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Continuing Fitness to Practise Fiona Browne and Tim Walker 18 July 2013 Introduction What we want to achieve today: • Develop a common understanding of the changing political context around ‘continuing fitness to practise’ • Share some key findings from the revalidation pilot and CPD consultation • Hear your views on emerging ideas What is continuing fitness to practise? • How registrants demonstrate that they continue to meet standards • How the General Osteopathic Council shows that registrants continue to meet standards • A process that does this in a proportionate way that genuinely enhances practice, rather than a ‘tick box’ exercise Our presentation • Political context • Method for informing GOsC proposals. • Findings from the Revalidation Pilot and emerging questions • Findings from the CPD Discussion Document Consultation Analysis and emerging questions • Examples of possible elements of a scheme • Next steps Political context Date Event Key findings 2006 GOsC CPD Scheme GOsC practitioner directed CPD scheme requiring 30 hours of CPD each year and at least 15 hours of CPD learning with others. 2007 Trust, Assurance and Safety ‘Public opinion surveys suggest that people expect health professionals to participate in the revalidation of their registration and that many believe that this already takes place.’ 2008 Principles of ‘Revalidation confirms that the registrant is practising in non-medical accordance their regulator’s standards and will identify for revalidation further investigation, and remediation, poor practice where local systems are not robust enough to do this or do not exist.’ 2009 Consultation Consultation on four stage revalidation scheme (including selfon GOsC assessment, bespoke assessment of practice and Assessment of Scheme Clinical Performance) which requires a ‘pass/fail.’ Political context Date Event Key Findings 2011 Enabling ‘Continue to develop the evidence base that will inform their Excellence proposals for revalidation over the next year. For those professions where there is evidence to suggest significant added value in terms of increased safety or quality of care for users of health care services from additional central regulatory effort on revalidation, the Government will agree with the relevant regulators … and the relevant professions the next steps for implementation.’ ‘In the meantime, the key responsibility for ensuring continued high quality care will remain with employers, providers and commissioners of services, the teams who assess and provide care and with individual professionals themselves. It is there, closest to the point of care, that any risk is most effectively and most promptly addressed.’ Political context Date Event Key Findings 2011 Health Committee Scrutiny of the NMC ‘The current standard for re-registration—completing 450 hours of practice and 35 hours of professional development— is wholly inadequate, as this tells patients and the public nothing about the quality of nursing and midwifery practice undertaken by the registrant. There is also no routine assessment of whether nurses and midwives have even met this minimal standard.’ 2012 GOsC Stage 1 self-assessment piloted and developmental (rather Revalidation than pass/fail) feedback provided. Pilot Individual detailed feedback about strengths and areas of development identified in the evidence provided to each participant who submitted a portfolio. PSA Report 2012 The Professional Standards Authority has published An approach to continuing fitness to practise which sets out contemporary expectations about nonmedical revalidation The outcome required The outcome of revalidation or equivalent … should be that: • registrants demonstrate they are safe and fit to practise • regulators should be able to provide assurances of the continuing fitness to practise of its registrants • This can be achieved by means other than formal revalidation Key factors • Compliance with continuing professional development requirements is not in itself a demonstration of continuing fitness to practise • Professional regulators can support and encourage quality improvement • Regulators of lower risk professions may not need to have such high levels of confidence in their decisions In summary • It doesn’t have to be revalidation but it can’t just be CPD • Therefore we have the opportunity within the osteopathic profession to develop our continuing fitness to practise scheme without the use of a pass/fail assessment • But the desired outcome must be maintaining and improving standards, and identifying and supporting development needs Registrant expectations Annual registration renewal with no CPD (old GMC) Patient expectations New GOC scheme core QA ‘d CPD plus peer review Current GCC consultation proposal Test of competence (e.g. PPP) or practice-based assessment Complexity/cost/level of assurance Current GOsC hoursbased CPD scheme Revised GOsC continuing fitness to practise scheme ‘Developmental’ schemes GOsC revalidation pilot GMC (annual appraisal plus fiveyearly revalidation) ‘Pass or fail’ schemes Informing our thinking • Developed and consulted on a draft revalidation scheme • Conducted a year-long revalidation pilot • Developed and consulted on a CPD Discussion Document analysing our current scheme and looking at options for change • Ongoing engagement and dialogue with interested parties The Revalidation Pilot Why What When • Testing a process supporting self-assessment • Identifying costs, benefits and proportionality • Four themes of the Osteopathic Practice Standards • Complete four templates – including patient feedback, clinical audit, structured reflection and case-based discussion • Independent data collection every three months • Independent report submitted to GOsC December 2012 Completed by 1 in 18 of all registered osteopaths What worked well • High awareness of the Standards • 74% of participants reflected more on areas of clinical practice • The pilot tools enabled osteopaths to document practice • Patients liked the idea of providing feedback • 37% to 44% of practitioners changed the way that they practised as a result of using a tool • 85% of assessors felt their role enabled them to critically evaluate their own practice What worked well ‘I have seem some excellent evidence which has triggered questions about my own practice both on a management and a clinical level. Seeing what other clinicians do well or not so well is invaluable to me as a practitioner.’ (Assessor) ‘I have where possible reflected on weaknesses ... generally I am spending a little longer with a new patient, checking … that they understand what I intend to do, with consent and explaining more of a long term plan with them. (Participant) Questions • How could we continue to build awareness of the Osteopathic Practice Standards: communication and patient partnership; knowledge, skills and performance; safety and quality and professionalism? • How could we encourage continued higher levels of reflection on practice? • How can we encourage and support feedback on practice? What needs to be improved? • Complexity of scheme, e.g. volume of mapping grids, kinaesthetic nature of osteopathy at odds with paperwork, complexity of 3-D matrix of evidence requirements • Time requirements, i.e. the time required was disproportionate (based on four pieces of evidence and a selfassessment in one year) • Communication, e.g. simplifying the support materials What needs to be improved? • ‘Simplify, simplify, simplify’ (participant) • ‘Simplify and clarify, The assessment manual is ridiculously long’ (assessor) • ‘Too much to do’ • ‘The manual was very complicated and the language too complex’ • ‘Overwhelming’ • ‘May have been better presented in bite sized chunks’ (participants) Questions • How could we reduce the time spent on the requirements to demonstrate continued fitness to practise? • How could we reduce the burden of the mapping of evidence – that is showing which piece of evidence relates to which standard? • How can we reduce the complexity of the structure (the 3-D matrix of requirements)? Self assessment and reflection • The difference between the participants’ selfassessment and the views of the assessors challenge the principle of self-assessment • The ability or willingness of participants to demonstrate reflection on the data collected was variable Self assessment and reflection • ‘Some of the participants felt that it was very difficult to reflect on their practice without being seen to criticise their practice and expose themselves to risk of scrutiny by the GOsC’ • ‘Pilot scheme ‘assumes’ that osteopaths are able to write reflectively, whereas no formal training is currently offered to osteopaths in this area’ Questions • Should we explore other ways of demonstrating continuing fitness to practise e.g. more formal assessment? • How might we strengthen self-assessment? • What roles could other organisations or groups play in the process to support honest reflection in practice? • Could more local or peer scrutiny work in the osteopathic context? Consent • A further issue identified is that consent is not always being gained and/or documented appropriately • This is evidenced by: – participants – insurers – patients – findings from other research Questions • How could we work together to improve the patients experience in relation to consent? • What support should the GOsC provide? • What support should other organisations provide? CPD Discussion Document CPD Discussion Document published from September 2011 to September 2012 – 441 responses including: • • • • Online questionnaire: 84 responses Regional Conferences: 333 responses Regional Network Meetings: 10 responses Other professional and regulatory bodies: 14 responses Findings – aims and principles of CPD • To keep up to date with osteopathic/healthcare practice/embed knowledge and maintain skills within the changing context of patient and societal expectations • To strive to continually improve standards • To learn new things • Proportionate, accountable consistent, transparent, accountable agile • Relationships with other health professionals • Research and osteopathic principles Findings – learning cycles • Makes the process more conscious • Support osteopaths to undertake CPD annually ‘Could be used. There would be a need for the profession to be trained in this process. I’d like to see the option of using this learning cycle.’ Findings – learning cycles • Limited support – boxed-in and form filling • ‘too academic and complex’ BOA • ‘the current CPD scheme was hard fought to maintain the right to pursue personal interest and not be forced into the learning cycle mentality’ Sutherland Society • ‘opportunistic learning can be as valuable as activities planned well in advance’ GCC Questions • How can we strike a balance between CPD that is purposefully related to the Osteopathic Practice Standards but also ensure that we don’t restrict registrants’ personal interests and personal development? Findings – core CPD content • ‘Could be advantageous if it concentrated on communication and professionalism’ OA • ‘Yes it means the registrants can maintain minimum standards of safe and effective practice’ HCPC • ‘Difficult for bodies with diverse membership/ registrants’ • ‘It limits the scope and range of CPD taken up by osteopaths and therefore the future development of the profession’ SCC Questions What roles could CPD providers, special interest societies and educational institutions play in the provision of CPD in the areas of: • communication • professionalism • consent Findings – CPD cycle/minimum hours • Length of cycle – very mixed – about 50% for retaining 12 months and remainder looking at longer periods • Number of hours – majority favour 30 hours as being about right Questions • Are we content that the minimum requirements for CPD should remain 30 hours including 15 hours learning with others? • What more needs to be in place to meet PSA’s expectations? • Would a longer cycle make it easier to include additional requirements? Findings – quality assured CPD • Some support for QA but more for other organisations to do, not the GOsC • Although polarised views • Clear objections also raised including: – Reducing diversity of CPD available – Increased cost – Concern about who would do it • 62.7% of osteopaths wanted more feedback about their CPD Questions • How could we build (developmental) feedback to osteopaths into a revised scheme? • Should we consider the role of QA further as we develop the role of other organisations in the continuing fitness to practise framework? Findings – why is CPD effective? • • • • • • • • It benefits my patients It helps me develop/stay up to date It extends and advances my skills I can use it It improves my knowledge and confidence It makes me safer and more effective I enjoy it I reflect How do you measure effectiveness? Method Online (n=63) Conferences and Meetings (n=274) Patient satisfaction/feedback 28 77 Clinical outcomes/patients get better 8 47 Don’t know/I don’t 3 45 Patient numbers/busyness of practice 9 40 Referrals and recommendations 16 38 Self-evaluation/reflection 3 36 Audit 16 29 Patients don’t drop out of treatment 4 24 Benchmarking/feedback from colleagues 2 14 Need support with this 0 10 Participating in the revalidation pilot / research 1 6 Conferences/CPD 0 2 Demonstrating continuing fitness to practise How could osteopaths best show they are up to date and fit to practise? Online (n=56) Conference (n=243) Existing CPD process 18 101 Modified CPD system (including a core/mapping to OPS/QA) 5 30 Completing revalidation 19 23 Test/exam 7 15 Contact with other osteopaths e.g. attending courses/meetings 2 15 Clinical audit 1 14 Patient feedback 2 13 I don’t know/difficult to do 4 12 Reflection on practice 0 8 Peer assessment/review 1 7 Full patient list 1 6 Lack of complaints 1 3 Questions • How can we build what many osteopaths are already doing into a continuing fitness to practise scheme? • What roles can other organisations play to support osteopaths to do this effectively? Where have we got to? • We know that we need to develop a scheme that goes beyond current CPD requirements • We have a variety of evidence of what works well and not so well • There are a number of individual elements that could be combined to produce a suitable scheme • We have not made any decisions on what those should be Some possible elements • • • • • • Overall process CPD Osteopathic Practice Standards themes Feedback on practice Demonstrating reflection Engagement Overall process • Do we keep the CPD scheme and have a separate continuing fitness to practise scheme or combine them? • What are the benefits/costs of either approach? • Which approach would best support osteopaths to demonstrate that they continue to meet the Osteopathic Practice Standards? CPD • Retain requirement of 30 hours and a minimum of 15 hours learning with others each year • Lengthen CPD cycle so that across a three year period other elements are added in Osteopathic Practice Standards Personal interests Communication and Patient Partnership Professionalism Consent Knowledge, skills and performance Safety and quality Feedback on practice • Choice of a small number of tools within a (longer) cycle, including: – Patient feedback and analysis – Peer and / or student feedback and analysis – Clinical Audit and analysis – Case based discussion and analysis – Complaints analysis – Structured reflection and analysis – CPD Courses Demonstrating reflection • Increase ways of demonstrating reflection and receiving feedback on this, for example: – Appraisal – this is already happening with a small number of osteopaths, primarily those in an educational environment – Peer review at local level – for example discussing and documenting learning with peers through a regional group or society – GOsC review, i.e. what was done in the pilot Engagement • Expectation that osteopaths will engage with the process – Undertaking the required elements – Interacting with others – Demonstrating positive response to feedback • Not a pass/fail for those who engage What happens next? Date Activity Spring to Autumn 2013 Consideration of findings of KPMG Evaluation and Impact Assessment and CPD Discussion Document consultation to identify all issues and options. Summer 2013 Discuss and listen to osteopaths, patients, osteopathic organisations and others as we develop revised proposals. Seminars. Autumn 2013 Publish framework proposal about regulating continuing fitness to practise. Winter 2013 Work with existing societies, providers, educational institutions and groups to develop resources to support osteopaths in the revised framework. Spring/Summer 2014 Publish more detailed guidance for consultation.