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Feedback
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Proposed RPS response
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Purpose statement
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1
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the definition of ‘patient-facing’ in the document needs revising and bringing in line with the definition in the NHS consultant pharmacist guidance.
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we will change the term ‘patient-facing’ to ‘patient-focussed’ throughout the document.
we will also ensure the definition of patient-focussed mirror the wording the nhs consultant pharmacist guidance as below:
consultant pharmacists are expected to have a direct impact on patients or the population although this may not involve direct patient-facing contact; this may be on an individual level for those with the highest level of need or at a system or population level so that the maximum number of individuals benefit from their input
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2
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the purpose statement needs a greater focus on patients and how consultant pharmacist roles will directly benefit their care
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we will amend the purpose statement to more explicitly describe how consultant pharmacists can directly improve patient care, including how this will result in:
improved safety and quality in patient care
ensuring high standards of patient care across the UK
equity and consistency in patient care across the UK
consistency across population of an approach
efficient use of resources– large scale reduction in inefficiency and wastage.
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3
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the term clinical speciality throughout needs to be clarified to ensure it is inclusive to generalists and those practising in primary care and community settings
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we will change ‘clinical speciality’ to ‘area of clinical practice’ throughout the document and ensure the definition of this term makes it clear that this includes those who are generalists and those who work across all sectors of pharmacy, including primary care and community settings.
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4
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it needs to be clearer whether this credentialing service is available only to rps members or to the whole professions
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we will make this information clear at the beginning of the document, so it is clear to the reader that this credentialing service is open to all pharmacists, not just rps members.
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5
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the term ‘pharmaceutical care’ is too narrow and should be widened to clinical care in line with other professions e.g. nurses or medics
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part of pharmaceutical care includes more holistic clinical skills. by using this term, we are describing how consultant pharmacists will have a medicines leadership role across systems
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curriculum structure and content
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6
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there should be 4 domains and not 5 domains to align more closely with the four pillars of advanced practice
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we agree that close alignment with the four pillars of advanced practice is essential so pharmacists can be recognised easily and map evidence to multiprofessional frameworks. we have chosen five domains as we believe communication and collaborative working is an important domain across post-registration practice which requires its own domain structure. including all the content for these areas across different domains would also create unbalanced domains at different levels of practice.
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7
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it should be clearer how the curriculum domains align to the four pillars of advanced practice, the apf and the wider post-registration development structure.
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we will add a section to the document with diagrams showing how the consultant pharmacist curriculum domains align with the four pillars of advanced practice and apf. we will also include a diagram to show where this level of practice fits in to the wider post-registration landscape.
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8
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the curriculum outcomes need more explicit reference to how they will directly benefit patients
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we will strengthen the patient benefit aspects of the curriculum outcomes to make this clearer.
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9
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the curriculum outcomes relating to population level health should include descriptors relating to public health understanding.
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we recognise the importance of public health principles, particularly health improvement and health service improvement, for population-level health and hope to have implicitly included these principles in the curriculum outcomes.
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10
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medicines optimisation should be explicitly referenced in the curriculum outcomes.
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we have tried to only use terms and language recognised across all countries of the uk; medicines optimisation is not as a term routinely used across wales & scotland.
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11
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more detailed comments on specific outcomes and descriptors are detailed in appendix a in greater detail.
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assessment strategy
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12
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there should be more information on the recommended number of pieces of evidence needed to be included in the portfolio
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we understand why candidates would prefer to be provided with a prescriptive number of evidences per outcome; however, given the wide range of potential roles and evidence types, it would be very difficult to set a single maximum number for all. the number of pieces of evidence mapped to an outcome will depend on the individual being assessed, their area of clinical practice and the range and breadth of the evidence presented. to help candidates in this regard, we have however suggested a minimum of at least three pieces of discrete evidence mapped to each outcome.
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13
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the proposed assessment will be too onerous for the legacy workforce who are very busy delivering frontline services
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we understand that pharmacists are extremely busy undertaking their invaluable roles supporting patients, especially in the current pandemic situation. through this curriculum, we are trying to make the process of evidencing learning as flexible and embedded into day-to-day practice as possible to mitigate overburden. we do not want busy pharmacists spending hours at home mapping evidence and are working hard to ensure evidence can be mapped easily as part of everyday practice using our new e-portfolio. we also want to maximise the potential for the legacy workforce to have previously certified learning recognised to avoid duplication of effort.
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14
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calibration and standardisation of assessors undertaking SLEs in the workplace will be important – how will this be achieved?
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guidance will be provided by the RPS for anyone undertaking supervised learning events in the workplace so that they understand their role. collaborators will also be asked to assess in line with the curriculum outcome descriptors which articulate the level of performance expected of individuals practising at this level. we accept that there will still be some variability in judgments across workplaces as these judgments are subjective. in programmatic assessment programmes, however, subjective bias and inter-assessor variability is mitigated by the fact that each outcome is assessed using a breadth of different assessment tools; no individual decision is high-stakes and assessment data is aggregated and viewed holistically.
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15
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there needs to be more guidance for potential candidates about the sle tools, whether these are mandatory or not and how these should be used to build portfolios of evidence.
