Information about the key legislative changes proposed for the CPD system

Annual submission of CPD records by pharmacists

Why move to annual submission of CPD records by all pharmacists?

The proposal to move to annual submission of CPD records by all pharmacists is based on evidence-based research, analysis and stakeholder engagement. This change will align the CPD model with national and international best practice for health and social care professionals. It will also support ongoing continuous engagement by pharmacists with learning and development activities.

Reducing the CPD cycle period from 5 years currently, as well as including newly qualified/recently registered pharmacists, is one of the recommendations from the independent review of the CPD model for pharmacists, and more information can be read here.

How many CPD cycles will pharmacists be expected to submit annually?

While this has not yet been determined, it is proposed that the number of CPD cycles to be submitted by pharmacists on an annual basis will be set out in a policy approved by the PSI Council.

As part of the development of this policy, consultation and engagement will be conducted with the Irish Institute of Pharmacy (IIOP), the peer support network and practising pharmacists.

Practice Review for pharmacists

Why is Practice Review being removed from the CPD model for pharmacists?

The proposal to remove Practice Review from the CPD model for pharmacists is based on the performance data observed to date, the feedback from the pharmacy sector in terms of the regulatory burden that it creates for pharmacists, the relatively high costs of its operation and the absence of similar measures in international practice. This is one of the recommendations from the independent review of the CPD model for pharmacists conducted in 2022/2023.

Linking CPD and registration

Why will the requirement to engage with CPD be linked to a pharmacist’s registration?

Engagement and compliance levels by pharmacists with the current CPD system remains very high year-on-year. Currently, fitness to practice processes are used in circumstances where a pharmacist, who does not have extenuating circumstances, fails to engage with the CPD system. The independent review of the CPD model for pharmacists, however, recommended that linking registration and CPD compliance would enhance the efficiency and effectiveness of the CPD model, and this aligns with national and international practice.

What if a pharmacist can’t submit CPD because of special circumstances (i.e. maternity leave, parental leave, serious illness etc)?

As is currently the case, it is proposed that pharmacists will still be able to submit applications for extenuating circumstances where the need arises.

Will the PSI Council be able to refuse a pharmacist’s registration, if they have not made a CPD submission that year, and have not been granted extenuating circumstances?

Yes. It is proposed that the following would happen in these circumstances.

The Council will inform the applicant in writing that it proposes to refuse their application for registration and the reasons on which this is based. The applicant will be informed that they have 28 days to make written representations to the Council, in response to the proposal to refuse the application.

The Council will then consider the following:

Any written representations sent to it
Any extenuating circumstances applying to the applicant
Any CPD subsequently undertaken by the applicant, and
Such other matters as the Council considers appropriate.

Having considered all of this information the PSI Council will then decide to grant or refuse the application for registration.

Will there be a right of appeal if a pharmacist’s registration is refused?

Yes. The right of appeal to the High Court is provided for under Section 21 of the Pharmacy Act 2007 if the PSI Council refuses an application for registration.

Will it be possible for a pharmacist to register again if their application for registration is refused by the PSI Council on these grounds?

Yes. Pharmacists seeking to restore to the register will need to comply with any requirement which may be imposed by the PSI Council. This may include one or more of the following:

Verify anything contained in their application
To supply further information in relation to the application
To make a statutory declaration supplying that information

This may include providing evidence to the PSI Council that they are engaging in appropriate CPD.

CPD model for pharmaceutical assistants

Why introduce a new CPD model for pharmaceutical assistants?

The introduction of a new CPD model for pharmaceutical assistants follows on from legislative changes to the Regulated Professions (Health and Social Care) (Amendment) Act 2020. Section 53 of this Act (once commenced) will introduce a requirement for PSI to oversee a CPD model for pharmaceutical assistants.

What is the proposed format of the CPD model for pharmaceutical assistants?

This report to support the development of a CPD model for pharmaceutical assistants was approved by the PSI Council on 22 June 2023.

The proposed CPD model for pharmaceutical assistants is a bespoke CPD model that draws on elements from the CPD model for pharmacists and utilises the infrastructure (ePortfolio) already in place.

The recommended CPD model includes the use of ‘themes’ that will provide direction and guidance for pharmaceutical assistants to conduct and manage their CPD learning activities within the new CPD model. The themes have been developed in consultation with the Pharmaceutical Assistants Association (PAA) and were approved by the PSI Council on 6 June 2024. 

How often will pharmaceutical assistants be required to submit records of their CPD?

Pharmaceutical assistants will be required to make an annual CPD submission, like pharmacists, except where they have an approved extenuating circumstances application in place.

Will the PSI Council be able to refuse a pharmaceutical assistant’s registration, if they have not made a CPD submission that year, and have not been granted extenuating circumstances?

