Revalidation for pharmacy professionals frequently asked questions

General questions about the consultation

How long do I have to make a response?
Why are you introducing revalidation?
Who should do revalidation?
Does this positively or negatively affect any of the people I am working with or me?
Are you doing an impact analysis?
What work have you done so far to come up with your proposals?
Where is the evidence behind the proposals?
What about the learning and development I am already doing?
Can you provide some examples of good records?

General questions about the overall change

What will I have to do and submit to the GPhC?
When should I submit my records?
By linking submission of records to renewal, does this mean I will lapse my registration if I haven’t submitted some or all of my records?
What does the term ‘records’ mean?
What does the term ‘reflective practice’ mean and how do you do it?
What does the term ‘people using your services’ mean?
Can you provide some examples of ‘people using your services’?
How long will it take me to complete my records?
How will my record be reviewed?
What feedback will I receive following review of my record?
Who are the professional and lay reviewers?
When is this all being introduced?
Why are you asking for ‘real’ examples?
What happens to my existing records in the uptodate.org system?
Will I be sent any reminders when my records are due for submission?
What if I cannot submit some or all of my records with good reason
What happens if you do not submit some or all of your records without good reason?
How long will the GPhC retain my records?
Can I import records from another life-long learning portfolio?
Will pre-registration pharmacy students be able to make records?

Questions about the changes to CPD recording

It’s less to record, so it must be easier?
When should I make CPD entries?
What is the difference between planned and unplanned CPD?
How long should my CPD entry be?
Is it okay for me to submit CPD entries that relate to the personal relevance or impact on myself rather than to people using my services?
Is it okay to submit CPD entries that will benefit people using my services rather than entries that have benefited people using my services?
 

Questions about introducing peer discussions

What is a peer discussion?
What is the difference between a peer discussion and a peer review?
How do I find a peer?
What sort of guidance will be available to my peer?
What kind of people can be peers?
What if I have a problem with my peer?
Will my peer pass over information to you about me?
How will you make sure peer discussions are robust?
How long should my written peer discussion be?
What should my peer discussion contain?
Is it okay for me to submit a peer discussion that relates to the personal relevance or impact on myself rather than to people using my services?
Is it okay to submit a peer discussion record that will benefit people using my services rather than entries that have benefited people using my services?

Questions about introducing reflective accounts

What is a ‘reflective account’?
How is a reflective account different from a CPD entry?
Which standard(s) can I use for my reflective account? How and when will you let me know what standard(s) to use?
How long should my reflective account be?
What should my reflective account contain?
Is it okay for me to submit a reflective account that relates to the personal relevance or impact on myself rather than to people using my services?
Is it okay to submit a reflective account that will benefit people using my services rather than entries that have benefited people using my services?

General questions about the consultation

How long do I have to make a response?

The consultation is open for 12 weeks from the 24th April to 17th July 2017.

Why are you introducing revalidation?

We know from a number of different sources that members of the public expect and believe that there are periodic checks on health professionals (including pharmacy professionals) and that their practice remains safe and effective beyond initial registration. To meet this expectation we have been trying to understand what pharmacy professionals already do to maintain and develop their knowledge and skills and how these might be used to provide that further assurance. We have learnt from extensive research, testing, piloting and evaluation that we can do more to encourage reflection on learning and practice in some innovative ways. ‘Revalidation for pharmacy professionals’ is our proposal for what a future framework of assurance should look like. It builds upon existing processes for CPD and adds additional components of a peer discussion and a reflective account to further assure the public that their trust in pharmacy professionals is well placed. The framework encourages reflection on learning and practice and focuses on outcomes for people using pharmacy services.

Who should do revalidation?

The revalidation framework applies to all pharmacists and pharmacy technicians as a condition of their registration with the General Pharmaceutical Council (GPhC). The requirements are not changed by factors such as part-time employment, working in a role where you do not have direct contact with patients, or living or working outside Great Britain.

Does this positively or negatively affect any of the people I am working with or me?

