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The Journal records the official start on the road to revalidation for pharmacy. Lin-Nam Wang reports on what is known so far and what might lie ahead

By Lin-Nam Wang

The Journal records the official start on the road to revalidation for pharmacy. Lin-Nam Wang reports on what is known so far and what might lie ahead

BY 2018, “CFTP” should be an abbreviation that rolls off tongues as smoothly as “CPD” does today. It stands for “continuing fitness to practise”, the term that the General Pharmaceutical Council has adopted for revalidation. At its November meeting in Lambeth last week, the council formally turned the ignition key in the journey towards revalidation of pharmacists and pharmacy technicians by approving the development of a CFTP framework, which will be made up of three components: CPD review, peer review and external performance indicators.

Duncan Rudkin, GPhC chief executive and registrar, explains: “One of the reasons we’re talking about assuring continuing fitness to practise rather than using the term revalidation is because we recognise that there is a continuum of assurance that we’re interested in providing for the public. It’s not a big-bang, once-every-five-years-you-have-to-do-a-test kind of approach, it’s much more realistic than that. Our concept recognises that we have measures in place now to provide assurance [but] we want to strengthen those.”

Mr Rudkin says that the element missing from the current CPD model is external input which gives the GPhC some assurance that the CPD has changed a pharmacist’s practice rather than him or her just being really good at making records. The aim is to “bring in a qualitative dimension”.

In fact, this move by the GPhC should come as no surprise to Journal readers — as early as 2007, the Government set out that revalidation was to underpin the regulation of all healthcare professionals in its White Paper “Trust, assurance and safety — the regulation of health professionals in the 21st century”.

Timeline 

Earlier start possible

Although the plan is for CFTP to begin in 2018, an earlier start is possible. During the council meeting a few concerns were voiced over the timeline (below). Soraya Dhillon, for example, pointed out that the non-medical healthcare professions validation standards had come out in 2008, so implementation in 2018 would mean a 10-year window.She questioned whether this was right in terms of those with patient-facing roles (and who, therefore, pose the highest risk to patients), especially when a number of practitioners are already in managed sectors where there are strong processes around appraisal, which could be used.

Council member Judith Worthington also expressed concern that the profession does not appear to be “dragging its feet”. On this issue, Mr Rudkin says: “There may be opportunities to move more quickly in some areas and so we will need to reflect on that feedback and look again at our planning to see whether there’s more that we can do to differentiate between different sectors.”

How will it all work?

So, what will revalidation look like? The answer is that it is too early to say. “It wouldn’t be right for me to speculate on exactly what that looks like in detail because there’s a lot of design work to do, a lot of formal and informal testing and evaluation to do,” Mr Rudkin says. But he wants the profession to be involved: “The individual components of the process in terms of exactly who does what [and] when or how [it] all works is definitely a piece of work to be developed by us in collaboration, hopefully, with pharmacy representative bodies, leadership bodies and employers.”

There have been a few hints, however, that might help us make a rough sketch, and we can also draw perspective from what is happening in the other health professions (see Graphic).

Asked about external performance indicators, Mr Rudkin says: “It’s about triangulating different sorts of evidence; CPD, some form of peer review, and then looking at what kind of practice are people in, what kind of records would there be that would give us clues about their actual performance. So it may be that actually the peer review is the way that’s incorporated. I’m not saying that it has to be a separate process. The peer reviewer might be looking at the external indicators and incorporating that into their review.” He adds that he hopes reviews will happen more frequently than once every five years.

The council papers state: “It is neither practicable nor desirable for the GPhC to run the peer review process, therefore the GPhC proposes that it will accredit partner organisations to do this. Wherever possible, peer review will build on existing processes, such as appraisals.” So, as Damian Day, GPhC head of education and quality assurance, explained to the council, “it’s not the regulator looking at you, it’s another registrant”.

Mr Rudkin points out that the Royal Pharmaceutical Society Faculty is a “good example” of an “existing process” and Catherine Duggan, RPS director of professional development and support, told The Journal: “We have been in close discussions with GPhC around their plans for revalidation and fitness to practise beyond CPD and have ensured that all methods of assessment would be a clear quality marker for revalidation from our Faculty members.”

However, Mr Rudkin adds that registrants who, for whatever reason, do not think the Faculty is right for them may be supported by other kinds of organisations, such as employers who meet the GPhC peer review and external assurance needs.

