As a medical student, there are many hurdles which you have to cross. Each subject, each clinical attachment and each academic year will have its own exams or assessments, and each has to be completed successfully. With so many hurdles, it can be easy to lose sight of the first finish line; graduation and provisional registration with the GMC, allowing you to work as a doctor.
Provisional registration and licence to practise
Provisional registration (with a licence to practise) allows you to take part in an approved foundation year 1 (FY1) programme in the UK – the first step on your medical career for most newly qualified graduates. Although it is described as a foundation year, and most doctors do complete it within 12 months, you can hold provisional registration for up to 1,125 days.
All doctors working in the NHS need to be registered with the GMC and for most roles a doctor requires a licence to practise, issued by the GMC. This includes doctors in training. Your licence to practise allows you to carry out certain activities, such as prescribing medicines. The GMC’s medical register will publically list if you hold a licence to practise.
In your first year, you will gain further experience and competence which, on successful completion, will also you to obtain full registration with the GMC. The GMC outlines the knowledge, skills and behaviours FY1 doctors must be able to show before being eligible to apply for full registration.
Once you’ve met the outcomes, you will receive a certificate of experience, signed by an approved signatory. This certificate will enable you to apply for full registration with a licence to practise as you move onto the second year of the foundation programme.
There are limits on what you can do during provisional registration, outlined by the GMC on its website.
Fitness to practice
When you apply for provisional registration, several months before the end of your final year at medical school, you will be asked to answer some questions about your fitness to practice. It’s important to be aware of this from your earliest days at medical school. Things that could call your fitness to practice into question can happen at any time during, or even before, your student years.
For that reason it is important to be aware of your university and medical school’s conduct and fitness to practice policies and procedures. Although there will be general similarities, each school will have its own policies.
The GMC has also published guidance for medical students called Achieving good medical practice. This explains that, because your studies will bring you into contact with patients and others who may be vulnerable, you will be held to a different standard to students who have no such contact. It provides guidance across the core domains of Good medical practice, as applied to students, and also includes guidance on professionalism and fitness to practice processes in universities and medical schools. You should be familiar with and follow this guidance.
It is important to understand that the GMC considers ‘fitness to practice’ as meaning more than simply clinical competence, or achievement of educational standards. Fitness to practice includes matters of health and personal conduct and criminal matters such cautions or convictions. You will be asked about this, and about any university fitness to practice or similar process that you may have been subject to.
The GMC has provided comprehensive guidance to help guide you through the application process, designed to help you complete your application accurately, and breaks down all the information needed.
What you’ll be asked when applying for provisional registration
Here are some examples of what you’ll need to consider in the application.
Health conditions: the GMC only needs to know about health concerns that have led to a formal process or if you have a serious communicable disease. The GMC stresses that having a serious communicable disease, is not itself, a reason to have concerns about fitness to practise.
Declaring a caution, conviction or fixed penalty notice:
- A caution is an admission of being guilty of a criminal offence. It would show up on a DBS check. Not declaring a caution may be a more serious concern to a medical school than the original incident that resulted in the caution.
- In contrast, a conviction is verdict of a person being found guilty of a crime by a court. The GMC states that if your caution or conviction is protected by law in the UK, you are not required to declare it. You can find out more about protected cautions and convictions on the GMC website.
- Fixed penalty notices are issued by the police or Crown Prosecution Service for minor criminal or civil offences, such as parking and motoring offence, disorder or littering.
To illustrate the difference, consider the following. While you may not be required to declare all speeding offences, as road traffic offences where a fixed penalty notice has been accepted don't always have to be declared (fixed penalty notices related to other matters may need to declared), you would be obliged to declare a caution for possession of drugs, such as cannabis, even if it was before you started medical school.
It’s useful to know that doctors are exempt from the Rehabilitation of Offenders Act 1974 and may be required to declare some convictions indefinitely. Doctors also have an ethical duty to inform the GMC without delay, anywhere in the world, if they accept a caution, or are charged with or found guilty of a criminal offence (Reporting criminal and regulatory proceedings within and outside the UK, 2013).
If in doubt, its best to ask for help while you’re completing your application. You can get support from your medical school or from us if needed.
Medical school concerns: if your university or medical school has raised concerns about your professionalism or behaviour which led to a formal investigation, the GMC expects to be informed. However, this is only if an investigation took place, not if you were only issued verbal warnings.
You can find a full list of areas you can expect to be covered in the application process on the GMC website. The GMC has also created a helpful tool so you can work out what you need to declare when applying for registration.
Applying with honesty and integrity
The GMC expects that doctors act with honesty and integrity. This includes a requirement to compete forms (such as an application for provisional registration) honesty and completely.
The GMC can refuse an application for provisional registration if they discover that information that should have been declared has not been.
If they discover a similar omission after they have approved the application, they can open a fitness to practice investigation.
If you are unsure whether some information should be declared, such as university or medical school investigations into your conduct or fitness to practice, or whether a caution or conviction may be protected, you can seek advice from your medical school or contact us for support. If you remain unsure, it is generally better to err on the side of caution and tell the GMC at the outset, rather than be criticised at a later stage for having failed to do so.
Find out more about provisional GMC registration.
Find out more about the foundation programme.
Dr Edward Farnan
Medico-legal adviser
Dr Edward Farnan
Medico-legal adviser
MB BCh BAO LLM FRCGP DGM DCH DRCOG
Dr Farnan graduated from Queen's University, Belfast, in 1995 and completed his GP training in Northern Ireland, practising as a principal in general practice in Armagh for 11 years. He also sat on a research ethics committee, and had a particular interest in clinical governance.
See more by Dr Edward Farnan