Reaccreditation of an Education and Training Programme to prepare Pharmacist Independent Prescribers, SwanseaUniversity

Report of areaccreditation event, 14 May 2015

Introduction

The General Pharmaceutical Council (GPhC) is the statutory regulator for pharmacists and pharmacy technicians and is the accrediting body for pharmacy education in Great Britain. The GPhC’s right to check the standards of pharmacy qualifications leading to annotation and registration as a pharmacist is the Pharmacy Order 2010. It requires the GPhC to ‘approve’ courses by appointing ‘visitors’ (accreditors) to report to the GPhC’s Council on the ‘nature, content and quality’ of education as well as ‘any other matters’ the Council may require.

The Swansea University programme was last reaccredited by the GPhC in 2012 for a period 3 years subject to 3 conditions. In line with the GPhC’s process for reaccreditation of independent prescribing programmes, an event was scheduled on 14 May 2015 to review the programme’s suitability for reaccreditation. The accreditation process was based on the GPhC’s 2010 accreditation criteria for Independent Prescribing.

Background

Swansea University was initially accredited by the Royal Pharmaceutical Society of Great Britainin 2008 to provide a programme to train pharmacist independent prescribers, having delivered a supplementary prescribing programme since 2004, and a conversion course from 2007.The programme was last reaccredited by the GPhC in 2012 for a period 3 years subject to 3 conditions. ; 1) evidence be provided to show that all prerequisites for entry are met (to meet criteria 2.1, 2.2, 2.3, and 2.4; 2) University learning outcomes be remapped to accurately reflect the GPhC learning outcomes and FHEQ level descriptors (to meet criterion 3.2); 3) the OSCE assessment criteria, both formative and summative, include the requirement for the student to identify the patient correctly (to meet criterion 5.3).

Documentation

The University provided copies of its application documentation in advance of the visit, in line with the agreed timescales. The application documentation was reviewed by the panel and it was deemed to be satisfactory to provide a basis for discussion.

The event

The event was held on 14 May 2015 at the General Pharmaceutical Council headquarters at Canary Wharf, and comprised a number of meetings between the GPhC accreditation team and representatives of the Swansea University prescribing programme.

The Accreditation Team

The GPhC accreditation team (‘the team’) comprised:

Name / Designation at the time of accreditation event
Professor Anne Watson
Professor Angela Alexander / Accreditation team member (Chair of event), Assistant Director of Pharmacy, NHS Education for Scotland
Accreditation team member, Professor of Pharmacy Education and Director of the Centre for Inter-Professional Postgraduate Education and Training, University of Reading

along with:

Name / Designation at the time of visit
Mrs Philippa McSimpson / Quality Assurance Officer, General Pharmaceutical Council
Dr Ian Glendenning Marshall / Rapporteur, Caldarvan Research (Educational and Writing Services)

Declaration of potential conflicts of interest

No potential conflicts of interest were declared.

