Unfinished business - Proposals for reform of the senior house grade

Introduction

  

1. The Royal College of General Practitioners (RCGP) welcomes the publication of the review by the Chief Medical Officer for England of the status and structure of the Senior Health Officer (SHO) grade, which provides a major opportunity to improve the quality of education and training for general practitioners across the UK. In particular we welcome the proposals for a programme-based approach to training and the plans for a two-year foundation programme, followed by a number of broad-based and time-capped specialist training programmes. We are of the view that these proposals, if implemented, will change fundamentally how care is delivered in the NHS.
 
 
2. We would like to highlight the key issues for the College. They are:
 
  • The document gives scant regard to general practice.  It is mentioned approvingly as a venue for teaching and experience gathering for doctors intending a career in hospital medicine – but without exploration of the costs and implications for general practice.
     
  • The introduction of a two-year Foundation programme must not be used to reduce the period for specialist training for general practice.  Current College policy for specialist general practice training is five years.
     
  • There should be real equivalence between general practice and other specialties, not least in the implementation of this review.
     
  • The College gives strong support for the introduction of competency-based rather than time-based training and assessment.

3. Before we address our specific issues on the document, we wish to highlight the following more general points.

  • We welcome that generalism in medicine is recognised and valued in a way that has seldom been seen in a Department of Health report before. 
  • The document contains a formal statement about the desirability of giving all doctors some training in general practice, perhaps through “some” training in the second foundation year. Again, we welcome the use of the term “training”. This is a considerable advance on previous reports, which have tended to use the word ‘experience’.  
  • We are however, concerned about the lack of analysis within the document, on the implications for doctors intending a career in general practice or those opting for general practice during their SHO period. General practice appears almost as an afterthought.
  • While supporting the proposal that general practice is treated as an equal alongside other medical specialties, we are disappointed that the consultation paper has neglected to set out detailed proposals for the content or duration of GP training, but we recognise that this is an opportunity for the RCGP to fill in the missing detail and contribute fully to the debate. General practice is the branch of medicine that will be most involved in any proposed changes and will also be most affected by any changes. It is essential that the RCGP is fully consulted and that our views are recognised and incorporated.   
  • To re-affirm the case for general practice being seen as a specialty, we would draw your attention to the European Definition of General Practice / Family Medicine, which states:

“General practitioners/family doctors are specialist physicians trained in the principles of the discipline. They are personal doctors, primarily responsible for the provision of comprehensive and continuing care to every individual seeking medical care irrespective of age, sex and illness. They care for individuals in the context of their family, their community, and their culture, always respecting the autonomy of their patients. They recognise they will also have a professional responsibility to their community. In negotiating management plans with their patients they integrate physical, psychological, social cultural and existential factors, utilising the knowledge and trust engendered by repeated contacts. General practitioners/family physicians exercise their professional role by promoting health, preventing disease and providing cure, or palliation. This is done either directly or through the services of others according to health needs and the resources available within the community they serve, assisting patients where necessary in accessing these services. They must take the responsibility for developing and maintaining their skills, personal balance and values as a basis for effective and safe patient care.”

  • We strongly support the proposals to establish two-year foundation programmes followed by a single “run-through” grade for all specialties. We have, therefore, referred to specialty training programmes throughout our response, not to basic specialist training programmes. We would wish to see an early implementation of this “run-through” grade in general practice as this would address the issue of the current lack of higher specialist training.

  • We welcome the proposal that the foundation years should be more generally based with the implication that each programme contains at least one module in primary care. We hope that basic programmes will also contain community experience. We welcome a more general approach to learning for the majority of hospital based specialties leaving the more specialised areas to post CCST.

  • We also welcome the emphasis that is put on competency-based assessment. We welcome the opportunity for the RCGP to review the current assessment system for specialist training for general practice and to deliver a unified assessment system working in partnership with the deaneries. There does seem to a be need for external evaluation of current external assessments to ensure that they are fit for purpose and that the emphasis is on the values and attributes as described in Good Medical Practice as well as on knowledge and technical skills. 
     
