“Highly challenging, rapidly changing”: the GDC issues guidance for registrants during the pandemic

The GDC has released new guidance for registrants during the pandemic. The need for it partly arose from the wave of 22,000 registrants volunteering to be “redeployed” on behalf of the NHS. The guidance states that the GDC wants to “support registrants to take part” in redeployment. 

To this end, it stresses two principles that will apply during the pandemic:

• The regulatory burden on registrants should be minimised; and
• The flexibility for registrants to manage their professional activities in response to the pandemic should be maximised.

The guidance addresses some of the specific regulatory risks that have arisen. For example, redeployed registrants are at greater risk of working out of scope. Such registrants should preserve basic principles of patient safety, but otherwise can rely on their own clinical judgment "in what we appreciate is a highly challenging, rapidly changing environment”.

The guidance rightly prioritises flexibility over strict enforcement. It does, however, seem that there will be a need for new and effective regulation once the worst has passed. This is because coronavirus will pose a lingering threat until an effective vaccine or treatment is discovered. The GDC and other healthcare regulators will play a crucial part in managing that threat.

On the one hand, managing the threat may lead the GDC to place new emphasis on existing standards. For example, a failure to maintain hygiene becomes even more egregious if it exposes patients or staff to coronavirus. On the other hand, the threat could lead to entirely new requirements. For example, registrants could be expected to screen for early signs of coronavirus as part of the effort to stem further outbreaks.

The guidance is correct that now “is not a time for fitness to practice cases to be a distraction”. It is, however, never too early to ask how regulatory enforcement might evolve once the crisis abates but the threat remains. The need for answers promises new challenges for all healthcare regulators during a time of adversity and rapid change.