It’s a proposal that aims to encourage pharmacists and technicians to record their CPD on the go, rather than wait for their five-yearly call up from the regulator. It’s called sampling. GPhC has been discussing the idea with the profession and successful pilots have now led to a consultation that has been recently launched. GPhC chief executive Duncan Rudkin spoke to P3’s Carolyn Scott about the plan.
A randomised system that samples records, rather than requiring everyone to submit once every five years, means that pharmacists and technicians could be asked at any time to submit that CPD records, or could even be selected more than once over a time period, Mr Rudkin explains.
“What we’re proposing is, I think, quite exciting,” he says. “It is based on evidence as to what’s useful, and it’s something that will encourage people to record in a more timely fashion, so it should make it easier for them”.
“Moving towards a sampling approach has a number of advantages,” he says. “It will encourage more timely recording – for people to think about their CPD more in real time. Overall it will reduce the bureaucratic burden on the profession as a whole.”
The current system doesn’t encourage people to record their CPD as it happens, suggests Mr Rudkin, possibly resulting in a great deal of work when some CPD records are called for review.
There is limited value in doing it in this way, he says. “We don’t see that particular bit of the jigsaw adds a lot to the process. It’s probably quite annoying and probably doesn’t feel very useful to the people doing it.”
“We don’t necessarily all like to record things, but actually let’s do it at the time or shortly afterwards, rather than having to sit over a whole weekend and write up five years of records – we know that people have been doing that.”
The proposed new approach is a more efficient process, suggests Mr Rudkin. “It’s a bit more agile, more targeted and a lot more efficient to sample, say, 2,000 people over a period rather than 100 per cent. Of course, everybody keeps doing CPD as before, but we can take a more targeted and efficient approach to the collection of the evidence.”
GPhC has been developing the new plans with a working group from the pharmacy profession and others, who found that research suggests the change will benefit all involved.
“The sampling approach is based on real evidence that GPhC has gathered in reviewing in-depth with members of the profession how CPD has worked for them,” says Mr Rudkin.
He stresses that CPD is an essential activity to keep professionals updated to deliver best care for patients – but the view is that recording this and submitting it to the regulator should be as least onerous as possible. “It’s the doing the CPD and the impact that has on practice that matters, rather than meeting the regulator’s processing requirements.”
The change to CPD being discussed is based on “a considerable body of evidence from the profession itself as to what works and what doesn’t”, he says.
“We’ve piloted the sampling and are satisfied that it should work as intended. What we are consulting on is a substantive change to the CPD framework that sets out, effectively, the rules. So now we’re proposing to move from pilot sampling to sampling being the norm.”
CPD for pharmacy professionals will continue to evolve, says the GPhC, and further additions to the scheme are planned in the near future, eventually paving the way for revalidation (Continuing Fitness to Practise).
“We’ve started the Continuing Fitness to Practise programme. We’ve been working through a structured programme of policy development, evidence gathering, testing with volunteers and piloting, and we are quite well advanced with that.”
New elements for CPD are planned for the future as a result of this work. The use of case studies is planned to enable registrants to demonstrate how their learning has impacted on practice outcomes, and input from professional colleagues will ratify that the learning outlined in someone’s submission has taken place.
“CPD is inherently an input – it’s a course or a professional incident that has helped you learn something or reminded you of something. What we are seeking to move towards is to also start looking at evidence of impact and outcome,” says Mr Rudkin.
“We’re moving towards the introduction, testing and piloting of additional elements of assurance, including case studies – so people are not just telling us about a course they’ve been on or an intervention that they’ve taken, but actually bring that to life with a short narrative explaining how that’s had an effect, how its been useful, and how it has made a difference to patient care.
“You then further strengthen that assurance by bringing in an element of third party confirmation and scrutiny from a colleague – who might say ”yes, I can see that this has happened and has had a useful effect”.
The pharmacy profession has been ”ahead of the game” with their CPD framework compared to other healthcare professions, and these developments are further examples of a modern approach to regulation, says Mr Rudkin. With revalidation on the horizon, this latest development moves thinking further away from “passive compliance” and towards “quality assurance”, he says. “We are continuously improving and challenging the way we work.”
CPD records sampling may mean that pharmacy professionals will want to look at CPD slightly differently, suggests GPhC’s Duncan Rudkin.
“If you are someone who has taken purely the compliance approach to CPD as an exercise for meeting regulatory requirements, then you may need to think about whether you are approaching CPD in the right way. But that’s going to be very much an individual reflection, based on your own values and how you’ve historically approached CPD.”
Ongoing recording of CPD as you undertake it would be an advantage in a system where you could be called to submit your records at any time. “There will be an awareness for everybody that they could be called for sampling and they would therefore be encouraged to keep their records up-to-date in a way that hasn’t been necessarily a feature of CPD recording for everybody in the past.”
It would not be possible to predict when you would be called by GPhC, under the new system. “It’s possible with a random sample that you might be called more than once in a period and your colleague might not be called for a while. We will have to see how that works for people, but that’s what you get with random sampling.” The important message is that anybody could be sampled, he says.
It is also proposed that the system will have the flexibility to allow GPhC to sample the CPD record of pharmacists and technicians who have had problems with their CPD in the past.
“There will be a targeted element as well, because we have evidence now that where people have struggled to meet the standards required in the past they are more likely than others to struggle again. So in addition to a random sample, people who have in the past five years been required to undertake remediation, will all be sampled as well, because there’s that evidence that they are at greater risk than the normal population.”
Pharmacists and technicians who this applies to, should expect to be contacted, he suggests. “If you have struggled in the past and have been required to undertake a period of remediation then you will be on notice that you will be called again. It will be better to try and find a way to overcome whatever was getting in the way, so that you can have a more straightforward experience the next time around,” he explains.
Although the details are to be decided, people will be given “a certain amount of weeks”, as they are now, to submit their records once they have been called, he says. “We’re not in any of this to catch anyone out. And if you are doing what you should be doing, it should be possible to provide the evidence in a matter of a few weeks.”
When the new system is up and running, the number of people chosen to be sampled will be monitored to check that the sample is reflective of the wider professional population, confirms Mr Rudkin.
GPhC invites comment on the CPD proposals until 31 October. View the consultation at pharmacyregulation.org/get-involved/consultations
People who have in the past five years been required to undertake remediation, will all be sampled as well, because there’s that evidence that they are at greater risk than the normal population