In all stages of our development work we have considered whether there are any significant equality implications, either positive or negative, for registrants or members of the public. We have engaged with a wide range of audiences and have ensured that our testing involved a sample of pharmacists and pharmacy technicians broadly reflective of the profession as a whole. We have not identified any significant negative equality or diversity implications of our proposals and expect there to be a positive benefit for patients and the public. We do however ask a specific question in the consultation to ensure we receive feedback on any relevant issues.

Are you doing an impact analysis?

Yes. We have produced Equality Impact Assessments (EIAs) at different stages of the work programme (testing, piloting and evaluation) and one of our forthcoming actions will be to review and update all the EIAs using information from the consultation and engagement with people and organisations affected by the proposals. A final EIA will be presented to Council for approval following the consultation.

What work have you done so far to come up with your proposals?

The development of these proposals began shortly after our establishment as the regulator for pharmacists, pharmacy technicians and registered pharmacies in 2010. This included reviewing work undertaken by the previous regulator, the Royal Pharmaceutical Society of Great Britain (RPSGB), as well working with other regulatory bodies, including the General Medical Council to consider learning from others. After almost three years (2014-2017) of research, testing, piloting and evaluation activities we have evidence to show our proposals are the right ones for us to consult upon. You can find more detail in reports that we and others have produced about this work on this page.

Where is the evidence behind the proposals?

We reviewed the research undertaken by the previous regulator, the RPSGB, and commissioned some further research included a review of our existing CPD processes.  After our research in 2015, we used the evidence we collected to test the proposals with more than 200 pharmacy professionals from a range of roles and contexts of pharmacy practice. We evaluated the results and found that the proposals were largely effective, but that we had more work to do to make our expectations clearer and provide support to pharmacy professionals. That learning was applied to the development of our pilot. In 2016 we commenced a pilot with over 1300 volunteers from a range of roles and contexts of pharmacy practice. Over eight months the volunteers used draft guidance and examples we produced to complete entries for revised CPD recording, a peer discussion and an early version of the reflective account. During the pilot we engaged with volunteers using an online workshop to find out which parts of the pilot were working for them, which could be changed and their proposals for improvements. Their feedback was used to improve the proposals that are made in this consultation. We also commissioned an independent evaluation of the pilot, undertaken by Solutions for Public Health (SPH). In their report, SPH found that the proposals largely had their anticipated impacts and findings from the report have been incorporated into the proposals.

What about the learning and development I am already doing?

You should continue to make entries of your learning and development using the existing uptodate.org system. We will introduce changes in a stages so that the pharmacy sector has time to adapt. We also plan to make some improvements to our IT platform to make the process of recording and submitting records to us easier.

Can you provide some examples of good records?

You can see some examples of good records here.

General questions about the overall change

What will I have to do and submit to the GPhC?

Each year you are expected to undertake, record and submit a total of six records: four CPD entries, of which a minimum of two must be planned learning activities, one peer discussion and one reflective account

When should I submit my records?

Each year, and by the time you renew your registration, you are expected to submit records of your CPD, peer discussion and reflective account to us. We will send you details of how to submit and how long you have to respond.

By linking submission of records to renewal, does this mean I will lapse my registration if I haven’t submitted some or all of my records?

Not necessarily. At the point of registration renewal you must declare that you have and will continue to comply with the requirements of the pharmacy revalidation framework. If you are unable to submit some or all of your records for a good reason you can tell us in advance of the renewal deadline and depending on your circumstances you may still renew (it is better to tell us about these reasons before submission). If you are unable to submit some or all of your records without good reason you will be entered into a process of remediation which will include intervention from us and a requirement for your records to be submitted.

What does the term ‘records’ mean?

By ‘records’ we mean your four recorded CPD entries, a peer discussion and a reflective account.

What does the term ‘reflective practice’ mean and how do you do it?

‘Reflective practice’ is a term with many definitions. For the purposes of revalidation we have chosen to use this definition: ‘the critical evaluation of practice and learning to find ways to improve outcomes for patients or service users’. You may find the following questions helpful in prompting reflection:

  • What happened?
  • What was I trying to achieve?
  • What went well and why?
  • What didn’t go so well and why?
  • How did it affect others? (particularly people using your services)
  • What were/are the consequences of me doing or not doing what I did?
  • What could be done differently next time?
  • What have I learnt from this that will change how I approach this situation next time?

