices are very good at championing their work. I
would like to see the teams having more opportunities to do so in both the London and Manchester Office.
This needs to be driven largely by the teams in Manchester and London, rather than the staff at the DO’s
having the sole responsibility to “make themselves known”.
More regular updates on topical issues – e.g. through policy network.
Presentations at the corporate induction or a roadshow to Manchester / London.
Effective use of the intranet.
Confidential 26 GMC DO Review 2015
6. Appendices
The following stakeholders invited to participate in the survey
External Stakeholders
Name Organisation
Regulation and Quality Improvement Authority
BMA Northern Ireland
NI Confederation of Health & Social Care
NI Medical and Dental Training Agency (NIMDTA)
Pharmaceutical Society of NI
DCMO
RCGP (NI)
RCPCH (NI)
Queen’s University Belfast
Patient and Client Council
NI Social Care Council
Healthcare Improvement Scotland
BMA Scotland
NHS Education Scotland
NSS
GpHC Scotland
Scottish Government
RCPE
Dundee
Board of Academic Medicine
PASS
The Alliance
Glasgow Medical School
MDDUS
General Dental Council
Healthcare Inspectorate Wales
Confidential 27 GMC DO Review 2015
Name Organisation
BMA Cymru
NHS Confed
Wales Deanery
GPhC
Welsh Government
Royal College Physicians
Cardiff University
Academy of Royal Colleges Wales
Swansea University
Welsh Community Health Councils
Royal College of GPs
Internal Stakeholders
Name Directorate
Chair
Council Member
Council Member
Council Member
Chief Executive
Chief Operating Officer
OCCE/OCCO
OCCE/OCCO
OCCE/OCCO
Strategy and Communications
Strategy and Communications
Strategy and Communications
Strategy and Communications
Strategy and Communications
Strategy and Communications
Strategy and Communications
Strategy and Communications
Standards and Education
Standards and Education
Standards and Education
Standards and Education
Confidential 28 GMC DO Review 2015
Name Directorate
Standards and Education
Standards and Education
Standards and Education
Standards and Education
Standards and Education
Registration and Revalidation
Registration and Revalidation
Registration and Revalidation
Registration and Revalidation
Fitness to Practise
Fitness to Practise
Fitness to Practise
Fitness to Practise
Fitness to Practise
Resources and Quality Assurance
Resources and Quality Assurance
Resources and Quality Assurance
Moore Stephens LLP, 150 Aldersgate Street, London EC1A 4AB T +44 (0)20 7334 9191www.moorestephens.co.uk
DPS29853
Strategy and Policy Board, 1 December 2015
3 – Devolved Office Review
3 - Annex B
Devolved Office Review action plan
Strategy and Policy Board, 1 December 2015 Agenda item 3 – Devolved Office Review
B2
Report Question
Action Owner Timescale Notes
Risk training undertaken and logs created for each office DO Under way Training delivered by Moore Stephens 3/9/15 Risk logs underway
Improved analysis of DO dependencies by Directorate for 2016 Business Plan - DOs approaching directorates for confirmation of requirements
DO/Directorates Under way Some directorates originally noted no DO dependencies, DOs checking this
DOs developing updated operating model (one for three nations)
DOs Under way
Updated to include new Promoting Professionalism provision, risk logs and soft intelligence sharing
DO representation on Data Strategy working group, commitment to 4 country thinking across Data Strategy work-streams
DOs/S&C Under way Noting DO Head time commitment of 23.5 days in 2016
Update DO section of Corporate Induction to demonstrate integral part of S&C and overall corporate strategy/commitment to 4 country working
DOs/S&C Under way New version of corporate induction session introduced in October 2015
Regular briefings by DO Head for DO country Council Members
DOs/Governance Under way Meetings re-introduced in 2015
Review Governance templates/guidance for more prominent prompts for 4 country thinking on all policy or project board documents
DOs/Governance Under way Meeting scheduled with Governance Team to discuss
Strategy and Policy Board, 1 December 2015 Agenda item 3 – Devolved Office Review
B3
Report Question
Action Owner Timescale Notes
Council evening seminar/informal session on DO Review and devolved political/regulatory context. Consideration of what parts of our business need to be a. UK only b. tailored to country and c. country specific.
DOs
Short term* To be agreed
Audit of DO representation on key policy making/project groups and boards with AD and Director of S&C to ensure appropriate cover/representation
Short term
Consider establishing regular DO link and update to Directorate leaderships teams as per R&R and Education & Standards
S&C and Directorates
Short term
DO representation (via Assistant Director – Strategy and Communication) on 2016 SOMEP editorial Board to assure 4 country commitment
Short term
CI review of DO office manuals and operational processes DOs (and CI Team)
Short term DOs already undertaken CI training – early 2015
New template to be used for DO 2016 business strategy and plan summary pack to ensure clear link between strategic purpose, priorities and desired impact
DOs Short term
2016 business strategy and plans shared with key contacts across directorates once finalised
DOs
Short term
DO input to 2016 Impact Report to assure 4 country proofed
DOs
Short term
Ongoing tracking/monitoring of demands on DOs linked to resourcing
DOs
Short term
• Short term = End of 2015 – first 6 months of 2016
Strategy and Policy Board, 1 December 2015 Agenda item 3 – Devolved Office Review
B4
Report
Question Action Owner Timescale Notes
HR led review of succession planning risks/issues/options for DOs
HR
DOs
Medium/ long term*
Review of “England” question/issue as a commissioned review with the Audit and Risk Assurance function and Moore Stephens
COO
Medium/ long term
Possible combined review with A&RA function with MS leading as per DO Review
Review of how all GMC work organised across countries for effectiveness and efficiency