The accreditation criteria

Accreditation team’scommentary
Section 1: The programme provider / All of the 4 criteria relating to the programme provider are met. (See Appendix A for criteria)
The Postgraduate Certificate (PGCert) in Non-Medical Prescribing Programme (NMP) is provided by the College of Human and Health Sciences (CHHS),Swansea University andquality assurance follows the University’s annual review, evaluation and monitoring processes. The course recently underwent review and was successfully approved by the College’s Curriculum Approval Board in accordance with the University’s procedure for validating academic programmes and modules. The team was toldthat the programme had changed since the last reaccreditation in that it had now been extended from 30 to 60 credits. The College has clinical practice suites on both its main campus in Swansea and at the St David’s Park site in Carmarthen, with facilities that offer multi-disciplinary clinical education and training.The programme currently offers one intake per academic yearwith projected student numbers for 2015/16 at 15 as a minimum and 30 as a maximum.The programme is commissioned and funded by the Welsh Government via the Workforce Education and Development Services (WEDS). The commissioned number for IP for 2014/15 was 27.Cohorts are a mixture of allied health professionals, nurses and pharmacists.The ratio of pharmacists to other health professionals is 1:2.The team was told that although the staffing complement has dropped from 3.2 FTE at the last reaccreditation due to staff departures, there is a 0.8 FTE post in the pipeline to bring the staff complement up to 2.6 FTE. The identified pharmacist is a graduate of the previous 30-credit IP course at Swansea and has contributed to the design and delivery of the new 60-credit programme, including a review of documentation. The team noted that the pharmacist was described as being employed on a casual basis, and was told that it was the intention to appoint him to an honorary position after he has gained experience as a sessional teacher.
Section 2: Pre-requisites for entry / All of the 6 criteria relating to pre-requisites for entry are met with 2 criteria requiring amendments.
All entrants must complete an application form that ensures that they meet the pre-requisites for entry to the course. The team note that the GPhC and PSNI registration numbers were not specifically requested, with the request being for the professional registration number; the team was of the view that the application form should specifically require GPhC and PSNI registration numbers. The team noted that the application form contained a section relating to any previous attempts to undertake a prescribing course and was told that any such applicants are considered on an individual basis. In particular, the provider needs to justify the use of funding for the course from the Workforce Education and Development Services (WEDS). All applicants are interviewed by group interview, but applicants that have attempted such a course previously are interviewed individually. The documentation submitted stated that course information and the application form stipulates pharmacist applicants must have at least two years appropriate patient-orientated experience in a UK hospital, community or primary care setting following their pre-registration year.The applicant is required to write a supporting statement and the line manager is asked to confirm that the applicant has up-to-date clinical, pharmacological and pharmaceutical knowledge relevant to the intended area of prescribing. Pharmacists without a line manager, for example self-funding or locum pharmacists, would obtain this sign off from the DMP and complete a self-declaration to ensure consistency, and would be interviewed individually.The team was told that the University maintains a register of DMPs allowing potential applicants to check on DMPs’ experience. Information on the role of the DMP and DMP handbook is sent to the DMPs, as part of the application process to appraise the DMPs of the potential commitments of the role. DMPs are visited by College staff during the first 2-3 months of the programme, allowing face-to-face discussion to take place in order to ensure that assessment criteria are being adhered to, offer any additional support and to discuss the progress of the student.
Section 3: The programme / Seven of the 8 criteria relating to the programme are met with one of the 7 requiring amendment.
The programme is taught at FHEQ level 7, carrying 60 credits. Formal taught contact hours are 204 (stated to be equivalent to 26 days) and 96 hours (equivalent to 12 days) in practice.The University requires 100% attendance and pharmacists must attend all clinical skills sessions. Student progression is monitored by teaching staff meeting with the students every 4-6 weeks, plus by the personal tutor system in place. Teaching staff also meet together with the student and their DMP in the practice setting, normally twice in the course of the programme. It was explained that the course runs from October to June but that resits could take the total duration to 1 year. All 10 course learning outcomes (LOs) are mapped to the GPhC 16 learning outcomes. However, the team noted a number of issues with the mapping exercise. The team agreed that the mapping in relation to pharmacist students should be amended and that it will be a condition of reaccreditation that the programme outcomes must be mapped fully and completely to all 16 GPhC learning outcomes, and that this must be communicated consistently to students and DMPs within the programme documentation.The documentation explained that a blended learning approach to teaching and learning is utilised, consisting of a mixture of classroom sessions, group work, reflective practice, problem based learning, role-play, critical analysis and discussion of issues observed in practice relating to prescribing. There is an enquiry-based focus to the curriculum, but other student-centred activities include: case studies, scenarios, small-group work, action-learning sets, workshops, pod casts, reflection, student presentations, supervised consultations with service users in practice and clinically focused tutorials.
Section 4: Learning in Practice / All of the 5 criteria relating to the period of learning in practice are met with 2 criteria requiring amendment
Specific documentation isissued to theDMP in relation to guidance and support, including guidance relating to supporting the student during the period of learning in practice, and the assessment criteria of learning in practice. DMP mentor workshops are offered to ensure the assessment criteria are understood and quality assurance of summative assessments is adhered to. The timetable includes prearranged times for teaching staff to visit DMPs, preferably with the student present. The team agreed that the DMP handbook required careful checking and appropriate amendment. Students will be supported by a DMP in order to achieve the minimum of 12 x 7.5 hour days of supervised practice. These hours will be logged by the student on the appropriate form. A final declaration is signed by both the student and the DMP to confirm the completion of hours. Failure in the period of learning in practice cannot be compensated by performance in other assessments and this is outlined in the student handbook.
Section 5: Assessment / All of the 4 criteria relating to assessment are met with 1 criterion requiring amendment.
The learning outcomes are achieved through summative assessment for the module consisting of a pharmacology MCQ exam, a drug calculations exam, 2 x Objective Structured Clinical Examinations (OSCEs), and a practice portfolio which includes the learning contract and clinical logs. The formative OSCEs are conducted in practice by the DMPs on patients in a specific area of practice. Two summative OSCEs are then conducted within the University setting, the first being a clinical station which is video recorded, with an examiner who is not part of the teaching team, and using actors as patients; students are required to formulate a treatment plan and write a prescription. The second is an in-depth discussion with the examiner and a staff moderator concerning the student’s clinical log. The programme team was aware, and the team noted, that the level 7 marking grid is not compatible with safe and effective prescribing and hence the assessments and awards have employed a policy which denotes that unsafe practice in relation to prescribing will override the marking criteria and the student will automatically be awarded a mark of zero resulting in a fail. The documentation stated that the programme operates a ‘zero-tolerance’ policy to failure. All failed components will need to be redeemed in order to successfully complete the programme.If a student fails an assessment on a matter related to patient safety, it is a requirement that they fail the whole programme and would therefore have to restart the course and not just re-sit the assessment. The team was concernedthat it could not find statements of this criterion in either the student or DMP handbooks. The team stressed to the provider that the lack of such statements could result in complications if a student were to appeal against failure based on this criterion and advised that the student and DMP handbooks be revised accordingly.
Section 6: Details of Award / Both of the 2 criteria relating to details of the award are met.
Successful candidates are given a transcript that confirms the successful completion of the programme, and contains a statement that affirms their successful period of practice learning