  • The introduction of structured training and assessment for all training grades will have a significant impact on the workload of consultants and general practitioners. Shorter training will mean that there will be less time to learn through “osmosis” and there will need to be considerable interaction between trainer and trainee. We already have excellent examples. These have been set up through enlightened and enthusiastic teachers. Very often, these enthusiasts are placed under considerable personal pressure to ensure that these valuable training opportunities are preserved.

  • We would also wish to stress that there will also be a need for consultant and GP trainers to maintain their teaching skills. This will mean release from their clinical responsibilities. The result will be more effectively trained doctors with a guaranteed level of competence at CCST but there will be loss of face to face patient time by GPs and consultants.
  • The intention that all doctors should train in primary care is extremely welcome, however there is urgent need to expand existing training capacity. We welcome the attempts that have been made to relieve some pressure on general practitioners through nurse specialists and nurse practitioners. Training capacity might also be increased if we were able to appoint more clerical/secretarial support for trainers so that they were freed from paperwork.
     
  • The balance between workplace and MsoBodyText" align="justify">The document does not fully address the tension between delivering the service, ensuring the quality of training and meeting the European Working Time (EWT) Directive. Current SHO rotas are made compliant with EWT Directive through the addition of doctors working in almost identical posts which are not recognised for training. If all doctors prior to CCST are in recognised training posts there will be need for a greater number of post CCST doctors to work during evenings, nights and weekends.

4. We look forward to working closely with the Department of Health to reform the arrangements for training the GPs of the future.

Response to specific proposals
 
The five key principles should be the basis for reform of basic specialist
 
5. We strongly support the five key principles described in the report and would stress that these should be the basis of reform. We want to ensure that training for GPs is on an equal footing as that for all disciplines and therefore we refer not to “basic specialist or general practice training” but to “specialist training including specialist training for general practice”. We wish to emphasise the need radically to reorganise the training of GPs in order to meet the five principles. We believe that this report presents an opportunity to re-define GP training in terms of competencies achieved by training programmes based in primary care.
 
There should be sufficient opportunities for flexible (part-time) training.
 
6. We support the commitment to provide increased flexibility for trainees. This is important because of the high proportion of female doctors wishing to train for a career in general practice. Flexible training is funded through a separate stream and there needs to be a regular review to identify whether certain specialties are more popular and evaluate why this is so.
 
There should be access to early and regular career advice.
 
7. Regular career advice is essential from school through to retirement. We believe that additional resources are urgently needed in this area. Better careers advice coupled with a review of entry criteria for medical schools should allow better career planning and aid recruitment and retention. Deaneries should be supported to take this agenda forward and should become more involved in providing career guidance at undergraduate level. There may be considerable merit in having one national electronic site providing the majority of careers information with local sites as appropriate. There may also be a need for a national centre for specific careers advice, for doctors who have had difficulty in one particular area.  
 
After graduating doctors should undertake an integrated, planned two-year foundation programme of general training: the first year equating to the current pre-registration house officer year; the second (post registration) year incorporating a generic first year of current SHO training.
 
8. We support the proposal of the “planned two-year foundation programme’’. We believe that this programme would better equip trainees to develop generic skills and extend and consolidate the knowledge, values and attitudes set out in Good Medical Practice. We would also wish to stress our support for paragraph 3.13, which refers to “strengthening insights into the essential links between different specialties and between primary and secondary care.”
 
9. We would wish to emphasise that the general practice element of this programme is not optional. This is a programme of learning in general practice rather than for a career in the discipline, and this period of foundation training should not in any circumstances be regarded as part of the specific training programme for general practice. It follows from this that the beginning of specific training follows the two years of the foundation programme, and should have the same rules applied to it as is suggested for other specialties. The Foundation programme should build on not revisit then undergraduate programme and it needs outcome objectives built around competences.
 