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we will be producing specific detailed guidance for candidates and collaborators when we launch the service. these will provide further information about the sle tools and give worked examples of when these could be used to evidence learning. we will also be providing supportive webinars about the use of sle tools to evidence learning.
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16
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it needs to be clearer that sles can be undertaken remotely using digital solutions
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we will make this clear in the curriculum as we agree that sles do not necessarily have to take place in person and can be effectively delivered remotely.
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stakes ratings
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17
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outcomes related to research are rated too low as are very important for the consultant pharmacist role
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the stakes ratings do not relate to the importance of the outcomes in terms of consultant pharmacist roles. we agree that research is an integral part to consultant-level practice and all candidates will be expected to demonstrate they have met the curriculum outcomes related to research to pass the assessment. however, as these outcomes have a less direct risk to patient safety, the clinical competence committee is likely to need fewer pieces of evidence to sign these off whereas outcomes with a high risk to patients will require more data points to inform the final pass/fail decision.
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18
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the purpose of the stakes ratings and how these were determined need to be articulated more clearly.
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we will work to clarify the language and include a summary in the document as to how the stakes ratings were determined by the consultant pharmacist curriculum t&f group.
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ccc
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19
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the process of how potential conflicts of interest are identified and mitigated for ccc members needs to be clarified.
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all members of the ccc will be asked to declare any conflicts of interest prior to assessing a candidate’s portfolio. those with a direct conflict of interest will not be permitted to assess the candidate. this process will be detailed in the assessment regulations.
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20
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more information is needed on how ccc members will be recruited and quality assured
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all members of the ccc will be recruited transparently by the rps and will need to provide evidence they have the requisite experience to meet the role descriptions. members of these committees will not be required to be rps members; we recognise we need the right experts around the table regardless of their membership status to make these important high-stakes decisions.
ccc assessment performance with respect to their peers will be monitored by the rps. given the group decision making nature of these decisions, it is important to note that no individual member will be able to ‘fail’ a candidate; this decision will need to be mutually agreed by all members of the committee.
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21
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ccc committees should contain a member who represents the sector of pharmacy practice in which the individual will work.
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we recognise this is important and anticipate that this criterion will be met by the clinical expert member.
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22
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the word ‘clinical’ in clinical competence committee is not appropriate as not all cp roles may be strictly clinical and not all members will be reviewing the portfolio from a clinical perspective.
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the term ‘clinical competence committee’ was drawn directly from the clinical education evidence base and is used widely in other parts of the world, such as canada.
we understand, though, that this committee’s remit is to assess both clinical and non-clinical aspect and we therefore will rename this to: “consultant pharmacist competence committee”
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inclusivity
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23
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part time staff and/or portfolio workers may not be exposed to the experience required to meet the curriculum outcomes.
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to help those working less than full time, we have tried to ensure the curriculum content can be achieved as flexibly as possible. we have not stipulated, for example, any time limit as to when the portfolio needs to be submitted and recognise that some individuals may need longer to complete the programme because of their working pattern or because they need to take a break in their career.
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24
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legacy workforce may be disadvantaged as their prior experience which has not been formally certified will not be easy to evidence.
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we want to avoid duplication of assessment as much as possible for the legacy workforce along with balancing our duty as a credentialing body to patients that those we credential have the knowledge, skills, behaviours and experience needed to practise safely at this highly advanced level. therefore, to recognise prior learning, we require for it to have been formally certified in some way. candidates can also demonstrate their prior experience through their portfolio by uploading any supporting evidence of this.
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25
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there should be a clear plan to mitigate any attainment gaps between groups of learners.
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we are committed to ensuring our curricula and assessments are inclusive to all. as stipulated in the curriculum document, we have tried to ensure as wide a range of voices in developing this curriculum and have a number of processes in place to monitor any differential attainment in assessment outcomes.
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26
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the curriculum is not inclusive as it is not applicable to non-clinical roles which should be included.
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we have widened the definition of ‘patient-facing’ to capture those roles with a direct impact on patient populations as well as individuals.
we recognise that this curriculum, however, focusses primarily on those in more clinically focussed roles. this is the first phase of our assessment & credentialing strategy and, once this is established, we will explore the potential and viability of the credentialing of non-clinical pharmacy roles.
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27
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the curriculum outcomes are currently too focussed on roles in acute secondary settings because of the definition of clinical speciality.
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we will amend our terminology to ensure it is clear these curriculum outcomes are designed for all sectors of pharmacy. we will rename ‘clinical speciality’ to ‘area of clinical practice’ to be more inclusive.
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28
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the curriculum outcomes will be easier to demonstrate in secondary care compared to primary care and community settings because of the structural barriers that exists in these.
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we recognise that secondary care settings may have traditional structures to support individuals undertaking this programme. we have tried to be innovative and flexible in our approach to minimise any difficulty for those practising in primary care or community sectors. for example, we have tried not to be prescriptive about how the support mechanisms and supervised learning events should be undertaken and hope that these can be delivered remotely.
