We have just published the report on our consultation on revalidation. Over 1850 written responses were submitted, and more than 2400 individuals participated in over 40 separate events across Great Britain. The quality and quantity of feedback and engagement gives us confidence that revalidation for pharmacy is on the right track.
Revalidation will be an important tool to uphold the public’s confidence that you as pharmacy professionals are maintaining, and continuing to improve, standards of practice. It is also a demonstration of your commitment to professionalism, assured by a regulatory approach which is flexible and able to address the needs of a changing pharmacy and healthcare environment.
When our consultation on introducing revalidation was launched earlier this year, it was inevitably met with some uncertainty from the pharmacy sector. How will the GPhC’s interpretation of revalidation compare with revalidation for other health professions? What does revalidation mean for CPD in the future?
One pharmacy trade publication described our proposals as a ‘massive shake-up’ in what pharmacy professionals would need to do to demonstrate that their knowledge and skills remained up-to-date, and although I may not use those exact words, I would certainly agree with the sentiment.
Given the scale of the change being proposed, it has been very encouraging to see the level of support and the positive feedback for our proposals expressed during the consultation:
- A majority of respondents supported our proposals and offered very positive feedback on key elements, including peer discussion and reflective accounts.
- They agreed that the proposed new framework was an improvement over the current system—which many viewed as essentially a tick-box exercise.
- They agreed that the standards, guidance and new requirements were clear and easy to understand; and that they would ensure that pharmacists and pharmacy technicians are continuing to meet the standards for pharmacy professionals.
Although the feedback we received was positive overall, there were some respondents who raised concerns and queries about the new revalidation process.
While most approved of increased structure and robustness of the proposed system, others commented that the proposal was not robust enough. It is much to the credit of the profession that some suggested they wanted a tougher, more rigorous approach, but we are conscious of the fact that we need an approach that works well for pharmacy professionals in a range of roles and settings.
There was also clear recognition from most that the addition of peer discussion and the reflective account—key components of the proposed framework—would be beneficial for professional development.
Some respondents, however, raised concerns about what they saw as a lack of quality assurance regarding the choice of peer, the content and quality of the discussions. In particular, some respondents were concerned that some members of the professions may find it challenging to find an appropriate person to discuss their professional practice with. A number of respondents felt that it could become a tick box exercise rather than a valuable discussion on professional practice.
As many of our pilot volunteers highlighted, they were already having peer discussions—including with colleagues and through association with professional membership bodies; and they told us that the insights and advice they received helped to improve their practice. In anticipation of the roll-out of revalidation, in recent weeks, a number of professional bodies have begun to highlight the resources they offer to pharmacists and pharmacy technicians to connect with an appropriate peer to start these conversations.
Another key component, the move to annual submission of records instead of the current requirement for records to be called on a five-yearly basis, also had broad agreement. It was felt that annual submission would help to embed CPD and reflection into day-to-day practice, and would ensure records are completed in a timely manner.
But some respondents commented that submission of all records at the same time as renewal could become burdensome, and a small number of respondents disagreed with the move to annual submission, citing this as being too onerous and out of line with other healthcare professionals who undergo revalidation on three-yearly or five-yearly cycles.
One of the things we are reflecting on is the impression given by some of the feedback that some people feel revalidation is being imposed on them. What we ultimately want to achieve is that everyone views revalidation as a positive opportunity to reflect on and improve their practice, for the benefit of their patients; so you are driving it, and it’s what you do and bring to revalidation that makes the difference to you and to your patients.
Revalidation is not about the regulator assessing individuals and identifying ‘bad’ performers, and removing them from the register. It’s about the assurance which you give to your patients, the wider public and your professional colleagues, through your commitment to ongoing professional development and improvement in your practice.
Moreover, the basis of the new model is engagement. The evidence we have developed and evidence from other health professions shows that when professionals are engaged in and reflective of their practice, it can often drive improvement.
All of the feedback we’ve had is hugely valuable as we work to finalise and introduce our proposals; we are reflecting carefully on everything we heard through the consultation and are considering if any changes need to be made to the approach before submitting our final proposal to our governing council for approval. We’re also planning what further guidance and support we, and other organisations, could provide to support pharmacy professionals with revalidation.
And as we take another important step forward in the development of revalidation, I want to thank those of you who have contributed in some way to our progress to date—perhaps by participating in the pilot or taking part in the consultation.
I want to invite you all to continue to work with us going forward, and to continue to let us know what you think as we move forward to develop the best possible framework for revalidation of pharmacy professionals.