10. We would welcome the requirement for all doctors to experience general practice during the second year of the foundation programme but recognise that there is not the infrastructure to deliver it at the moment. The educational experience of Pre-Registration House Officers (PRHOs) in general practice is excellent, but, problems have been identified because of the logistical difficulties. We recommend that in the short term an optional period in general practice is offered. In time, resources should be made available to extend capacity so that all doctors will gain a better understanding of primary care and an understanding of the patient’s journey within the NHS. The RCGP is committed to working with deaneries to ensure that this becomes a reality. We believe that deaneries are best placed to supervise and quality assure the programmes and the quality of the graduates from these programmes. During the two years there needs to be an assessment of competence to ensure full registration. At the end of the two years, all doctors should have received support and guidance to help them choose the most appropriate further training programmes.
 
11. We recommend that there should be an exit assessment towards the end of the foundation period, which is the same as the entrance assessment for overseas doctors. This could be a modified PLAB assessment. This would ensure that all doctors entering the second phase of (basic) specialist training would have achieved the same set of competencies. This also would help to remove any possible perception that overseas doctors may be of a lower standard to UK and EU graduates. An additional benefit would be that it would potentially introduce a national standard that could be used for monitoring the output of UK and EU medical schools.
 
After completing their foundation programme, doctors should enter a basic specialist training programme providing a breadth of education and training within certain broad clinical disciplines.
 
12. We believe that all doctors should move from the foundation programme to specialist training programmes, and these should include general practice. We support the proposal that urgent work is undertaken to explore, specialty by specialty, the appropriateness of creating a “run-through” training grade in which doctors would move seamlessly through training with satisfactory progress checks (see later). The RCGP is ready to support this initiative; work on how this could be achieved for GP training is at an advanced stage. Early implementation of the “run through grade” could offer the prospect of higher professional education for GPs which is sadly lacking at present.
 
13. We strongly agree with paragraph 3.38 “General practice should be regarded as a specialty equivalent to other specialties”. It is regrettable that this is not reflected across the whole document
 
14. The report envisages enough places for all SHOs completing foundation schemes and to accommodate some EEA and overseas graduates. We support this assertion but would recommend that a more radical review of workforce numbers is required to ensure that there are enough placements to meet the targets set out in the NHS Plan for England.
 
15. The review should take account of the need for GP training programmes at this level to be based in primary care rather than rotating through time-limited SHO posts which have historically provided poor educational opportunities for doctors training for general practice. We recommend that specialist training programmes for general practice are based in primary care while allowing exposure to an increased number of different secondary care environments which will help the trainees acquire the competencies that they will require in their future career as GP principals.
 
16. We also acknowledge the pressures there would be in maintaining the one-to-one ratio for training and that this may not longer be viable.
 
17. By absorbing existing ”Trust grade” posts into the new grade and reviewing the working practices of doctors in the new grade it should be possible to support innovative new ways of providing improved care to our patients, including covering acute admissions.
 
A limited number of placements on individual training programmes should be provided for those doctors requiring: remedial help; support in changing career direction; or who wish to re-enter training to prepare for competitive entry to higher specialist training.
 
18. We support the proposal to create a limited number of individual programmes designed to meet the specific training needs of individual doctors. They should be tightly managed by the postgraduate deans with clear entry criteria and regular assessment of trainees’ progress. However, we recognise the additional burden that this could place on deanery support structures. 
 
19. It is essential that a decision not to pursue a hospital specialist discipline is not seen as a route into general practice: we are very clear that training for any specialist discipline is not sufficient as training for general practice.
 
20. It is important that these programmes are tailored to the needs of the learner. They should support trainees experiencing difficulties or seeking to change career. Opportunities should also be made available to support doctors returning to training or practice and to facilitate entry of doctors into training programmes from elsewhere in the EU and overseas. For the latter group we recommend that all doctors entering the NHS should spend an induction period to orientate them to the NHS, help them identify their learning needs, obtain career guidance and to plan their future training and work. 
 
