Memorandum of understanding between the Care Quality Commission and the General Medical Council.
Introduction
The purpose of this Memorandum of Understanding (MoU) is to set out a framework to support the working relationship between the Care Quality Commission (CQC) and General Medical Council (GMC).
The working relationship between the CQC and GMC is part of the maintenance of a regulatory system for health and adult social care in England which promotes patient safety and high-quality healthcare.
The CQC is the regulator of health and adult social care in England. The GMC is the independent regulator for doctors, physician associates (PAs) and anaesthesia associates (AAs) in the UK. The responsibilities and functions of the CQC and GMC are set out at Annex A.
This MoU does not override the statutory responsibilities and functions of the CQC and GMC and is not enforceable in law. However, the CQC and GMC agree to adhere to the contents of this MoU.
Principles of cooperation
The CQC and GMC intend that their working relationship will be characterised by the following principles:
- The need to make decisions which promote patient safety and high-quality health and adult social care.
- Respect for each organisation’s independent status.
- The need to maintain public and professional confidence in the two organisations.
- Openness and transparency between the two organisations, as to when cooperation is and is not considered necessary or appropriate.
- The need to use resources effectively and efficiently.
The CQC and GMC are also committed to a regulatory system for health and adult social care in England which is transparent, accountable, proportionate, consistent, and targeted - the principles of better regulation.
Areas of co-operation
The working relationship between the CQC and GMC involves cooperation in the following areas. Named MoU managers for each organisation are identified at Annex C.
Cross-referral of concerns
Where the CQC or GMC identifies a concern which it believes falls within the remit of the other, they will promptly share the concern and relevant information to the appropriate person at the other organisation. To ensure patient safety, and /or the administration of justice the referring organisation will not wait until its own investigation is completed before making the referral.
In particular, the CQC will refer to the GMC:
- Any identified concerns and relevant information about doctors, PAs, or AAs which may call into question their fitness to practise.
- Any identified concerns and relevant information about a healthcare organisation or a part of that organisation which may call into question its suitability as a learning environment for medical students, doctors, PAs, or AAs in training.
- Any concerns and relevant information about a healthcare organisation which may call into question the robustness of its system of appraisal and clinical governance.
In particular, the GMC will refer to the CQC:
- Any concerns and relevant information about a health or adult social care organisation (including online) which may call into question its registration with the CQC.
This MoU is supplemented by a separate Information Sharing Agreement (ISA) and Joint Operational Protocol (JOP) which will set out the detailed arrangements for sharing information between the parties. Copies are available from the named MoU managers in Annex C.
Revalidation
It is important that all doctors, physician associates (PAs) and anaesthesia associates (AAs) practising in the UK follow the professional standards set by the GMC, and that their knowledge and skills are up to date. The GMC expect all doctors, PAs and AAs working in the UK to collect feedback from their patients and details of any significant events they have been involved in. They are also expected to review information provided by their employer. This information is then discussed in regular appraisals, where doctors, PAs and AAs reflect on their practice, recognising their successes and identifying areas for development. This information helps us to decide whether a doctor, PA or AA continues to meet the standards we set over time. We call this process ‘revalidation.’
Engaging in reflection and professional development through revalidation supports patient safety. It also helps identify improvements to patient care that can be put in place in the organisations where doctors, PAs and AAs work.
Exchange of information
Cooperation between the CQC and GMC will often require the exchange of information. All arrangements for collaboration and exchange of information set out in this MoU and any supplementary agreements will take account of and comply with the UK General Data Protection Regulation 2021, the Data Protection Act 2018, the Common Law requirements for confidentiality, section 76 Health and Social Care Act 2008, and any CQC and GMC codes of practice, frameworks or other policies relating to confidential personal information.
Both the CQC and GMC are subject to the Freedom of Information Act 2000. If one organisation receives a request for information that originated from the other, the receiving organisation will discuss the request with the other before responding.
Resolution of disagreement
Any disagreement between the CQC and GMC will normally be resolved at working level. If this is not possible, it may be raised with one of the MoU managers identified at Annex C. They may then refer it upwards through those responsible, up to and including the Chief Executives of the two organisations, who will then jointly be responsible for ensuring a mutually satisfactory resolution.
