The Pharmaceutical Journal
Vol 269 No 7224 p707-708
16 November 2002
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The Pharmaceutical Journal |
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PDF* 85K |
Are health professions comparable in requirements for CPD and revalidation? |
| In this feature Lin-Nam Wang (on
the staff of The Journal) looks at how the regulatory
bodies for pharmacists, dentists, doctors and nurses are tackling continuing
professional development as part of the series on regulatory reform |
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Related websites |
At a recent meeting of the Barnet branch of the Royal Pharmaceutical Society, members were shown the Society's continuing professional development guide "Plan and record". Of particular interest were the format of the record sheets and the Society's estimate that it would take about 30 minutes to complete one record. It is generally accepted that CPD is essential to maintain standards in health care, but is the Society, as one member at the Barnet meeting said, being overzealous in what it will require pharmacists to do to stay on the register? The modernised statutory regulatory bodies for each health profession will have a common public duty: to ensure that professionals on their respective registers are "fit to practise". This is to be achieved through various "revalidation" processes, and there is no doubt that CPD will be an essential component of such processes. However, so far, each regulatory body appears to be treating CPD and revalidation in its own way. For example, the system for pharmacists allows CPD to be viewed as a distinct entity, with a formal recording system recommended by the Society. In comparison, for doctors, the General Medical Council (GMC) does not propose a formal structure for recording CPD, evidence of which is enmeshed within an intricate appraisal procedure. Similarly, some regulatory bodies specify the amount (in terms of hours, points or credits) of CPD their registrants should perform while others do not. CPD requirement The Society has chosen not to measure CPD in terms of hours or credits, and there is, at present, no set target for how much must be done. "Plan and record" states that pharmacists who took part in the Society's pilot completed one record a month on average, although they undertook more CPD than was recorded. Pharmacists are not required to declare that they have fulfilled their quota of 30 hours of continuing education as required by their Code of Ethics and Standards. The General Dental Council's (GDC) recertification programme "Lifelong learning" requires dentists to complete a minimum of 250 hours of CPD over a five-year period, of which at least 75 hours should be "verifiable CPD". This is CPD that meets specific educational criteria and participation in it can be proved by obtaining a certificate from course providers. The Nursing and Midwifery Council (NMC) requires nurses and midwives to undertake and record at least 35 hours of relevant learning during the three years before renewal of registration. For doctors, one of the principles of good medical practice is to keep knowledge and skills up to date and regularly to take part in "educational activities which maintain and develop competence and performance". The GMC does not specify a fixed number of points or hours of CPD for general practitioners and consultants, but most postgraduate colleges, such as the Royal College of Physicians, will require its members or fellows to perform a certain amount (eg, 50 credits) of CPD each year. Keeping CPD records "Plan and record" provides two template record sheets for pharmacists to record their CPD. These were developed by the Society's CPD advisory group and through the education division's CPD pilots. One template is for recording learning that starts with reflection. It is three pages long and consists of separate sections for each step of the CPD cycle (reflection, planning, action and evaluation), with questions for each step. The second template is shorter (one page) and is designed for recording unscheduled learning. "Plan and record" says that, at present, pharmacists can use any format they wish to record CPD, as long as it is more than simply a record of continuing education. However, Fred Ayling, CPD officer at the Society, told The Journal that because the CPD records of all pharmacists will be looked at, for ease and equity in the future it is likely that the format used to record CPD will need to provide all the information the Society requires. That is to say, CPD records will need to be in an approved format.
In contrast, the GDC's suggested recording method is much simpler. It consists of a single sheet, on which several CPD activities can be logged and it should take no more than a few minutes to record each CPD event. A dentist using the GDC's format would need to fill in a grid with the date, title of the activity, venue, provider, whether the CPD is "verifiable" and the time spent. There is a further column for comments. One of the GDC's aims is that recording lifelong learning should not be "unduly onerous". The GDC's guide "Recertification for the dental profession — what it means for you" says that the recording of CPD in itself allows for reflection. Dentists are not asked for information such as how they identified the learning objective, what the impact of their learning will be or what feedback they have had. Ian Sunderland, recertification administrator at the GDC, told The Journal: "The GDC takes it on professional trust that dentists will do something that is relevant [to their practice]". Although he admitted that with the GDC's scheme there was the potential for dentists to "work the system", for example, attending courses just to pick up a certificate, that would be a professional conduct issue. "We expect dentists to take a professional responsibility to spend their out-of-surgery time productively. If a dentist says they are doing something and its relevant to their needs, fine. Only in extreme circumstances would the GDC challenge a dentist's judgement," he says. Commenting on the suggested recording format for pharmacists, Mr Sunderland says that the Society seems to be attempting to embed ideals. "The GDC considered these, but to be prescriptive would make the scheme potentially difficult for dentists to understand and difficult for us to administer," he explains. Mr Ayling says that in isolation, the GDC recording format is effectively continuing education and it would not be credible from a public interest perspective for the Society to adopt such a system for recording CPD. Nurses should record their CPD in a "personal professional profile". Although there is no approved format for this, the NMC has suggested a template in its PREP (postregistration education and practice) handbook. This more closely resembles the Society's format but it is shorter (two pages). A nurse using the template is asked to describe briefly a learning activity and how it was done and then to say how the activity has influenced his or her work, including any plans or ideas for follow-up