GOC's CET review consultation
Our response to the consultation, August 2020
The consultationIn summer 2020 the GOC consulted on changes to its Continuing Education and Training (CET) scheme to make it more flexible and less prescriptive.
Section 1: Change of name
Q7 What impact, if any, will changing the name of the scheme to CPD as of January 2020 have on you/your organisation?
Q8 Please explain your answer
The name CPD also better represents a system that supports self-directed learning, reflection and professional development. The change of name could help to signal a change in approach and learning culture to registrants if communications are properly aligned with the implementation of changes. Communications about a culture of post-registration education that gives individuals more control over learning should form part of the GOC’s implementation plan for the review. The implementation plan also needs to acknowledge the impact of the pandemic upon registrants.
The AOP currently uses the term CPD to describe education and training for the wider practice team beyond GOC registrants, so in the light of this proposal we are considering our own messaging for 2022 and beyond.
Section 2: Freeing up the scheme
Q9 What impact, if any, will replacing the current CET competencies with the Standards of Practice for Optometrists and Dispensing Opticians have on you/your organisation?
Q10 Please explain your answer
We welcome the move to give registrants more freedom to decide what CPD they do, based on their scope of practice and learning needs. Individual registrants should have control over what they access and the pathway they take through the CPD system.
It is logical and less restrictive to link the scheme to the standards of practice rather than the current CET competencies. This link to the standards of practice supports a move away from what is often seen as a box-ticking ‘skills maintenance’ scheme to one that allows individuals to consider their own learning needs and clinical practice.
The current points-based system is well understood, and we think it makes sense to retain this approach. Registrants and providers will need guidance and support from the GOC in navigating the new scheme, and this should form part of the communications and implementation plan for the scheme.
Registrants currently expect to spread points throughout the three-year cycle. Although this is not a formal requirement of the current scheme, we think that framing it as an “expectation” is helpful for registrants, because it gives a ‘soft’ steer that they should spread their learning across the cycle. We therefore think this approach should remain unchanged in the new scheme.
Our members have told us how much they have benefited from being able to access interactive webinars and peer review online during the COVID-19 pandemic, noting that peer review in particular is the best way to learn, but that they often have difficulties attending these sessions in person.
It is clear that optometrists would do more interactive learning and peer review if they were able to access it flexibly – online or in person. Having the means to access interactive content in different ways should allow registrants to choose the method which best suits their needs, and will be particularly helpful in ensuring equitable access for those with family, caring or other commitments restricting travel, and those who live in more remote locations. We would therefore like to see the GOC ensure that the innovation and expansion in online training, which has been necessitated by the pandemic, continues into the future.
In the new scheme, individuals will be responsible for identifying their own scope of practice and what ongoing training they need to safely practice. The system may therefore need to become more directive in some areas, to ensure that enough people have the skills that are needed for patient care delivery as the profession evolves.
The focus of the scheme is rightly upon empowering individuals to consider their own highest areas of risk through self-directed learning. Re-skilling and upskilling to enable professional development should complement this learning and be integral parts of a CPD scheme.
Section 3: CPD domains
Q11 What impact, if any, will requiring registrants to undertake CPD in the domains identified have on you/your organisation?
Q12 Please explain your answer
Again, we welcome this as a logical development, linking CPD to the standards of practice, and allowing more scope for individuals to choose CPD that is relevant for them, rather than taking a tick-box approach based on a longer list of competencies. The current system also makes it difficult to cover important issues that do not fit neatly into a competency framework, such as clinical governance and failsafe procedures.
We also welcome the proposed new 'addressing risks' domain. The inflexibility of the current scheme means that it is not good at meeting skills needs arising from evolving service delivery.
However, as with the other consultation proposals the GOC has provided limited detail about the mechanics of the scheme and how mapping individual items of CPD to the different domains will work, as well as what guidance and support the GOC will provide to registrants and providers about its operation.
We understand that the detailed arrangements for mapping CPD products to the domains will form part of the final scheme design and we look forward to understanding more about this. Clearly some CPD items will be relevant to more than one domain, and we think it is logical to build this into the scheme so that CPD providers can indicate all the domains to which an individual item of CPD is relevant, and registrants can then allocate CPD to the most relevant domain based on the registrant’s own learning experience.
We particularly want to understand more about how the ‘addressing current risks’ domain will work. Although the GOC has said it does not expect to introduce this until the 2025-27 cycle, it seems possible that it could be introduced sooner. In that event it will be important for both CPD providers and registrants to have adequate notice of the change.
Section 4: Non approved CPD
Q13 What impact, if any, will allowing registrants to use non-approved CPD to count as points towards their CPD have on you/your organisation?
Q14 Please explain your answer
It is important for registrants to have access to high quality CPD across the full range of professional roles and clinical activity. Content should be designed and delivered by professionals from different backgrounds and perspectives.
We support the introduction of some flexibility for registrants to decide what content to choose for CPD and to allow the use of material from non-approved sources.