Duration and review of this MoU
This MoU originally came into effect from [date]. This MoU is not time-limited and will continue to have effect unless the principles described need to be altered or cease to be relevant. The MoU may be reviewed at any time at the request of either party, but it must be reviewed by both parties every three calendar years from the date of this MoU.
The separate Joint Operational Protocol sets out the operational detail of how the GMC and CQC will work together to maximise the effectiveness of their regulatory responses.
Both organisations have identified a MoU manager at Annex C who will liaise as required to ensure this MoU is kept up to date and to identify any emerging issues in the working relationship between the two organisations.
Both the CQC and the GMC are committed to exploring ways to develop increasingly more effective and efficient partnership working to promote quality and safety within their respective regulatory remits.
Signed
Julian Hartley
Chief Executive
Care Quality Commission
06 October 2025
Charlie Massey
Chief Executive and Registrar
General Medical Council
11 March 2025
Annex A: Responsibilities and functions
The Care Quality Commission (CQC) and the General Medical Council (GMC) acknowledge the responsibilities and functions of each other and will take account of these when working together.
Responsibilities and functions of the CQC
The responsibilities of the Care Quality Commission (CQC) are set out primarily in the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. Further responsibilities have been given to CQC through the Health and Care Act 2022 with CQC now having the responsibility to review systems. Specifically, CQC has a duty to assess Integrated Care Systems and to also assess Local Authorities against their responsibilities detailed in the Care Act 2014.
The Care Quality Commission is the independent regulator of health care and adult social care services in England. CQC also protects the interests of people whose rights are restricted under the Mental Health Act. Whether services are provided by the NHS, local authorities or by private or voluntary organisations, CQC focuses on:
- Identifying risks to the quality and safety of people’s care.
- Acting swiftly to help eliminate poor quality care.
- Making sure care is centred on people’s needs and protects their rights.
By law, all providers of care services in England are responsible for making sure that their services meet national standards of quality and safety set by Government. CQC registers providers and can use a range of powers to take action when a service is not meeting the standards in order to drive improvement.
The CQC uses inspections and information from other organisations to monitor whether care services are meeting the standards, as well as the views and experiences of people who use services, which are at the centre of CQC’s work.
Responsibilities and functions of the GMC
The responsibilities and functions of the GMC are set out primarily in the Medical Act 1983 (the Medical Act), The Anaesthesia Associates and Physician Associates Order 2024 and ‘the next GMC order’. (The name of the order which relates to the three professions (doctors, physician associates and anaesthesia associates) under GMC regulation has yet to be confirmed by DHSC. This will be updated as part of the next scheduled annual review of the agreement, if said order name is confirmed by that date.)
The purpose of the GMC under the Medical Act and the next GMC order is to protect, promote and maintain the health and safety of the public by ensuring proper standards in the practice of medicine.
The GMC is the independent regulator of doctors, physician associates (PAs) and anaesthesia associates (AAs) in the UK.
We work with them and other stakeholders to:
- set the standards of patient care and professional behaviours doctors, PAs and AAs need to meet
- make sure doctors, PAs and AAs get the education they need to deliver good, safe patient care
- check who is eligible to work as a doctor, PA or AA in the UK and work with them and their employers to confirm they are keeping up to date and meeting the professional standards we set
- give guidance and advice to help doctors, PAs and AAs understand what is expected of them
- investigate where there are concerns that patient safety, or the public’s confidence in doctors, PAs or AAs may be at risk, and take action if needed.
Annex B: Legal Basis for sharing personal information between the CQC and GMC
Both the CQC and GMC are data controllers acting alone for the purposes of UK GDPR.
Where the GMC identifies that personal data, it holds ought to be shared with the CQC in order to fulfil its obligations the GMC’s legal basis for sharing data under the UK GDPR is:
- Legal obligation (Article 6(1)(c)
- Public task (Article 6(1)(e)
Where this includes special category data, the GMC’s legal basis under Article 9 of the UK GDPR is Article 9(2)(g) – reasons of substantial public interest with a clear basis in law. The substantial public interest condition is condition 6: for statutory and government purposes under Schedule 1 of the DPA 2018.
Annex C: Contact details
This annex is only available as part of the original document.