21. We also anticipate that individual programmes will be closely monitored both locally and nationally.
 
Following completion of a basic specialist or individual training programme, those trainees to progress directly to higher specialist training should be allowed a period of grace before leaving training.
 
22.  While we support the suggestion that programmes should be time-capped, the system must be flexible enough to reflect the needs of those training part-time or whose training has been interrupted due to illness or other legitimate reasons.  We do not believe that a “period of grace” might be granted to a doctor to enable him or her to organise transition to the next stage of professional development; appropriate management of programmes should ensure that there are not hiatuses where doctors are held up during their training waiting for jobs and programmes to be organised or advertised.  This is the standard in general practice and, if adopted in the hospital-based specialties should facilitate speedier entry into consultant/specialist posts.
 
23. Another consideration that should be taken into account is the difficulty a period of grace could cause in ensuring a single entry date to training programmes with subsequent loss of camaraderie and team spirit. Periods of grace may need to be undertaken in locations where there is need rather than preference.
 
Progress through programmes should be determined by assessment.In the longer-term assessment should move towards a competence-based system.The purpose of the Royal College examinations should be reviewed and a system of external accreditation introduced
 
24. We welcome the proposal that the new Post Graduate Medical Education and Training Board (PMETB) will become responsible for the accreditation of all training and assessment programmes currently organised by deaneries and medical royal colleges. We will continue to press the case for the necessity of RCGP involvement in the work of the PMETB
 
25. There is a need for development in the consultant and GP workforce in undertaking workplace assessment to a uniform standard.
 
26. We support the move to competency-based assessment throughout training and as evidence of its completion. For all medical specialties, including general practice, progress through training should be informed by success in accredited assessment programmes that have standards set by the royal colleges. It should be borne in mind that medicine is a profession with a set of professional values as set out in Good Medical Practice. It is frequently a matter of judgement whether a young doctor is adhering to those values.
 
27. The RCGP is committed to taking the lead in modernising the assessment system currently applied to specialist training for general practice. We have begun a review of the MRCGP examination and training programmes and will be working with deaneries, in anticipation of any standards for assessment programmes that will become policy of the PMETB. The aim will be to produce a single competency based assessment programme that is fit for purpose; work has also begun to prepare administratively for the demise of the Joint Committee on Postgraduate Training for General Practitioners (JCPTGP) and the establishment of the new PMETB.
 
Programmes should be managed by Programme Directors, appointed by, and accountable to, Postgraduate Medical Deans
 
28. We support the role of Postgraduate Medical Deans and their Directors of Postgraduate GP Education to manage GP training programmes in the deaneries. The deaneries already have an effective system for managing GP training programmes through their networks of associate advisers, course organisers and GP trainers. The current system is an appropriate model that could be adapted for other specialty programmes.
 
Trainers should be supported and trained
 
29. Trainers must be of the highest calibre and have adequate support. In specialist training for general practice a great emphasis has been put on the education of trainers and course organisers; it is only recently that hospital based education supervisers have had the same opportunities.
 
Key information on programmes: the arrangements for appointment and induction; the curriculum to be followed and the procedures for assessment must be made available to all traineesThe appointment arrangements to all programmes should be the responsibility of the postgraduate medical dean. They should meet published nationally agreed standards and practice
 
30. Postgraduate Deans should be responsible for the recruitment arrangements to all programmes: foundation, specialist and individual programmes, as they are now for PRHOs and specialist registrars. They should be managed to published national standards and they will need to ensure that NHS Equal Opportunities policy and sound employment practice prevail. It should be made clear that Directors of GP Education will run the general practice programmes on behalf of the Postgraduate Deans. A nationally coordinated system of matching may suit appointment to foundation programmes. The current model for recruitment to GP training programmes in England (and a similar one in Scotland) has proved successful and popular with trainers and trainees. Producing effective and appropriate detailed information, with arrangements for appointments and inductions is very important. Information on programmes including the arrangements for appointment, curricula and assessment procedures should be easily accessible on the Internet. Additional information on the number of applicants to previous programmes and availability of specialist and GP principal posts should be also made available to help medical students and young doctors plan their careers.
 