Allowing registrants to gain points from non-approved educators will be of particular benefit for optometrists who work in hospitals and for optometrists who wish to gain an IP qualification or explore other relevant, out of sector content, in line with their scope of practice and aspiration. The most helpful courses for IP Optometrists, for example, are often those run in-house for junior doctors. Enabling optometrists to use these courses and CPD from the Royal College of Ophthalmologists, and other medical/health CPD providers, is a positive move.
Expanding the types of professional activities that can be counted as CPD reflects the desire held by the profession, for CPD to capture ‘real life’ or ‘in practice learning’. This change will require a platform which allows registrants to upload a variety of different types of evidence to demonstrate their learning.
However, moving from a system where every piece of CET must be approved in advance by the regulator, to one where registrants can choose up to 50% of their CPD from non-approved providers, is a significant change which raises potential risks. For instance, it may lead to registrants selecting CPD which:
- isn’t designed for optics and isn’t relevant to optical registrants (or in the worst case, provides unhelpful or dangerous advice for clinical practice)
- is designed for optics but not in the UK context, so doesn’t reflect the UK’s legal or regulatory requirements, or its service delivery landscape
- is designed for UK optics, but its quality and/or delivery are poor because the provider isn’t experienced in the content topic or in the design and delivery of effective CPD material
If registrants choose inappropriate CPD as a result of this change, it will adversely impact the value of their learning, and it could also present practical challenges to the registrant and the GOC if numerous pieces of CPD are subsequently rejected through audit.
Although our members have varying views on the severity of these risks, we think these risks need to be mitigated, at least in the first CPD cycle using this new approach. We therefore recommend that for the next CPD cycle the GOC adopts an incremental approach and allows registrants to obtain up to 25% of their CPD from non-approved sources. Depending on the outcome, this percentage could then be increased in the next cycle. We also recommend that the one compulsory peer discussion comes from an approved source.
The GOC may also want to consider whether it could define a broad category of ‘recognised’ but non-GOC-approved CPD providers, such as other regulators and established professional bodies, to help registrants choose their CPD sources. Our Hospital Optometrists’ Committee would support hospital optometrists obtaining up to 50% of their CPD requirement from non-GOC-approved sources that the GOC had identified as recognised CPD providers.
We understand that the GOC considers the proposed new peer-to-peer reflective discussion process may also help to mitigate risks arising from the use of non-approved CPD. However, we think this is only likely to provide very limited mitigation in practice – because it is a new element of the CPD system, it may only take place right at the end of the cycle, and practitioners may not always feel able to challenge their peers’ CPD choices. Allowing a lower percentage of non-approved CET in the next cycle will provide a more robust safeguard.
Section 5: Reflection
Q15 What impact, if any, will introducing a mandatory requirement for reflection have on optometrists, dispensing opticians, employers, professional associations?
- Optometrists - Positive impact
- Dispensing opticians - Positive impact
- Employers - Positive impact
- Professional associations - Positive impact
Q16 Please explain your answer
It is unclear why the GOC is not proposing to make peer discussion for DOs mandatory. AOP, ABDO and other bodies were supportive of this proposal which was signalled in the 2018 GOC consultation. Whilst this might not be appropriate for all sessions there is a great deal of peer learning that can take place amongst professional groups that work so closely together in clinical practice. This would fit well with the GOC move to align learning outcomes for both professions. To facilitate this, the GOC should align the requirements for optometrists and DOs so that a single approval system is possible.
Finally, it would also be helpful to clarify the terms the GOC uses to describe reflection-based activity with peers. Under the current system we have (provider-led) peer discussion and (registrant-led) peer review, terms which are often used interchangeably even though they are slightly different things. We are now set to introduce a further ‘peer’ term into the mix which will be even more confusing.
One solution would be to drop the term 'peer review’ in relation to the current system and simply have 'peer discussion' as an overarching term for both provider-led and registrant-led activity. The prefix 'provider-led’ or 'registrant-led’ would be redundant most of the time which would make things easier for both the provider and registrant.
This approach would free up the term ‘review’ to form part of the new peer-to-peer exercise as ‘peer-to-peer review’. Whatever approach is chosen it must be clear, consistent and well explained to registrants and providers to avoid confusion.
We also welcome the proposed additional flexibility in how registrants can document their planning and reflection. Along with our ask for the GOC to provide model examples of practitioner types, we think providing examples of CPD cycle plans would also benefit registrants.
We have argued in the past that the GOC should allow more flexibility in how registrants may meet the existing requirements for reflection – for instance, through remote discussion with smaller numbers of registrants than are currently permitted. The requirement for peer review sessions to have at least four participants could safely be reduced to a requirement for two participants, since the number of participants isn’t a factor in the quality of discussion or learning experience. We also think it is important to retain the current flexibilities for virtual peer discussion that have been introduced in response to the pandemic.
Section 6: CPD approvals and audit
Q17 What impact, if any, will this new CPD approval system have on you/your organisation?
Q18 Please explain your answer
We understand that current established providers like the AOP will not be required to submit 10 first pieces of CPD for approval under new scheme.
As with other proposals set out in this consultation, it would be useful for us to have more detail about the new CPD approval system. A clear understanding of the proposed audit process and the process for approval of peer-led review would be helpful. We would also like to know what the expected annual cost for being a CPD provider will be and whether registrant-led peer-review will still require approval.