learning. However, according to the NMC's professional advice department, these records are personal to the nurse and at no time are these scrutinised by the NMC. There is no GMC specification as to what records of CPD doctors must keep, but again, postgraduate colleges have their own recording formats. How it works Dentists will be asked to submit an annual return stating how much CPD they have done. This return will go through an administrative check only. As for a quality check, "85 per cent of [verifiable] CPD activities will be provided by organisers who have their own rigorous quality assessment measures," explains Mr Sunderland. "Responsibility is placed on the individual. If a provider is not satisfactory, we would expect the dentist to go somewhere else," he added. A random selection of dentists will have their records checked further by being asked to provide their certificates for verifiable CPD. Dentists who do not meet requirements for the five-year cycle will be erased from the dental register, although they are allowed a six-month grace period in which to complete any outstanding CPD and there is an appeals mechanism in place. Although, in isolation, the GDC's format for recording CPD (and therefore fitness to practise) may not appear robust, it is part of a broader revalidation agenda, which is likely to include clinical audit, peer review and, possibly, formal appraisal. Nurses and midwives must renew their registration with the NMC every three years. The NMC's revalidation scheme, (PREP) requires registrants to meet a practice standard (nurses and midwives must have worked in their respective fields for at least 100 days in the five years prior to renewal) as well as the CPD standard before registration can be renewed. For nurses to reregister with the NMC, they need to fill in a "notification of practice" form, in which they must declare that they meet the two PREP standards. The NMC audits compliance with its CPD standard by asking a random sample of registrants (10 per cent of those due for renewal) to use their personal CPD records to complete a summary form. This is sent to nurses before their renewal date. The form is one page long and the nurse is asked to list the learning activities undertaken, the key learning points gained from those activities and the way in which the learning has influenced his or her work. Failure to fill in a form will result in a lapsed registration. Maureen Williams, professional officer at the NMC, told The Journal that submitted forms are looked at by an information officer to check that the requisite 35 hours of CPD have been met for that period of registration. The only other criterion applied is that the form is coherent. "It's not an exam, but a means of checking compliance," she says. Ms Williams went on to say that research conducted with 4,000 subjects before the NMC's mandatory system of CPD was implemented showed that filling in the summary form does not take long. "Some people told us they could do it in less than half an hour," she says. At present, it is likely that every pharmacist will be asked to submit his or her CPD records, either on paper or electronically, every three to five years for validation by the Society. However, it is undecided precisely how this will work. "It is a matter of public interest that all pharmacists submit their CPD records, instead of only a random sample," Mr Ayling told The Journal. He says that feedback is required for a genuine learning process. "Half an hour [making one record] a month is not asking too much and pharmacists will benefit in terms of the feedback they will receive, which the NMC and GDC do not provide," he adds. Furthermore, the way in which the Society has chosen to handle CPD may prevent the need for a distinct formal appraisal. "We think that there is evidence of appraisal in our CPD format," says Mr Ayling. The GMC will monitor whether or not doctors are fit to practise through a process of revalidation, which will run on a five-yearly cycle. This requires employers to carry out annual appraisals with their doctors and summaries of the appraisals conducted during the revalidation period must be submitted to the GMC. The GMC groups responsible for revalidating doctors will have medical and lay membership, with one of the group members being from the same specialty as the doctor being reval-idated, where possible. Doctors who are successfully revalidated will be granted a "licence to practise". Those who are not, will be allowed to stay on the GMC register, but will not be entitled to practise. Appraisal itself is an employer-led system. The GMC has been working with employers to ensure that appraisals incorporate the principles of good medical practice. The appraisal system for doctors used by the National Health Service is lengthy. It involves the doctor preparing an appraisal folder and completing detailed pre-appraisal documentation, which includes recording learning events (with entries for reflection and further actions), a personal development plan and learning needs. According to a spokesman at the Department of Health, although the time taken to prepare for appraisal varies and it is an ongoing process, it is estimated that it will take six to eight hours. Appraisers are likely to be other doctors, trained in appraisal. For GPs, appraisers will be provided by primary care trusts. Progress In November 2001, legislation was passed so that for dentists, CPD could become mandatory. The GDC is introducing its scheme in three tranches with the first set of annual declarations due in January next year. It will be interesting to see what proportion of dentists comply with this, and how many might risk being erased from the GDC register. At this stage, nurses are well-versed with concepts of CPD and revalidation (as interpreted by the NMC) and PREP standards apply to all of them. The GMC is in the process of putting legislation through that will make revalidation mandatory. It aims to revalidate the first group of doctors within two years of this legislation. In terms of appraisal, the Department of Health has its standards in place, but the GMC is still working on an appropriate system for doctors outside the NHS. Much to do with ensuring that health care professionals are fit to practise is still in development. And regardless of what is developed, the system eventually used may (its remit is uncertain) be stipulated by the Council for the Regulation of Health Care Professionals, which is going to oversee the practices of each regulatory body. One of the priorities of this new council will be to ensure that the regulatory bodies act in a consistent manner, but with such diversity in the way revalidation is being implemented, which way will the council lean? It will be interesting to see what the Council for the Regulation of Health Care Professionals will make of certain approaches, says Mr Ayling. Perhaps the Society, by adopting such rigorous standards from the outset, rather than being seen as overzealous, will be seen as an example for some of the other regulatory bodies to follow. |
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