Mr Day reported to the council that the regulator has already had “quite a lot of approaches from quite a lot of organisations keen to become involved”. It is also interesting to note the recent Pulse headline: “Thousands of GPs to be revalidated by non-GP responsible officers”. “Who is the reviewer, exactly what criteria they’re using and exactly what evidence, that’s one of those things where we need to get pharmacy to give us some advice,” says Mr Rudkin.

Other issues raised at the council meeting included the need for the system to have a degree of flexibility as well as a degree of consistency in order to work for registrant groups across a number of sectors, and the need for a model that can be used by registrants who are isolated.

CFTP is also likely to affect the current CPD call and review model. “Given that we obviously need to make the best possible use of resources, we want to do things with the right touch and take account of risk as well, we think it would be responsible for us to consider whether, in future, we will need to maintain the 100 per cent monitoring or whether … as part of a wider CFTP assurance process, we would be able to take a more targeted approach to CPD monitoring,” Mr Rudkin says.

Revalidation in other health care sectorsBurdens

Undoubtedly one of the questions that will be foremost on pharmacists’ minds is that of cost. Council member Sarah Brown said:“We must consider not just costs to ourselves, which will get passed on to the registrants, but also costs in terms of time and for those who are going to do their peer review. This is not a quick and easy process.”

Mr Rudkin acknowledges “there’s bound to be some cost” but says “we haven’t got a price tag on this yet”. However, he adds: “We know that it needs to be kept in proportion. We know that the process … needs to feel, to the profession as well as to the public, that it’s worth the effort. And worth the cost. And I certainly would hope that many members of the profession … would actually feel that there is value in having some external assurance and some confirmation from the regulator based on some evidence that says ‘yes you are doing the right thing and your professionalism is sound and the public can have confidence, and we’re up to date with you on that’.”

He also says that the GPhC will try to maximise efficiencies between itself and other organisations that have suitable processes rather than adding new processes. So, for example, if pharmacists have joined the Faculty, the GPhC would look to allow them to use Faculty processes so they would not have to pay significant further costs.

When asked whether pharmacist retention fees would go up as a result of CFTP, Mr Rudkin says: “we don’t know at this stage.”

Wider implications

Hugh Simpson, GPhC director of policy and communications, told the council that the lack of experience from other professions is the biggest challenge in introducing CFTP for pharmacists. Indeed, some Journal readers may be worried that we are heading down a route that has not had adequate testing.

For example, the General Medical Council, having been the first to introduce revalidation in 2012, is still only at the stage of having commissioned the development of a framework for how to evaluate its system. “One of the things that we have learnt from medical revalidation is that it’s very complex and I think the jury is still out in relation to … the impact. Certainly the current debate implies that there are some very positive things about it but there are also a lot of questions that remain,” Mr Simpson said.

If there are parallels with the GMC’s experience, revalidation could affect both the number of pharmacists on the Register as well as GPhC reserves (over £16m in the black according to its September 2013 balance sheet) and, ultimately, registration fees: following the introduction of revalidation, there have been reports of over 10,000 doctors deciding not to renew their membership and of the GMC forecasting a £2m loss as a result.

The GMC pledged to freeze its retention fee but only if its income did not fall below a certain level. On the prospect of pharmacists leaving the Register, a GPhC spokesman says:“There are significant differences between the GMC and GPhC registers as registrants are required to declare that they are intending to practise in Great Britain in the next year”.

Another challenge, according to Mr Simpson, is the “recognition that if one gets it wrong, one has the potential to create the most enormous bureaucracy that costs a fortune and delivers very little.” Hence the iterative development strategy.

CFTP might also impact on the GPhC fitness-to-practise case workload. (Council papers reveal that from October 2012 to September 2013, 83 per cent of cases that were closed were closed within 12 months.) Mr Rudkin told The Journal that the GPhC does not know what the impact will be, but it could go either way: it could cut the workload because more registrants would be fit to practise or it could increase the workload because there would be cases of non-compliance with CFTP.

However, he emphasises that the aim is not to achieve a particular impact on the FTP caseload. Rather, “[CFTP is] about improvement. It’s about working in partnership. It’s not actually going to be designed to catch people out… . This is being done for positive reasons,” he says.

Citation: The Pharmaceutical Journal DOI: 10.1211/PJ.2013.11130584

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