What does the term ‘people using your services’ mean?

Pharmacy professionals work in many different places and provide their services to a variety of people (not just those who might be defined as patients). We have chosen to use the words ‘people using your services’ to refer to any person receiving services from a pharmacist or pharmacy technician. The term is inclusive so that it is relevant to all pharmacy professionals whether they directly interact with patients or not. The term includes, but is not limited to: patients, family and carers of patients, health professional colleagues, non-health professional colleagues, students or trainees, and organisations. When trying to identify ‘people using your services’ you may find it helpful to consider the ‘first level’ of people receiving or using your services, but it is also acceptable to consider those at different levels including people who may benefit indirectly.

Can you provide some examples of ‘people using your services’?

The people using your services will vary depending on your role, context of practice and the learning activity you undertake. Examples might include: patients, doctors, nurses, dentists, opticians, other pharmacy professionals, staff in your team, colleagues in other departments, networks or organisations, management, students or trainees, support staff, end-users of your products or services, customers (direct or indirect).

How long will it take me to complete my records?

Our research suggests that a majority of pharmacy professionals complete their records within about 4 hours and 30 mins. In most cases it will take under an hour to complete each of your planned and unplanned CPD entries. The time to complete a peer discussion, including time to identify a peer, to make arrangements for the discussion, prepare for and hold the discussion and write up the entry is variable. Our evidence suggests that in many cases it takes between 2 and 5 hours, and the actual discussion takes between 30 mins and an hour. The time taken to complete a reflective account is variable too and may take between 30 minutes and an hour.

How will my record be reviewed?

When you submit your records to us we will have some automatic checks to make sure that your record is complete and will let you know if you have further entries to make. Once your record is submitted it may be selected for review. Our selection process includes both random and targeted elements. We will let you know if your record is selected and tell you how long it will take before you know the outcome. If your records are selected they will be reviewed against our review criteria. We will also seek to contact your peer to confirm that your peer discussion took place. The review process will be undertaken jointly by a pharmacy professional and a lay reviewer. As part of the review of your record we may ask you to provide more information to enable us to verify that the information submitted relates to learning you have undertaken and to your context of practice.

What feedback will I receive following review of my record?

There are two types of criteria (core and feedback) that we will use to review your record. The core criteria, if not met, may lead to remedial measures where you are asked to submit more or revised records. The feedback criteria will be used to offer developmental feedback for your future records. If your records meet the review criteria we will tell you and send you a feedback report to help you with your future recording. If your records do not meet some of the core review criteria you may be entered into a period of remediation where you have another opportunity to submit records. If your records do not meet the core review criteria a second time we will follow the steps outlined in our statutory rules. We will not provide a feedback score.

Who are the professional and lay reviewers? How will they be recruited and trained?

Professional and lay reviewers will be recruited through our normal processes for appointing partners and associates to our organisation. We already have a pool of professional and lay reviewers who conduct our CPD review process and although we think the role for them will change in some ways, the skills and attributes that these reviewers have are appropriate for our revised approach. We think that we will need to conduct a round of recruitment in 2018 for new professional and lay reviewers because of the new approach to pairing reviewers and allocating reviews to reviewers from the same parts of our register will just take more people to do it. This is likely to mean that we need to appoint more pharmacy technician and lay reviewers and possibly some more pharmacists. We will advertise any additional recruitment through channels appropriate to each type of reviewer. We will be training our existing and new reviewers in advance of them conducting any reviews and will refresh their training to make sure the reviews happen consistently over time.

When is this all being introduced?

We are consulting at the moment so that means we have not made any decisions yet. Therefore the timeline below is just a draft and may alter depending on what we hear in the consultation and on what our council decides towards the end of 2017. 

At the moment, you will renew as normal and should continue to do and record CPD using our current processes and guidance. We will make it clear which of our registrants are affected and at which times.