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29
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the curriculum needs to be accessible for pharmacists working in remote and rural locations
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we agree and have tried to ensure this in the curriculum content. we would welcome feedback from those working in such settings if they believe that this is not the case.
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30
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the curriculum is not inclusive of the uk as scotland does not currently. have the relevant policy in place for consultant pharmacist roles.
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in scotland the pharmacist postgraduate career framework has now been published and includes practice at a level equivalent to consultant which aligns with this curriculum.
we have developed this curriculum with input from nes and have received a lot of engagement from scottish stakeholders on its content. this was with the aim of the curriculum being applicable in scotland in the very near future.
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31
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the recommended support structures in the curriculum document, such as access to expert mentors and coaches, need to be accessible across all sectors of pharmacy and geographies.
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we agree that this is important and are currently working with the respective educational commissioning bodies to explore how to develop and support individuals to meet the curriculum outcomes.
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learning & experience
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32
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the distinction between learning for a lead pharmacist and consultant pharmacist should be clearly stipulated
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we will include a reference in the curriculum document to the relevant section of the nhs consultant pharmacist guidance which clearly differentiates these roles.
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33
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there should be a minimum number of years post-registration experience prior to eligibility
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the curriculum has been designed to be outcome-based; therefore, we have not placed a minimum experience requirement as successful completion will be judged on demonstration of the curriculum outcomes. we recognise that different people will need different amounts of time to achieve these dependent on their individual circumstances.
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34
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there should be a minimum number of clinical education hours stipulated
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the curriculum has been designed to be outcome-based; therefore, we have not placed a minimum experience requirement as successful completion will be judged on demonstration of the curriculum outcomes. we recognise that different people will need different amounts of time to achieve these dependent on their individual circumstances.
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35
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the minimum standard of experience should be across more than a single sector to encourage cross-sector working
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we would actively encourage those undertaking the programme to gain as much cross-sector experience as possible. indeed, doing so would create rich evidence of learning against the curriculum outcomes. however, we recognise this may not always be possible for some roles or some geographies and would not want this to limit their ability to credential at this level.
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support
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36
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there needs to be greater clarity on how the proposed expert mentor and professional coach roles will be provided/funded and whose responsibility this is
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we will make it clearer in the curriculum document that these roles are only recommended and not mandated.
the curriculum was developed in collaboration with representatives from hee, nes and heiw and we are working with these bodies to explore how we develop these support structures across the uk.
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37
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it needs to be clear who will be eligible to act as expert mentors and professional coaches and how these will be quality assured e.g. can they be drawn from other professions; do they need to be rps members?
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we will make this information clearer in the curriculum document. these roles are not mandated, can be undertaken by anyone with the relevant experience (from across all professions) and they do not need to be members of the rps.
the rps will provide guidance of the knowledge, skills and experience we would expect from those undertaking these roles but would expect the candidate to nominate appropriate individuals to support them with their learning.
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38
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it may be challenging to find people with the time to fulfil these support roles as they may be too onerous.
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we understand the time pressures on the healthcare workforce, especially at this time. we have tried to make these roles as flexible as possible to mitigate overburdening individuals; we have not prescribed, for example, how often meetings should take place and encourage meetings to take place remotely.
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39
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the terminology of mentor and professional coach may be misleading as they do not fit with the traditional definition of mentoring and coaching. the nomenclature should be changed to avoid this confusion.
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we will make it clear that these roles are slightly different to traditional mentor and coach roles.
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40
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it needs to be clear whether these roles are mandated or optional and whether they need to be undertaken by separate individuals.
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we will make this clearer in the curriculum documentation.
these roles are not mandated, and an individual can undertake more than one role if they have the requisite skills and experience to do so.
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acpl
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41
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acpl routes for those who have achieved under the hee acp multi-professional framework should be clarified.
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any prior accredited certified learning, including any undertaken against the hee acp framework (or any other relevant framework) will be reviewed and considered as part of the acpl process described in the curriculum document.
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42
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a degree of apcl should be available for high stakes clinical outcomes and these should not be excluded, including for those who achieved mastery in faculty given that the curriculum is exclusively based on the apf.
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given the high-risk nature of these outcomes to patient safety, we believe it is necessary to ensure that all individuals demonstrate they currently meet the necessary standard prior to being credentialed as eligible to practise at this very senior level. we believe that a level of direct observation of practice is required to validate this level of clinical competence.
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format
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43
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the written information needs simplifying.
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we will try to simplify the language in the document to ensure it is accessible to all. we will also produce candidate specific guidance which will be more targeted to their needs.
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44
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the presentation of the document could be clearer.
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the document was designed in line with the rps curriculum quality guidance and presented in a similar format to comparable post-graduate curricula in other professions.
we will be producing more targeted, shorter guidance documents for candidates and other stakeholders. we will also be presenting key information on our website, so it is easier to assimilate.
we would welcome any feedback, though, on how the presentation of the information can be continually improved.
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45
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case studies on consultant pharmacists and their impact on patient care would be helpful
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case studies are available in the nhs consultant pharmacist guidance. we will also look to incorporate case studies in our website information to help bring the curriculum to life.
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