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Use of ChatGPT in revalidation could trigger FtP case, GPhC warns

The pharmacy regulator has suggested that pharmacists undertaking AI-assisted revalidation could face sanctions under a fitness-to-practise (FtP) procedure.

It follows concerns that some pharmacists have been using ChatGPT or other artificial intelligence (AI) writing software to generate continuing professional development (CPD) responses as part of their revalidation process.


A pharmacist talking to C+D on condition of anonymity said that they were personally aware of a small number of fellow pharmacists who had used ChatGPT to generate CPD answers and had submitted these to the regulator for their revalidation.


But in response to C+D questioning, the General Pharmaceutical Council (GPhC) said that it was “not aware of ChatGPT being used by pharmacists or pharmacy technicians to complete their revalidation”.



“Administrative removal”


However, the GPhC did warn that if a revalidation submission contained “false or misleading information”, this could result in the “administrative removal” of a registrant.


It stressed that the revalidation process is “one of the ways that we work with pharmacy professionals to provide assurance that the trust in pharmacy professionals is well placed”.


“It is important that pharmacy professionals reflect on their own learning and practice as part of the revalidation process,” it added.


Read more: GPhC: Regulation should not stop innovation, but online pharmacies must meet standards


The regulator told C+D that its “core criteria” for assessing and reviewing pharmacists’ revalidation records “specifies that registrants must ensure that records contain only true and accurate information”.


“If we have grounds for believing that records contain false or misleading information, we will investigate and may deal with this under our FtP procedures,” it said, adding that this “could result in administrative removal”.


Read more: ‘Pure greed’: Fury over 'unjustified' GPhC fee hike proposal


While the GPhC told C+D that its “frameworks and processes are regularly updated”, the regulator did not indicate that it is currently checking whether CPD answers were being generated by ChatGPT.


“It is possible that in the future we may need to consider the use or misuse of AI in the revalidation process, as well as many other areas of pharmacy regulation,” it said.



“Sample” of submissions selected for review



According to the regulator’s website, a “sample” of revalidation submissions are selected for review – some chosen randomly and some targeted such as those of registrants who have a “history of poor compliance” with GPhC standards.


Reviews are carried out by a pharmacy professional and a lay reviewer using the review criteria set out in the revalidation framework, it said.


Read more: 'Dishonest' pharmacist suspended for working two jobs at the same time


Those selected for review who meet the review criteria will not have their records reviewed again for the next two years, it added.


Pharmacists submitting their revalidation must make a “declaration” stating that they are “currently carrying out and recording revalidation activities and will continue to do so, in line with the GPhC’s standards and framework for revalidation and the standards for pharmacy professionals”, it said.



GPhC must mitigate against misuse



Nick Hunter – chief officer for Doncaster, Rotherham and Nottinghamshire LPCs – wasn’t personally aware of pharmacists using ChatGPT for revalidation.


But he told C+D that “people have been looking for ways around examinations etc for years, so why wouldn't they consider using [ChatGPT] for revalidation?”


The GPhC “absolutely” needs to “bring in some processes around how they would mitigate for people misusing the process and misusing AI and ChatGPT”, he said.


Read more: Full pharmacy revalidation requirements reinstated from October


Mr Hunter told C+D that the current revalidation process is overdue for a change and that the regulator “needs to revise” it.


“The process around revalidation and CPD just needs a complete overhaul anyway and this is just another reason why it needs an overhaul,” he said.


He added that his issue with revalidation was that it didn’t “engage” him personally in his CPD or help him learn in the way he “thinks it should do”.


Read more: GPhC claims fee plans 'still among the lowest' despite 7.5% hike


Meanwhile, he told C+D that he could see potential positive cases for the use of AI in the revalidation process.


He noted that community pharmacists “don’t come across safeguarding issues very often”, for example, and though training is done, they “don't get chance to practice that properly, because you don't come across those incidents”.


Read more: ‘Dispensing robots can fail. Pharmacy should be cautious with them’


AI could be used to bolster training in areas such as these so “when the situation does arrive, if it ever does, you'd be better equipped and more confident dealing with it”, he said.


“AI has a huge part to play in pharmacy, and in health in terms of training and development and CPD, but not in terms of manipulating revalidation,” he added.


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