In January 2018 we will be able to share with you the decisions that our council makes and the agreed approach to revalidation. This will include information about the format of recording (which is currently in our consultation document and we are seeking your views upon it). 

We plan to launch a new online portal integrated with MyGPhC in spring of 2018. This will initially only contain the new recording format for CPD so that we do not introduce too much change at once. 

In Autumn of 2018 the first groups of people renewing under the new arrangements will be asked to submit CPD records alongside their renewal declarations and fee payment. Reviews will start in 2019 and only look at CPD records NOT peer discussions or reflective accounts.

Later in 2018 we will launch the peer discussion and reflective account recording forms in the online portal. 

In Autumn 2019 we will ask the first group of registrants to renew and submit their full set of six revalidation records.  Reviews will start in 2020 for the full set of revalidation records. 

Why are you asking for ‘real’ examples?

Putting learning into practice is a good way to prove that you have actually learnt what you intended. We want you to submit records where you have a real (rather than hypothetical) example of how people using your services have benefited from your learning as this demonstrates to us that you are engaging in the process of reflective practice and a person-centred approach. If you have undertaken some learning but have not yet had the opportunity to put it into practice, or the benefits are not yet clear, you can return to the record and complete it at a later stage once benefits for people using your services start to emerge.

What happens to my existing records in the uptodate.org system?

The new recording requirements are very different and we will only be asking you submit the records for the previous year (rather than for a period since your last review) so we will not be transferring records from uptodate.org into the new online portal.

We will be “turning off” uptodate.org around the middle of 2018. Before then we will give you notice that you need to download all your records from there so that you can keep them for your own records. 

Will I be sent any reminders when my records are due for submission?

Yes. Reminders will be sent in line with formal notice given of your renewal deadline. We are also building optional reminders that you can set up for your recording. When the system is formally rolled out you will however be able to submit your records at any point throughout the year and the reminders will simply act as a prompt as the renewal deadline approaches. 

What if I cannot submit some or all of my records with good reason

There are sometimes reasons why you will not be able to submit some or all of your records at the point of registration renewal. This might happen for reasons such as sick leave, maternity or paternity leave, military postings, breaks from practice and possibly other reasons. Normally, if you have good reason, it will still be possible to renew your registration without submitting your records to us.

In some cases, it might be appropriate to accept the records that you can complete. If there are gaps in your records like this, they should not normally exceed 12 months.

In other cases, it might be appropriate to give you an extension so that you can submit all your records at a later date.

What happens if you do not submit some or all of your records without good reason?

If you are unable to submit your records without good reason we will enter you into a process of remediation which will include intervention from us and a requirement for your records to be submitted.

If you still do not submit your records after the period of remediation, we will commence a process called administrative removal, described in our rules. If you are removed from the register through this process, and you later reapply for registration, we will expect to receive and review your CPD, peer discussion and reflective account records as part of your reapplication.

How many years’ worth of entries will the GPhC assessors review?

If your records are selected for review the reviewers will review one years’ worth of records relating to your last year of registration. 

How long will the GPhC retain my records?

We are still to agree the exact time that we will retain records for, but we will only keep them for as long as we need to in order to carry out reviews. This will mean we will not keep your records for more than 18 months after they are submitted to us. We will also be automatically deleting records that are held in the system for some time that are not submitted to us, but we will give you the option to save them or download them so you do not lose them. 
 

Can I import records from another life-long learning portfolio?

We are exploring how we can make it possible to transfer records relevant to revalidation into our online portal from another life-long learning portfolio. We would like to prevent the need to record similar entries multiple times for those of you already undertaking activities for another purpose. This requires us to work alongside a number of different organisations who provide portfolios and to integrate both our requirements for recording and also technical systems. This may therefore be something that is challenging to achieve, but we committed to exploring the option because we know that dual recording is time consuming and not of benefit to you. 

Will pre-registration pharmacy students be able to make records?

