The Attestation Trap: How Soviet-Era Certification Survives in Georgian Healthcare

Georgia’s medical attestation system was designed to protect the public from incompetent physicians. PHIG examines why it does not — and what a functioning re-certification system would look like.

“Attestation as currently designed certifies attendance at an interview, not competency in clinical practice. It has not prevented a single incompetent physician from practising. It has also not identified one.”

Pkhakadze G. Attestation System Review Georgia. Tbilisi: PHIG; 2025.[1]

Introduction

Georgia’s physician attestation system requires all licensed physicians to undergo a triennial review, during which they present CME certificates and may be interviewed by an attestation commission. Physicians who pass retain their licence; those who fail must complete additional training. In 2024, MoLHSA processed 4,812 physician attestations, of which 4,809 (99.9%) passed.[2] The 0.1% failure rate — three physicians in the entire country — does not reflect a highly competent physician workforce. It reflects a system with no effective mechanism to detect incompetency.

Table 1. Georgian Physician Attestation System: Key Indicators 2024
Indicator Value Implication
Total physicians attested (2024) 4,812 Full triennial cohort
Pass rate 99.94% (4,809/4,812) Effectively universal pass
Failures requiring remediation 3 No effective detection mechanism
Attestation commission members who are clinically active 68% Potential bias toward peers
Clinical assessment component None Process is administrative, not clinical
Patients assessed (simulated or real) 0 No performance component
Average time per attestation 22 minutes Document review, brief interview

Sources: MoLHSA Attestation Bureau 2024; PHIG analysis.[1,2]

What the EU Does Instead

All EU member states with functioning physician re-certification systems share three features absent from Georgia’s attestation: a defined competency framework to which practitioners are assessed; a performance component in the assessment (practice audit, patient outcome data, structured examination, or observed clinical practice); and a graduated response to underperformance that includes remediation support before licence action.[3]

The UK General Medical Council (GMC) revalidation model, introduced in 2012, is the most extensively evaluated. A 2021 systematic review of UK revalidation found that the process successfully identified concerns in 1.2% of physicians per five-year cycle, compared to less than 0.1% under the previous certificate renewal system — a 12-fold increase in detection rate.[4]

Figure 1. Physician Concern Detection Rate: Georgia Attestation vs. UK GMC Revalidation vs. Australian AMC System

0.06%Georgia (attestation) 1.2%UK GMC (revalidation) 0.8%Australia AMC % of physicians with concerns detected per review cycle. Source: GMC 2021; AMC 2023; MoLHSA 2024.[1,2,3,4]

Sources: UK GMC Revalidation Report 2021; Australian Medical Council 2023; MoLHSA Georgia 2024.[2,3,4]

Table 2. Proposed Georgian Physician Re-certification System: PHIG Recommendation 2025
Component Description Timeline Model
National licensing examination Standardised clinical knowledge test at entry to practice 2027 (pilot) USMLE/AMC MCQ + OSCE format
Continuous Professional Development requirement 60 accredited CPD hours/3 years with assessment component 2026 (revised regulation) UK CPD framework
Practice audit requirement Annual self-audit of clinical outcomes vs. national benchmarks 2027 UK GMC revalidation
Responsible Officer system Each physician has a designated responsible officer for annual appraisal 2028 UK GMC/NHS model
Remediation pathway Structured support programme before licence action 2026 (framework) UK GMC remediation
Regulator independence Attestation removed from MoLHSA; independent Medical Council 2028 (legislation) GMC model

Sources: PHIG Re-certification Reform Proposal 2025.[1,3,4]

Figure 2. Phases of Proposed Georgian Physician Re-certification Reform 2026–2030

2026CPD regulationrevised 2027National licensingexam pilot 2028Responsible Officersystem piloted 2029IndependentMedical Council 2030Full re-certificationsystem operational Phase 1 Phase 2 Phase 3 Phase 4

Conclusion

Georgia’s attestation system is not a quality assurance mechanism; it is a licence renewal ceremony. Reforming it into a genuine re-certification system — with clinical assessment, performance data, and a functioning remediation pathway — is one of the highest-leverage patient safety investments available to the Georgian health system. The reform does not require new institutions; it requires the political will to extend the existing attestation infrastructure with performance components and to transfer regulatory authority to an independent body insulated from the conflicts of interest inherent in ministry-controlled physician regulation.

References

  1. Pkhakadze G. Physician Attestation System Review: Georgia 2024. Tbilisi: PHIG; 2025.
  2. Ministry of Labour, Health and Social Affairs of Georgia. Physician Attestation Annual Report 2024. Tbilisi: MoLHSA; 2024.
  3. European Union of Medical Specialists. European Revalidation Standards for Specialists: 2023 Framework. Brussels: UEMS; 2023.
  4. Archer J, Regan de Bere S, Nunn S, et al. Understanding the rise and rise of revalidation. BMJ. 2021;373:n1261. doi:10.1136/bmj.n1261
  5. Australian Medical Council. Medical Registration and Revalidation: Standards and Outcomes 2023. Canberra: AMC; 2023.

Prof. Giorgi Pkhakadze

Prof. Giorgi Pkhakadze, MD, MPH, PhD
Professor of Public Health, David Tvildiani Medical University | Chair, Public Health Institute of Georgia | Founder, Accréditation Sans Frontières
Published on behalf of the PHIG Analysis and Intelligence Team · Tbilisi, Georgia
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