GPhC proposals do not go far enough for revalidation, says PDA


THE General Pharmaceutical Council’s proposed revalidation framework should be renamed continuing professional development (CPD) as it does not constitute revalidation, or an assessment of fitness to practise, the Pharmacists’ Defence Association (PDA) has said in its response to the GPhC’s revalidation consultation.

The reasons given by the organisation were that they did not include any formal appraisal, by a senior pharmacist, of a registrant’s practise; would not detect impaired performance at an early stage; and were not sufficiently rigorous.

In addition the PDA said they did not meet the definitions of revalidation given by the Council for Healthcare Regulatory Excellence, the Professional Standards Authority, or the Department of Health, and were different in principle to the legal definition in the Medical Act 1983 (though the Act itself does not apply to pharmacists).

Mark Pitt, director of defence services at the PDA told Pharmacy in Practice: “The proposed framework of undertaking professional development and learning, could be of benefit to pharmacists’ practice.

“However, the public might reasonably expect the term ‘revalidation’ to mean that the GPhC is validating once again, on a proposed annual basis, that its registrants have been formally assessed as fit to practise in a modern context and have up-to-date knowledge which is relevant to their sphere of practise. Our view is that the term may provide assurances to the public that may not be justified by a closer examination of the framework.”

“The PDA believes that the GPhC needs to reconsider whether the framework it has proposed should be referred to as revalidation. It does not include a formal appraisal by a senior pharmacist and our view is that it is otherwise not sufficiently rigorous to justify using that term.

“Having spent three years developing it as a ‘continuing fitness to practise’ framework, we were surprised when the GPhC informed us three weeks before the launch of the consultation in April that it was changing the name to revalidation. The framework doesn’t appear to meet the definitions of revalidation set out by the Department of Health, the Professional Standards Authority and others.

“We also believe that the GPhC needs to undertake a detailed root cause analysis to understand the apparent poor engagement and/or capability of pharmacy technicians to get involved in and complete all required records during the pilot”.

Other recommendations in the PDA submission included:

  • The review of CPD, peer discussion and reflective account records submitted by GPhC registrants should be conducted by pharmacists. Review by those who are not pharmacy professionals, including pharmacy technicians and lay persons, should be discouraged.
  • Records from a Royal Pharmaceutical Society faculty portfolio should be easily transferable to the GPhC’s online CPD, peer discussion and reflective account recording system.
  • Employers must not be able to designate with whom pharmacists are to hold their peer discussions.
  • There should be more stringent controls on who may act as a peer for the peer discussion.
  • There should be a separate revalidation framework for chief pharmacists, superintendent pharmacists and pharmacy owners, to assess whether or not they are (and remain) fit and proper persons to hold their positions of responsibility.
  • The GPhC should impose a mandatory requirement on employers to provide protected time to complete the activities involved in meeting its proposed “revalidation” requirements.
  • The GPhC must ensure it does enough to avoid putting at a disadvantage those pharmacists who work part-time or in remote or isolated roles through the requirement to hold a peer discussion.



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