The Pharmacists’ Defence Association says the General Pharmaceutical Council’s proposed framework for revalidation more accurately describes continuing professional development, as it does not include any formal appraisal by a senior pharmacist of a registrant’s practice, will not detect impaired performance at an early stage and is not sufficiently rigorous.

“The proposed framework does not constitute revalidation,” says the PDA. “The GPhC should re-establish the continuing fitness to practise advisory group with a view to considering whether a revalidation framework should be introduced, the practical aspects of what would be required, proportionality and the evidence for improvements in the safety or quality of patient care it would bring.”

Other recommendations from the PDA in response to the GPhC’s revalidation consultation include:

• The GPhC should analyse why only a small number of pharmacy technicians took part in the CFtP pilot and completed the required records. The regulator should then publish its findings
• The review of CPD, peer discussion and reflective account records submitted by registrants should be conducted by pharmacists
• There should be the ability to easily transfer records from a Royal Pharmaceutical Society Faculty portfolio to the GPhC’s online CPD, peer discussion and reflective account recording system
• The list of potentially valid reasons for not submitting records should be expanded beyond ill health and maternity leave
• Employers must not be able to designate who pharmacists can hold their peer discussions with
• More stringent controls are needed as to who may act as a peer in these discussions and the GPhC must ensure it avoids putting at a disadvantage those pharmacists who work part-time or in remote or isolated roles.

The union wants the GPhC to develop 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”. It should also impose a mandatory requirement on employers to provide protected time for registrants to complete the necessary activities.

The regulator should explain how any cost savings arising from the proposed framework will be invested in improving the protection it provides the public, the PDA adds.

The PDA’s full response can be seen here.