The revalidation framework does not apply to pharmacy pre-registration students, however if our proposals are accepted then following implementation we will make some ‘dummy’ login details available to those in pre-registration training that will allow them to practise making entries in preparation for joining the register. These ‘dummy’ records will solely be for the purposes of allowing individuals to familiarise themselves with our revalidation processes and there will be no requirement to submit the records to the GPhC for review.   

Questions about the changes to CPD recording

It’s less to record, so it must be easier?

Our research suggests that a simple approach to CPD recording is quicker, more enjoyable, encourages participation, encourages reflection plus may help to facilitate recording entries closer to the time of learning than has previously been the case.

When should I make CPD entries?

You can undertake and record your entries throughout the year. You may find it helpful to start recording close to the time of the learning activity itself and return to the entry at a later stage once you have had the opportunity to put your learning into practice and reflected on the outcomes for people using your services.

What is the difference between planned and unplanned CPD?

Planned learning is when you decide to develop your knowledge and or skills in advance of undertaking a learning activity. Unplanned learning is when an event occurs that causes a learning activity without prior thought or planning, for example through reading a journal or talking to a colleague. These types of learning can feed into one another. A planned learning activity might lead to an unplanned one or the other way round. Although patients and the public have told us that they prefer to see planned learning activities to provide them with assurance that learning and development is taking place, we have included the option to record both planned and unplanned learning because pharmacy professionals have told us that they find both approaches useful.

How long should my CPD entry be?

Our in-house research suggests that CPD entries rated as ‘good’ are consistently between 200 – 400 words in length. We suggest however that when making CPD entries you focus on meeting our review criteria rather than the number of words.

Is it okay for me to submit CPD entries that relate to the personal relevance or impact on myself rather than to people using my services?

You should continue to undertake as much learning and development as is necessary for you to be able to practise safely and effectively but for the purposes of submission we only want to see CPD entries that are relevant and have a beneficial impact on people using your services

Is it okay to submit CPD entries that will benefit people using my services rather than entries that have benefited people using my services?

No. We ask that you give an example of how the learning has benefited people using your services. The tense of the question is deliberate as we want to hear about the actual outcomes for people using your services as a result of putting your learning into practice.

Questions about introducing peer discussions

What is a peer discussion?

A peer discussion is a learning and development activity that encourages you to engage with others in your reflection on learning and practice. Research indicates that having an external view can help pharmacy professionals to reflect on their practice and can also reduce the potential for professional isolation. To be most effective, these discussions should be formative, open and honest with someone who you trust and respect and should relate to your activities over the past year.

What is the difference between a peer discussion and a peer review?

A peer review is a learning and development activity that encourages you to engage with others and typically involves some form of judgment or assessment of your performance. A peer discussion is similar but should be formative in terms of how it influences your development and your peer is not expected to make an assessment of you. Some pharmacy professionals may find it helpful to consider using their existing processes for peer review (for example, annual appraisal) as a suitable vehicle for completing a ‘peer discussion’.

How do I find a peer?

You may find your peer(s) through your employer, an education and training provider, a professional body or association or local or national networks. We know that some peer discussions may happen spontaneously rather than being planned and be just as effective, however, these are generally less effective as preparation, including thinking about the discussion in advance, will make the discussion more effective.

What sort of guidance will be available to my peer?

We will produce guidance setting out the expected role of the peer, how the process should work, how long the process should take, questions to prompt reflection, what should be recorded on the peer discussion form, advice relating to fitness to practise concerns.

What kind of people can be peers?

For many of you the most effective peer relationship would be with another pharmacy professional. However, for some of you, it may be appropriate to consider a peer from another health profession or possibly someone who is not a health professional but has insight into the kind of work that you do, for example, some pharmacy leaders may consider seeking out someone in another leadership role who is not a pharmacy professional. You may also have different peers at different stages of your career. Your peer should be someone who understands aspects of the work that you do and someone that you respect and can trust. This might mean it is an individual you work with, or a group of people with similar roles to you, someone with the same or similar professional background, or a colleague from a multidisciplinary team.

