Revalidation as a Fully Private GP: What If You Have No Designated Body?

A GP who leaves the NHS entirely can end up with no designated body and no responsible officer, which means no route to revalidate. There are three ways to resolve it, and the consequence of resolving none of them is withdrawal of your licence to practise.

This is the highest-stakes administrative question in private general practice, and it is documented across several GMC pages and a statutory instrument rather than anywhere a doctor would naturally look.

How does revalidation normally work?

Every licensed doctor revalidates, usually every five years, on a recommendation from a responsible officer. The responsible officer sits within your designated body, which is the organisation you have a prescribed connection to.

For most GPs that is straightforward. NHS England, an NHS trust, or a locum agency is the designated body, and the connection follows from the work.

Why might a private GP have no designated body?

Because designation is set by regulation rather than by choice.

The Medical Profession (Responsible Officers) Regulations 2010 list designated bodies in a Schedule split into two parts. Part 1 bodies are designated bodies in all circumstances. Part 2 bodies qualify only while they have a prescribed connection with a particular doctor.

A GP working solely in their own private practice, not through an independent hospital group, not on a performers list, and not with an agency, may fall outside both. Not because anything is wrong, but because the structures were built around employment relationships that no longer exist for them.

The moment this typically bites is resignation from the NHS. Nothing changes clinically. The connection simply ends.

Route one: find a designated body

The first thing to check, because it is the simplest answer if it applies.

Independent healthcare providers, private hospital groups, out-of-hours organisations and some professional organisations can be designated bodies. If you do any work through one, you may already have a connection you have not identified.

The GMC publishes a connection tool for working this out, and it is worth running honestly rather than hopefully. A tenuous connection you cannot evidence is worse than none, because you may believe you are covered when you are not.

Route two: a GMC-approved Suitable Person

If there is genuinely no designated body, a doctor may connect to a Suitable Person: an individual approved by the GMC to make revalidation recommendations.

Two limits catch people, and both are commonly missed.

It is an alternative, not a supplement. A Suitable Person is available only to a doctor who has no prescribed connection to a designated body. If you have one, however inconvenient, you cannot elect for a Suitable Person instead.

It is unavailable to doctors under an Approved Practice Setting requirement. If that applies to you, this route is closed.

Approval is a GMC process with its own criteria, and organisations exist that provide Suitable Person services commercially.

Route three: GMC assessment

The least documented route, and the one most doctors have never heard of.

A doctor with neither a designated body nor a Suitable Person revalidates directly with the GMC. According to the GMC's guidance for doctors without a connection, that means finding an appraiser who meets the GMC's criteria, sending an annual return with supporting evidence, and meeting the required standard in a revalidation assessment if the GMC asks you to take one.

Two things make this the route to avoid rather than the route to plan for. It is more onerous than a normal revalidation cycle, because without a responsible officer there is no independent recommendation and the assessment stands in for it. And the GMC may withdraw your licence if you do not comply without reasonable excuse.

What happens if your licence is withdrawn?

You must stop practising medicine in the UK immediately. Not gradually, not after a notice period.

Two points of reassurance sit alongside that. Withdrawal of a licence is not erasure from the register: your registration survives, and the licence can be restored. And administrative withdrawal for a connection problem is not a fitness-to-practise finding, so it is not a misconduct matter.

But it stops your practice while it lasts, with all that implies for patients mid-treatment, for your income, and for any insurer or contract that requires a licensed doctor.

The trap: two things fall away at once

This is the part worth planning around.

The designated body concept does double duty. It governs your revalidation route, and it also underpins the CQC registration exception in Schedule 2 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, which excepts treatment in a consulting room by a practitioner on a performers list for a designated body.

So a GP who fully leaves the NHS can simultaneously lose their revalidation connection and their CQC exception, in the same moment, without doing anything different clinically. Our guide to CQC registration for private GPs covers that half.

Neither change announces itself. Both are discovered later, usually by someone else.

What should you do?

Six steps, in order, if you are going private or already have.

Establish your current connection using the GMC's tool, before you resign rather than after
If you have a connection, keep it evidenced. Know which body, which responsible officer, and how the connection arises
If you have none, apply for a Suitable Person early. Approval takes time and your revalidation date will not move for you
Keep your appraisal cycle running regardless. Whichever route you end up on, annual appraisal and a supporting-information portfolio are the raw material, and a gap year is hard to reconstruct
Keep the portfolio evidence as you go, particularly patient and colleague feedback, quality improvement activity and significant events. In a solo private practice nobody collects these for you
Check the CQC position at the same time, because the same event changes both

The practical version: treat leaving the NHS as an event with two administrative consequences, and deal with both in the same week. It is straightforward to solve in advance and genuinely disruptive to solve late.

On the portfolio point, systems that hold your clinical records with dates, attribution and an audit trail make assembling supporting information a retrieval task rather than a reconstruction. That is what Atlacare does with notes and the audit log, though the appraisal portfolio itself lives wherever your appraiser wants it.

This is general information about revalidation and licensing, not legal or regulatory advice. The rules on designated bodies, Suitable Persons and GMC assessment are set out across GMC guidance and the 2010 Regulations and are updated. Confirm your own position directly with the GMC.

Sources: Medical Profession (Responsible Officers) Regulations 2010 · GMC, revalidation · Suitable Person service information