Summary and Conclusions

The team agreed to recommend to the Registrar of the General Pharmaceutical Council (GPhC) that Swansea University should be reaccredited as a pharmacist independent prescribing course provider for a further period of three years, subject to making revisions to programme documentation as detailed within the record, and meeting one condition:

  1. The programme outcomes must be mapped fully and completely to all 16 GPhC learning outcomes, and this must be communicated consistently to students and DMPs within the programme documentation. This is to meet criterion 3.2.

There are no recommendations.

As a result of this event, a private record and a public report will be prepared and sent to the University for its comments on matters of factual accuracy. The full record and report include other comments from the team, and the Registrar regards the record and report in their entirety as the formal view on provision. Providers are required to take all comments into account as part of the reaccreditation process.

Post event action

Following the reaccreditation event the GPhC was made aware of a group student complaint relating to this programme. The complaint was investigated at University level and the report provided to the GPhC. The accreditation team was reconvened on 27 Aug 2015 to review the findings of the report. The team agreed that the issues raised were not of sufficient concern to withdraw its original recommendation for reaccreditation; however they agreed that some of the issues identified by the investigation highlighted the need to amend the original outcome on reaccreditation to include additional requirements, including two additional conditions:

  1. The provider must submit an action plan for addressing the recommendations made by Professor Paget, Director of Student Experience, Director of Academic Integrity, Swansea University in her report of the group student complaint, dated 13 Aug 2015. The action plan must contain sufficient detail including relevant timescales.
  1. The provider must provide a clear process for the quality assurance of assessments and related marking arrangements. This must also include key dates to represent how the quality assurance process is will be observed and adhered to.

In addition to the above three conditions, reaccreditation will be subject to a monitoring visit to take place in January/February 2016. This event will be to review the next cohort of the programme at its mid-way point, and before the first summative assessments take place. During this event the accreditation team will wish to speak to the pharmacists on the cohort.

The provider was asked to note the following:

  1. The programme is not reaccredited until approval has been given by the Registrar and any conditions have been met satisfactorily.
  1. The team’s recommendations are not binding on the Registrar, who may accept, modify or reject them.
  1. The accreditation team’s feedback is confidential until it has been ratified by the Registrar of the GPhC; but it may be shared with staff and students internally.

Standing conditions of accreditation:

  1. The full record and report include other comments from the team and the Registrar regards the record and report in their entirety as the formal view on provision. Providers are required to take all comments into account as part of the reaccreditation process.
  1. Any required amendments to be made to documents for accuracy or completeness have been identified and are detailed in the record. The provider must confirm the changes have been made but the GPhC does not require documents to be submitted for its approval.
  1. Once agreed by the Registrar, the definitive version of the record and report will be sent to the provider for their records. The provider must respond to the definitive version of the record and report within three months of receipt. The summary report, along with the provider’s response, will be published on the GPhC’s website for the duration of the accreditation period. The record remains confidential to the provider and the GPhC.
  1. On an annual basis, all institutions and other providers approved by the GPhC must give such information and assistance as the GPhC may reasonably require including changes to the curriculum and/or resources.

Following the above event, the provider submitted documents to address the conditions of reaccreditation and the accreditation team was satisfied that the conditions had been met. The Registrar of the GPhC subsequently accepted the team’s recommendation and approved the programme for reaccreditation for a further period of three years, until the end of August 2018 subject to a monitoring visit to take place in January/February 2016.