31. We support the notion of competitive entry to specialist programmes, but recognise that there will need to be better career guidance and support for doctors not admitted to their first choice programme. We also acknowledge that doctors’ choices of specialty may change during their training, so trainees must have the opportunity to move from one programme to another if their intended career proves not to suit them. The process of how they could investigate a possible career change must be made explicit. Information must also include details of the selection process for the new training programme and what targeted training would be available to support their transfer. The information must be realistic and the opportunities limited and managed by the Postgraduate Dean.
 
The SHO element of specialist training for general practice programmes should follow a similar model to those for hospital disciplines
 
32. We strongly support the recommendation that general practice should be considered as a speciality equivalent to other specialities. It is disappointing, therefore, that the document as a whole does not appear to be consistent with this statement. We welcome the opportunity to work with the Department of Health to ensure that the recommendation is realised. We commend the European Definition of General Practice/Family Medicine, published by WONCA Europe in 2002 as set out above.
 
33. General practice is not the combination of a range of specialties practised to a lesser degree. It has its own characteristics and is based on a thorough understanding of clinical medicine practised in the context of the physical, psychological and social environment of the patient. It therefore needs its own training programme to meet the curriculum. Some of the training will need to be based in secondary care, working alongside other SHOs. Exposure to the rare but important diseases is an important aspect of hospital training for general practice, but a greater proportion of the training posts will need to be based in primary care learning the specific skills of general practice.
 
34.  Equally, each broad speciality will need to develop its own curriculum and ensure that every trainee has the opportunity to experience a range of patient care to meet the curriculum.
 
35. If the model of the future is that all SHOs should experience a range of opportunities to meet the competencies of an agreed curriculum then general practice has an important part to play in the provision of these opportunities.
 
36. We agree that one of the specialty training programmes should be for general practice, but we disagree with the current scheme whereby two of the three year training programmes for general practice should be based in hospital. We do not support the proposal that the minimum requirement for specialist training should include any of the time spent in foundation programmes.
 
37. We recommend that general practice is treated equally with other specialties with a three-year primary care-based specialty training programme beginning after completion of the foundation period.
 
38. There continues to be a recruitment crisis in general practice; continuation of the status quo is not acceptable, and adoption of the proposal outlined in paragraph 3.41 of the consultation document could make it even worse. Many general practitioners completing their training feel unprepared for independent practice as a GP Principal. Many GP registrars extend their training by participating in innovative training programmes organised by deaneries. These initiatives are very popular. Early evidence indicates that extending the amount of time spent in the GP phase of training helps the trainees develop their skills and improve their confidence. These initiatives should also help retain the new GPs in the area that they trained.
 
39. We have started work to review the curriculum for GP training. As part of this initiative we are looking at different ways to deliver GP training in primary care drawing on the experience of the deaneries’ innovative schemes and training programmes from across the world. The aim is to produce new competency-based training and assessment programmes to better equip GPs with the knowledge, skills and attitudes required of a GP working in the NHS in the 21st Century.
 
The provisions for basic specialist training should ensure that the needs of non-UK qualified doctors are properly and fairly taken into account
 
40. We agree. The introduction of a modified PLAB test for all doctors towards the end of the foundation period and a compulsory induction period for overseas doctors would assist with this objective. There needs to be an appreciation of the career aspirations of these doctors many of whom appear to be “stuck” in Trust grade posts at the equivalent of the SHO level. This review should enable us to evaluate the situation of those doctors currently working in the NHS and help them to achieve their aspirations. For doctors wishing to enter the UK to work in the NHS, more accessible information on how to apply for training programmes and a more transparent mechanism for recognising their overseas training is required.
 