The relative status of the peer does not appear to matter in terms of prompting discussion and you may choose a peer who has a different level of authority to you. Choosing a peer is important and you should think about perceptions in terms of independence and authority. We would strongly recommend that you do not choose anyone with whom you have too close a relationship as a peer, such as a family member or a very close friend.

What if I have a problem with my peer?

If your peer discussion does not go well you can choose a different peer.

Will my peer pass over information to you about me?

In some very rare circumstances it might be the case that discussions cause concerns about a pharmacy professional’s fitness to practise. You and your peer should refer to our guidance on raising concerns if this happens.

How will you make sure peer discussions are robust?

On the peer discussion form we ask you to send us the name, contact details and the role of your peer. If your records are selected for review we will seek to contact your peer to confirm that your peer discussion took place. We will not ask for details of the discussion, simply confirmation that it happened.

How long should my written peer discussion be?

Our in-house research suggests that a peer discussion record rated as ‘good’ is typically between 200 – 400 words in length. We suggest however that when recording your peer discussion you focus on meeting our review criteria rather than the number of words.

What should my peer discussion contain?

Your record should contain information on why you chose this peer, how the peer discussion has helped you to reflect on and make improvements to your practice, and a real example of any beneficial outcomes for your patients or service users as a result of making changes to your practice. You may also wish to include any feedback about your practice that you have had from other people. You are not required to include information on the subject(s) discussed if you feel the contents are confidential.

Is it okay for me to submit a peer discussion that relates to the personal relevance or impact on myself rather than to people using my services?

We want you to tell us how the peer discussion has helped you to reflect on and make improvements to your practice, plus give a real example of any beneficial outcomes for the people using your services as a result of making changes to your practice.

Is it okay to submit a peer discussion record that will benefit people using my services rather than entries that have benefited people using my services? 

No. We ask that you give an example of how the learning has benefited people using your services. The tense of the question is deliberate as we want to hear about the actual outcomes for people using your services as a result of putting your learning into practice.

Questions about introducing reflective accounts

What is a ‘reflective account’?

The purpose of the reflective account is to encourage you to think about how the work you do as a pharmacy professional relates to our standards for pharmacy professionals. Our pharmacy revalidation framework is based on affirming the core standards for safe and effective practice on a continuous basis. Evidence suggests that producing a reflective account that focuses on how you meet our standards increases awareness and understanding of the standards and helps towards reflecting on how practice affects the people using your services.

How is a reflective account different from a CPD entry?

Your reflective account is a type of learning activity that has a focus on how you meet one or more of our standard(s) for pharmacy professionals. Your CPD entries do not need to focus on the standards, but should be relevant to the safe and effective practice of pharmacy and relate to the context of your practice including any specialisations.

Which standard(s) can I use for my reflective account? How and when will you let me know what standard(s) to use?

We will tell you each year which standard(s) you should provide a reflective account on via your online portal, through our renewal correspondence, in the recording forms, on the website, and through Regulate. You will know which standard(s) you should reflect upon well in advance of needing to submit records to us as part of your renewal.

How long should my reflective account be?

Our research suggests that a reflective account rated as ‘good’ is typically between 200 – 400 words in length. We suggest however that when recording your reflective account you focus on meeting our review criteria rather than the number of words.

What should my reflective account contain?

The main parts of your reflective account will be: a brief summary of your practice history for the last year including who the typical users of your service are, a statement of how you have met one or more of our standards for pharmacy professionals and examples of how people using your services have benefited. We also want you to tell us briefly about your work (setting of practice, main roles and responsibilities, typical users of service) as this type of contextual information is helpful if your records are selected for review and also as a means for you to consider if the people using your services have changed.

Is it okay for me to submit a reflective account that relates to the personal relevance or impact on myself rather than to people using my services?

You should continue to undertake as much learning and development as is necessary for you to be able to practise safely and effectively, but for the purposes of submission we only want to see records that have relevance to the people using your services.

Is it okay to submit a reflective account that will benefit people using my services rather than entries that have benefited people using my services?

No. We ask that you give an example of how the learning has benefited people using your services. The tense of the question is deliberate as we want to hear about the actual outcomes for people using your services as a result of putting your learning into practice.