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How will the GPhC's revalidation plans work in practice?

The GPhC is proposing to revalidate pharmacy professionals from 2018

Lawyer Marie Dancer explores what pharmacists and the regulator can learn from how doctors are revalidated

In 2018, the General Pharmaceutical Council (GPhC) is proposing to introduce revalidation for pharmacy professionals. This will involve pharmacists demonstrating that they have kept their knowledge and skills up to date, to provide evidence that it is appropriate for them to retain their registration. 

The General Medical Council (GMC) rolled out revalidation for doctors in 2012, and there are some key lessons that can be learned from their experience.

What are the GPhC’s plans?

It is anticipated that the revalidation process will be gradually introduced between 2018 and 2020. The GPhC’s consultation has now closed, but the key proposed changes include:

  • Reducing and simplifying the recording requirements for CPD – requesting four instead of nine CPD entries
  • Introducing a peer discussion
  • Introducing a reflective account against one of the standards for pharmacy professionals. 
What is a peer discussion?

A peer discussion is a conversation where a pharmacist discusses with a fellow professional their own practice, learning, development and reflections. The aim is to reduce professional isolation and improve standards. 

The GMC’s revalidation process involves an appraisal rather than a peer discussion. The appraisal is conducted with a named ‘responsible officer’. For most doctors working in mainstream roles in hospitals or GP surgeries, finding a responsible officer does not present too much difficulty. 

However, for a small percentage of doctors, particularly those working in more isolated roles or locations, or those who primarily work abroad, it has been more challenging. Some locum doctors also found revalidation challenging, as many did not have a formal line manager with an overview of their practice. 

Who can you have a peer discussion with?

The GPhC appears to have recognised that compared to doctors, many registered pharmacists will work in smaller organisations and often without a line manager. The term peer discussion suggests that it does not necessarily need to be with a senior colleague or line manager – although no doubt this will often be desirable.

Ideally, the peer review should be with someone who you trust and respect, who you feel you can be honest and transparent with. For most pharmacists, this will be a colleague or a line manager. However, the proposals are flexible, and interestingly they set out that a peer discussion can be with another healthcare professional, or even someone else, providing they have sufficient insight into the nature of pharmacy and that the choice can be justified.

As well as having flexibility on who the peer discussion can be with, the GPhC appears to have taken feedback from the GMC into account by not formally including a feedback requirement. The medical revalidation system requires an analysis of 360-degree feedback, obtained from a variety of colleagues and other professionals. 

Compared to the GMC’s appraisal system, not having to give an account to the GPhC of the nature of the peer discussion may facilitate a more open conversation. However, there will inevitably be a significant variance in the effectiveness of the peer discussion. Given the extra flexibility compared to the GMC’s appraisal model, this may ultimately make it less effective, but only time will tell.

What is a reflective account?

A reflective account based on one of the GPhC’s standards will also be required for revalidation. The purpose of this is to demonstrate that the profession is familiar with, and continually reflecting on, their professional standards. 

The concept of written reflections is increasingly common in fitness-to-practise hearings for both doctors and pharmacists. Reflective writing is seen as a valuable technique to enable the registrant to demonstrate insight and remediation. However, for many professionals, it presents a genuine challenge, particularly for those who have been out of training for some time. The GPhC is therefore proposing to publish guidance and examples of a reflective account, which no doubt will be helpful.

What might happen after a revalidation review?

If the GPhC concludes that a pharmacist has not adequately complied with revalidation, they will be given another opportunity to comply. However, if the pharmacist continues not to meet the core criteria, then – similarly to the way that the GMC deals with this issue – the GPhC will begin the process of removing the pharmacist from the register. 

What do you need to know?

Ultimately it will be the responsibility of each individual pharmacist to comply with revalidation. Those who choose not to engage with revalidation will be at risk of being removed from the register. Weeding out registrants unable to demonstrate that they have maintained their knowledge and skills is perhaps one of the unstated but key motivations of a regulator when introducing revalidation.

Marie Dancer is a fitness-to-practise lawyer and managing partner at the national firm of solicitors, Richard Nelson LLP. She founded the Medic Assistance Scheme to help advise and represent pharmacists in regulatory matters.


Gaynor Devereaux, Locum pharmacist

Surely by undertaking CPPE exams and passing them that shows that you are keeping upto date in the areas chosen and the workshops allow for peer review as it is the only time one really gets to meet other pharmacists.  I suppose that CPPE will help us with the reflective bit as they had us do reflective essays with the antibacterial distance learning course.  Am I being too simplistic here, it just doesn't seem to be too big a problem but maybe I have just not understood all the niceties of it.  I think having to prove that you do really do the work for your CPD is only going to be helpful to yourself and patients.

Jonny Johal, Pharmacy Area manager/ Operations Manager

A pre-reg have to sit an exam to demonstrate knowledge, an essential part of a pharmacist's fitness to practise. I can't see how recording 4 e.g. drug companies sponsored 'working' lunches, having a discussion with one's chosen mates, and writing an essay about my ideals can demonstrate that I have kept up to date and fit to practise.

Revalidation should be what it says. My knowledge & practice should be examined to confirm that I am still current. If no examinations are involved, how is the GPhC going to catch those who are passed their 'best before' dates (or perhaps they don't want to)?

I suspect this (lacking in substance) proposal to 'revalidate' is here for the optics only, and to allow the multiples' area managers to remain on the register and do the odd locums here and everywhere.

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