41. We welcome the review into the role of direct placement schemes. It is our view that this practice is contrary to the principles of competitive entry and transparency and should cease.
 
42. We also believe that the NHS has a moral duty to support the development of health care in less-developed nations. Specific training programmes should be organised that reflect the educational needs of doctors wishing to spend time training in the UK with the aim of equipping them with knowledge and skills to return to make a contribution to health care in their country of origin.
 
It is proposed that urgent work is undertaken to explore, specialty by specialty, the appropriateness of creating a ”run-through” training grade in which doctors would move seamlessly through training with satisfactory progress checks.  This could not be implemented immediately. Given the needs of the service and the availability of training places, the need for application and competition prior to progression should be explored
 
43. The RCGP is ready and willing to deliver a “run-through” training grade. While we recognise that ‘run-through’ programmes will need to be introduced gradually on a specialty by specialty basis, we believe that this is a significant opportunity to modernise GP training, to improve recruitment to the specialty and help deliver the NHS Plan workforce targets.
 
44. We would ask that there is a long-term evaluation of any changes. If doctors reach consultant even earlier they will need effective career pathways as consultants and support and development in their early years.
 
45.  We support the proposal that “provided that appropriately defined entry and exit points for each programme and means of assessing progress through the programme, it could become unnecessary to expect a doctor to change grade during a programme or to link a particular programme to a grade.”  We have initiated a review of curriculum and assessment procedures to support the move to the new system.  We are prepared to look radically at the current rules e.g. the need to have one trainer per GP registrar in order to deliver increased capacity quickly.  We are committed to working with the deaneries to deliver new GP based training programmes in accordance with any standards that will be introduced by the PMETB.
 
The arrangements for awarding a Certificate of Completion of Specialist Training (CCST) should be changed. New and shorter higher specialist training programmes should lead to the award of an earlier CCST for those satisfactorily completing training in the ”generalist” elements of a specialty. At that point a doctor should be able to apply for a consultant post in their chosen specialty – say general internal medicine or general paediatrics.
 
46. We support the proposal to shorten specialist training and to remove the term “Consultant” and replace it with “Specialist”. However, we would not wish to see this proposal used to re-introduce the Senior Registrar grade.  
 
47. Shorter, more general CCST programmes should be based in secondary care with release to tertiary and more importantly primary care to gain special expertise.
 
48. This proposal would bring the UK more in line with the EU. We would then be able to demonstrate that completion of specialist training for general practice would lead to the award of a certificate that is at the same level as other specialties and compatible with the spirit of the SHO reform document. While the length of the training programmes for any specialty should be flexible and determined by the ability of the doctor to acquire pre-determined competencies we recognise that the current situation where only one year is spent in the GP setting is inadequate. Reform and modernisation is required; this review should be the stimulus for that transformation.
 
A review of the role, educational support, professional development and career opportunities and pathways for non-consultant career grade doctors should begin in the autumn
 
49.  We support an urgent review of the non-consultant career grade.  There are many disillusioned doctors in this grade who do not have access to support for their continuing professional development.  They should be given the opportunity to develop and access targeted education and training programmes to facilitate their entry onto the specialist or generalist registers. This move would initially require additional resources, both financial and human, but it would contribute to patient care and help the Department of Health achieve the workforce targets set out in the NHS Plan.  The RCGP is committed to working with the deaneries to build on the success of the Trust-grade/SHO post conversion initiative to facilitate doctors through targeted training into general practice principal posts.
 
50. It is important to remember that this is not a homogeneous group of doctors. Some doctors prefer to work in a career grade without the responsibility of consultant status. Other doctors have not been able to enter their preferred speciality as a trainee and would prefer to work as a non-consultant career grade rather than move to a less popular speciality. It is also important to clarify which tier these doctors are working on.
 
