As Health Education England was absorbed into NHS England, and NHS England into DHSC, the body specifically mandated to provide independent educational quality oversight has disappeared. The draft GMC Order 2026 consultation — closing 23 June — is the opportunity to address this.
In 1841, a group of doctors working in asylums came together not to advance their professional standing, but because patients with mental illness had no independent voice advocating for the quality of their care. That founding purpose has shaped the Royal College of Psychiatrists ever since.
In 1926 the College received its Royal Charter as the Royal Medico-Psychological Association. In 1971, a Supplemental Charter formally established the Royal College of Psychiatrists. Through every era, the College's three founding aims have remained constant: teaching, research, and public education — all in service of patients.
That is what is at stake in the consultation on the draft GMC Order 2026 and the NHS 10-Year Plan's proposals for postgraduate training. This is a question of patient safety architecture, not professional territory.
A progressive shift in where accountability for training quality has resided — and what has been lost along the way.
Before any national regulator, the royal colleges were the only organisations setting, examining, and enforcing standards in medicine. Their authority was wholly independent of government or employers.
Independent professional authorityPsychiatry's founding body established to raise standards for patients in asylums — a patient safety mission from the outset. Royal Charter received 1926; College formally established 1971.
Patient safety mission from day oneA national regulator forms, but 18 of its 24 founding council members come directly from the royal colleges. Colleges shape the GMC from within — co-governance rather than displacement.
Colleges: co-governors of standardsColleges develop postgraduate training pathways, fellowship examinations (MRCPsych, MRCP, FRCS), and training post inspections. They remain the primary independent quality body for specialist education.
Primary independent quality guardiansA government body (PMETB) takes formal oversight of postgraduate curricula. Colleges retain design and examination roles but lose regulatory equality. Independent professional oversight begins to be mediated through government-appointed structures.
Independent space: first reductionGMC absorbs all postgraduate education oversight. Colleges become approved curriculum providers — designing within GMC-set frameworks rather than setting the framework. Application of standards formally leaves the profession.
Colleges: approved providers onlyHealth Education England absorbed into NHS England. Education functions progressively consolidated into DHSC structures. The body specifically created to hold independent responsibility for education quality is absorbed into the machinery of government and employer priorities.
Independent education oversight: vacuum createdPortfolio Pathway (formerly CESR) proposed as expanded default route. CCT no longer the primary pathway. Formal college examinations de-emphasised. Modular, competency-based progression proposed. Alternative non-college providers introduced. The draft GMC Order 2026 must clarify and protect the college's role in this new landscape.
College role in new framework: undefinedGovernment and NHS employers have legitimate priorities — workforce numbers, service delivery, throughput. These are necessary functions. But they are not the same as educational quality. When the body specifically tasked with independent educational oversight is absorbed into government structures, a critical function is lost — even when no displacement was intended.
The question is not who holds power, but who is independently accountable for the standard. Royal Colleges hold no government accountability and no employer interest. Their charter duty is to standards and public education. In the current landscape, they are among the few remaining institutions able to fulfil this function.
Accountable for NHS performance, throughput, workforce numbers, and political delivery. These are legitimate and necessary goals — but they are distinct from independent educational quality assurance.
Accountable for service delivery and filling posts. Equally legitimate — but the natural pressure is towards training completion and workforce availability rather than the depth and rigour of specialist formation.
As HEE was absorbed into NHSE, and NHSE into DHSC, the independent mandate for educational quality has been lost. Royal Colleges — with charter-based duties to standards, teaching and public education — are now among the few remaining institutions able to fill this function. The draft GMC Order 2026 must formalise and protect this role.
An illustrative representation of the qualitative shift in authority over postgraduate medical education standards across five eras.
Since November 2023, the Portfolio Pathway (formerly CESR) has replaced equivalence-based assessment with demonstration of Knowledge, Skills and Experience (KSE). This is a welcome development, particularly for SAS and Locally Employed Doctors who have historically lacked a structured, supported route to specialist registration.
RCPsych should be a champion of the Portfolio Pathway — but championing it means ensuring it is delivered with the same rigour and college-led quality assurance as the CCT route. Expansion of access is only meaningful if the standard is maintained.
Key questions for the draft GMC Order 2026 — framed around patient safety and educational quality.
If formal college examinations are de-emphasised and the Portfolio Pathway expands as the default route, what independent mechanism assures the public that a specialist doctor has reached the required standard?
The Portfolio Pathway is a necessary and welcome route for SAS, LED, and internationally trained doctors. As it expands, a college-led quality framework must accompany it. Flexibility and rigour must coexist.
With DHSC now holding education policy alongside NHS delivery, the principle that training standards cannot be compromised to fill workforce gaps must be actively protected.
The college's formal statutory voice within the GMC has diminished progressively since 1858. The draft GMC Order 2026 must not reduce it further — it should formalise a mechanism by which independent professional expertise shapes regulatory decisions on education standards.
The NHS 10-Year Plan introduces alternative training providers outside the traditional college and deanery structure. A clear inspection and accreditation framework, led by colleges with the relevant clinical expertise, must be a condition of their approval.
Broadening access to specialist registration for SAS, LED, and internationally trained doctors is the right objective. But equity of access must not come at the cost of equity of standard — both are patient safety issues requiring college-led quality assurance.
I bring over 30 years of NHS experience, rooted in frontline clinical work as a trainee, SAS and consultant psychiatrist. I have also served in a wide range of educational leadership roles, including SAS Tutor, Clinical Tutor, Director of Medical Education, and Vice Chair of the Mental Health Act Approval Panel (NHS Midlands and East).
Within the College, I have contributed extensively through committees and by leading major programmes, including the International Congress, Mental Health Act approval courses, supervisor training, and the National Autism Training Programme for Psychiatrists (NATPP) — supported by Faculties, Divisions and incredible colleagues.
As Associate Dean, I led the establishment of RCPsych Learn and oversee a significant proportion of the College's educational delivery, including Certificate and Diploma courses and MRCPsych eLearning. I am currently leading the MPAC Review and the International Congress.
I sit on the BJPsych Advances Editorial Board and the College's Digital Strategy Group.
This is a particularly challenging time for our profession. Workforce shortages, service pressures, NHS reform, evolving regulatory structures — including the draft GMC Order 2026 and the Medical Training Review — and increasing divergence among the devolved nations all raise real concerns about who will continue to uphold standards should training systems change. In this context, the College's role as a trusted, independent voice becomes even more critical.
We must also engage robustly with Mental Health Act training and implementation, and foster international collaboration and bidirectional learning.
"I have always believed the College should feel like a professional home — a community that stands alongside us and supports us at every stage of our careers to do our best for our patients."
"The Dean's role is not just about training, curricula and examinations, but about ensuring that sense of belonging, development and support throughout our professional lives."
"Supporting Colleagues. Safeguarding Standards in Uncertain, Changing Times."
The RCPsych Dean election is open now. Vote for the leadership you want for the College — and for the independent voice that matters for our patients and our profession.