Yes. Similar to the system for pharmacists, it is proposed that the following would happen in these circumstances.

The Council will inform the applicant in writing that it proposes to refuse the application and the reasons on which this is based. The applicant will be informed that they have 28 days to make written representations to the Council, in response to the proposal to refuse the application.

The Council will then consider the following:

Any written representations sent to it
Any extenuating circumstances applying to the applicant
Any CPD subsequently undertaken by the applicant, and
Such other matters as the Council considers appropriate.

Having considered all of this information the PSI Council will then decide to grant or refuse the application for annual registration.

Delivery of the CPD system and quality assurance of training

What changes are being proposed to the delivery of the CPD system?

The revised rules are proposing to introduce greater flexibility in how the CPD system and/or the Irish Institute of Pharmacy (IIOP) is delivered. This includes removing reference in legislation to staffing requirements for the IIOP. It also provides flexibility to the PSI Council in how the IIOP is delivered.

While there is an ongoing desire to utilise the outsourced arrangement of the IIOP for the implementation and delivery of the CPD system, this is subject to successful procurement processes, contract negotiation and agreement on associated funding and resources, now and into the future. The proposed changes will provide the PSI Council with flexibility to consider alternative delivery mechanisms for the CPD system, where necessary.

What changes are proposed for quality assurance of CPD Training Programmes?

It is proposed that a quality assurance policy will be developed to quality assure training delivered through the IIOP, instead of accreditation standards. This follows on from a research paper approved by the PSI Council in April 2024. Quality assuring training through policy allows greater flexibility and responsiveness, based on the needs of the pharmacy profession and the different ways training can be delivered.

General Information

Where can I find more information about how the revised CPD model for pharmacists will work in practice?

Currently the focus is on the changes needed to the legislation to underpin the revised CPD model for pharmacists, following the proposals previously approved by the PSI Council. The background to this can be read here in Review of the CPD Model.

Operational aspects of the revised CPD model for pharmacists, including submission periods, the number of CPD cycles to be submitted, including when the new system will be implemented will be set out in a CPD Review policy which will be approved by the PSI Council if the statutory rule changes are approved.

We will engage widely with the IIOP, pharmacist peer support network and practising pharmacists as part of the development of this policy and provide this information to pharmacists in good time to allow them to prepare for these changes.

What’s the benefit of setting out the CPD requirements for pharmacists in a CPD review policy?

This approach has worked well to date in terms of the existing ePortfolio Review policy, which is developed by the IIOP and approved by the PSI Council. Setting out CPD requirements in policies provides flexibility and agility to support CPD delivery for pharmacists and pharmaceutical assistants. This is particularly relevant as pharmacy practice continues to change and evolve and with the future expansion in the scope of pharmacy practice. Consultation and engagement with peer support pharmacists and practising pharmacists and pharmaceutical assistants will continue to inform policy development.

Are there any other changes being proposed in the draft rules?

The draft rules are proposing that pharmacist’s will self-assess their CPD learning and development needs against a CPD review policy, the Core Competency Framework for Pharmacists (CCF) and any other competency frameworks that may be in place, and the Code of Conduct for Pharmacists.

The draft rules also provide for the issuing of a certificate of engagement for successful submission of CPD and where CPD extracts are selected for peer-review, the issuing of a certificate of compliance where the standards are met.

The draft rules continue to provide for referral of information by the IIOP to PSI, regarding pharmacist non-engagement/standards not met, where the matter has not been resolved with the pharmacist through the IIOP’s remediation policy.

What other changes can be expected in the CPD review policy?

The independent review of the CPD model for pharmacists conducted in 2022/2023, included a number of other recommendations, including the following:

Investigating opportunities to incorporate intra and inter-profession collaboration,
Incorporating peer feedback/discussion into the self-reflection process
Incorporating enhanced risk-based approaches to the sampling of practitioners for CPD review processes (i.e. ePortfolio Review)

These recommendations will be incorporated in the CPD review policy for pharmacists which will be approved by the PSI Council. We will engage widely with the IIOP, peer support pharmacists and practising pharmacists, as part of the development of this policy and provide this information to pharmacists in good time to allow them to prepare for these changes.

Will the IIOP Peer Support Network be involved in rolling out the changes to the CPD system for pharmacists and the implementation of the CPD system for pharmaceutical assistants?

The PSI recognises the valuable contribution of the IIOP Peer Support Network in the success of the CPD system for pharmacists since its inception, and in supporting high levels of engagement by pharmacists with ePortfolio Review and Practice Review.

In conjunction with the IIOP, we will continue to explore opportunities for the role of the Peer Support Network in the ongoing maintenance and evolution of the CPD system for pharmacists. In addition, opportunities for the Peer Support Network to be involved in supporting the roll out of the new CPD system for pharmaceutical assistants will be explored.