Other Issues
 
Research
 
51. It is important that in reviewing the training of GPs, we do not forget the need to attract GPs into academic positions. We must ensure that there is flexibility in the new system to allow exposure to academic general practice. A number of the deaneries’ innovative schemes allow trainees to experience teaching and research while attached to academic departments. Attracting newly qualified GPs into academic general practice can help because combining academic and clinical posts can improve the recruitment and retention of young practitioners and involvement in education and research improves morale and should aid the retention of established practitioners.
 
Dentistry
 
52. There are many parallels with medical training both in the secondary and primary care arenas. We believe that dental training should follow a similar set of principles to medical training because there is considerable overlap of the educational and training processes.
 
Funding
 
53.  The report questions whether 100% of SHO salaries in England should be funded from the education levy, as is the present case for PRHOs and specialist registrars (and all grades in Scotland).  We believe that the Department of Health should ensure that all medical training grades should be 100% funded by the Multi-Professional Education and Training (MPET) levy.  The move would help to cut down bureaucracy, empower deaneries to ensure an appropriate balance between education and service.  It would also go a long way to address the imbalance between cash-rich Trusts in the South and less well-funded ones in the North of the country.
 
Timescale and implications for service provision
 
54. Any reform of SHO training will inevitably have an impact on service provision. We believe that improving the quality of training programmes should have a positive effect on service provision in primary and secondary care. The transition should be managed to maintain current levels of service provision, while in time moving to a new system for training in all specialties to deliver better-trained and better-motivated doctors more quickly. 
 
55. The introduction of the proposals will, however, coincide with the implementation of the European Working Time Directive. This will in itself be a major challenge. The proposals should free up thinking about how care is delivered by doctors and other health care professionals, act as a stimulus to change outdated work practices and to explore creative ways of working, making better use of the skills within teams. New training programmes should maximise opportunities to learn with other doctors training in other specialties and other professional groups.
 
Annex E
 
56. We would support the Postgraduate Training Programmes: principal pathways diagram. However, it should be amended to make clear that GP training must have three years after the foundation years. We would reject the use of the words “2 or” in the diagram. On the issue of Higher Specialist Training Programmes we would wish to see that there must be some, albeit small at first, programmes for general practice.
 
Conclusion
 
57. We believe that there is a big opportunity to make a real difference to how health care is provided by taking the opportunities offered by the reform of medical training. The RCGP is ready to work in partnership with the Department of Health, postgraduate deaneries, and our sister royal colleges to ensure successful implementation. However, as currently drafted, the proposals do not have sufficient regard to the discipline of general practice and its training structure. In particular, we believe that there needs to be a clear statement that any time spent by trainees in general practice during the foundation programme should not be eligible to be counted as part of specialist training for general practice.
 
Acknowledgments
 
We wish to acknowledge the work of the Chairman of the College’s Education Network (Professor Steve Field) in preparing this response, and also contributions from members of the Education Network Steering Group and from:- Dr Tina Ambury, Dr Justin Allen, Ms Mitzi Blennerhassett, Dr Elizabeth Brain, Dr Simon Brown, Professor Mike Carmi, Surgeon Rear Admiral Ralph Curr, Dr Christopher Hand, Professor Jacky Hayden, Mrs Eileen Hutton, Dr Bill Irish, Dr Helen Stokes-Lampard, Dr Tony Mathie, Dr Geoff Morgan Dr Catti Moss, Dr Orest Mulka, Professor Mike Pringle, Dr Bill Reith, Dr David Sales, Professor Dame Lesley Southgate, Dr Andrew Spooner, Dr Alastair Thompson, Dr Alex Williams and Dr Paul Wilson.

[1]The European Definition of General Practice/Family Medicine, WONCA Europe, 2002
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