News & Features — 29 March 2014 at 3:20 pm

The AM Guide to the new GMC APS Rules

Matt Wilkes / Adventure Medic Editor


The rules have changed since 1 June 2014. Please visit our Updated Guide for the latest information.


As many of you will know, the General Medical Council has recently ruled that new doctors, or those returning to the specialist register, must work in an Approved Practice Setting until after their first revalidation. This potentially has big implications for the expedition and event medicine community. If the number of emails we have received on the subject is anything to go by, plenty of you are already concerned about the consequences for your practice. Ever your humble servants, Adventure Medic has been liaising with the GMC to answer some of your questions. Please note that these rules are very likely to change in the near future, but this is the current GMC position. We’ll keep you updated.

Do the new rules affect me?

To find out if the new rules affect you – please use our handy flow diagram. Start at the top left. The first question about Nationality is a little confusing. If you are a British Citizen, then you are not an EEA National, so answer ‘yes’ and carry on down.

The Adventure Medic Guide to the New GMC APS Rules

Do the rules apply to voluntary work as well as paid work?

The GMC says / The requirement applies to any work where the doctor is exercising the privileges of a licensed medical practitioner.  There is no reason why a doctor who is subject to such a requirement cannot volunteer at events, as a first aider for example.  Such a role will not usually involve any activities that are reserved by law to registered and licensed medical practitioners.

Do the rules apply to teaching, as well as treating patients?

The GMC says / As above, the requirement applies to any work where the doctor is exercising the privileges of a licensed medical practitioner.

Do the rules still apply if the doctor is working abroad but for a UK based company?

The GMC says / The requirement applies to practise undertaken in the UK. Practise abroad will be subject to local regulation requirements.

Is it possible to get early removal of the APS requirement for those who cannot at present undertake the work they wish to?

The GMC says / There is scope to disapply the requirement to practise in an APS, but for that to happen the applicant would need to provide us with robust, objective evidence as to how patient safety will be ensured if the requirement is not applied. The requirement has been disapplied in cases where an applicant new to full registration is eligible for entry to the GP or Specialist Register.

Can you bring forward your revalidation date?

The GMC says / There are circumstances in which we will consider bringing a doctor’s revalidation submission date forward.  Any doctor wishing to bring forward their revalidation date should discuss this first with their responsible officer as it is their responsibility to make sure that they have sufficient information to recommend that a doctor is up to date and fit to practise.  Our Guidance for Revalidation Decision Makers on Changing a Submission Date, includes examples of these circumstances, as well as the criteria we will use to decide whether to change a doctor’s date. When we revalidate a doctor earlier than their original date, where applicable, the APS requirement will be lifted from their registration.

How easy is it for an organisation (say, an events company) to get APS status?

The GMC says / To gain recognition as approved practice setting an organisation must be a designated body. It must also be subject to independent regulation, for example through registration with the Care Quality Commission and must be able to satisfy us that it meets the APS criteria detailed on our website.

Are these rules likely to change anytime soon? They have big implications for a number of our readers.

The GMC says / Yes. This is an area being actively internally reviewed by the GMC as it has implications for event medicine, expedition medicine and prehospital care. We will let you know of any changes as and when the occur and the system is likely to be made much more flexible from the end of April. For more information, please have a look at the GMC APS page.