Consultation on changes to the GDC’s Standards for Education and Preparing for Practice documents Response from the Faculty of General Dental Practice (UK) May 2014 The GDC published the Standards for Education in November 2012. The standards are the regulatory tool used by the GDC to ensure that a programme of education and training leading to registration as a dentist or dental care professional is fit for purpose. The four standards (patient protection; quality evaluation and review; student assessment; and equality and diversity) are central to the GDC’s quality assurance processes and currently include a total of 29 individual requirements. Education providers must be able to demonstrate that upon qualification, students have achieved the learning outcomes specified by the GDC. These are set out for each of the professions that we register in Preparing for Practice (2011). Upon approving the Standards for Education, the Council noted that there would be a postimplementation review of these standards after the first year of operation. The review provides an opportunity to update the Standards for Education and Preparing for practice in light of the new Standards for the Dental Team, Scope of Practice (including direct access) and ensure that they adequately reflect the recommendations of the Report of the Mid Staffordshire NHS Foundation Trust Public Inquiry (Francis Report). We have also identified a number of areas within the Standards for Education that might be amended following feedback from Quality Assurance (QA) inspectors, programme providers and the QA Operations Team. This also incorporates initial feedback provided by the GDC’s QA Advisory Group in 2013. This consultation focuses on a number of specific changes to Standards for Education and Preparing for Practice. Both these documents with proposed revisions can be viewed via the following links: Draft GDC Standards for Education: Current Requirements and Proposed Changes Draft Preparing for Practice: Dental team outcomes for registration We recognise that some education providers are in a transition phase and working to ensure their programmes deliver the learning outcomes set out in Preparing for Practice. We are not proposing to make major changes or review our overall approach to Quality Assurance of education and training at this stage. However we are keen to hear your views on any changes you feel maybe needed in the future.
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Section 1: Who are you? To help us understand the context of your response, please indicate the perspective from which you are replying: (Tick all that apply) 1) Who are you or who are you responding on behalf of?
Education/training provider GDC Inspector Awarding body Registrant not affiliated with programme Student Regulatory body Professional association Patient Other, please specify
2) If you are a student or registrant, please indicate which category applies to you:
Clinical dental technician Dentist Dental hygienist or dental therapist Dental nurse Dental technician Orthodontic therapist
3) Name: Charlotte Worker, Public Affairs, PR and Policy Manager 4) Email address:
[email protected] 5) Address: Faculty of General Dental Practice (UK), The Royal College of Surgeons of England, 35-43 Lincoln’s Inn Fields, London WC2A 3PE 6) Please indicate which registrant category you offer a programme or aware in, or in which you are a student. (Tick all that apply)
Clinical dental technician Dentist Dental hygienist or dental therapist Dental nurse
Dental technician Orthodontic therapist
Standards for Education and Learning Outcomes The Standards for Education cover four areas that education programmes are expected to meet and these are central to the GDC’s quality assurance process: 1. Patient protection 2. Quality evaluation and review 3. Student assessment 4. Equality and diversity The Standards currently contain a total of 29 underlying requirements across the four areas. The GDC assesses the demonstration of these at all stages of the QA process. The Standards for Education require that providers only allow students to pass if they demonstrate a set of learning outcomes, which have been defined by the GDC in the document: Preparing for Practice: Dental Team Learning Outcomes for Registration (2011) The learning outcomes were designed with a focus on patient protection and future oral health need. Preparing for Practice contains learning outcomes for each of the seven professionals that are registered with the GDC. From 2011, education providers have been reviewing the programmes that they offer so that those who pass the programme meet the learning outcomes from Preparing to Practice. For some providers this may be a short process, but others may need to completely revise their curriculum. All proposals or ‘submissions’ for new programmes are required to be mapped against the relevant learning outcomes in Preparing for Practice. The submission must also demonstrate how the new programme will meet the Standards for Education.
Standards for Education Please see the Link to a document containing draft revisions to the Standards for Education. You should answer the following questions with reference to this document: Draft GDC Standards for Education: Current Requirements and Proposed Changes
Impact of the Francis Report and ensuring patient safety through encouraging reporting of concerns We are proposing changes to the requirements relating to Standard 1 to place greater emphasis on patient safety and in particular raising concerns – a major theme in the Francis Report. The proposed Requirement 6 is as follows:
‘Providers must ensure that student and all those involved in the delivery of education and training are aware of their obligation to raise concerns if they identify any risks to patient safety and of the need for candour when things go wrong. Providers should publish policies so that it is clear to all parties how concerns should be raised and how these concerns will be acted upon. Providers must support those who do raise concerns and provide assurance that staff and students will not be penalised for doing so.’ 7) Do you agree with the suggested change? Yes
No Unsure
Please provide any comments below:
The revised wording is wholly appropriate. It is important that providers’ published policy is clear on how those that raise concerns will be supported.
Clarity, consistency and reducing duplication We are proposing that some requirements should be amended to make the GDC’s expectations of provides clearer and to reduce duplication. 8) Do you agree with the proposed changes? Yes
No Unsure
Please provide any comments below:
N/A
Equality and Diversity Feedback that we have received has suggested that the current requirement 29 should be expressed as a learning outcome rather than a requirement under the Standards for Education. Requirement 29: Providers must convey to students the importance of compliance with equality and diversity law and principles of the four UK nations both during training and after they begin practice. Proposed learning outcome 6.5: Recognise and respect the patient’s perspective and expectations of dental care and the role of the dental team, taking into account issues relating to equality and diversity being in line with equality and diversity legislation (noting that this may differ in England, Scotland, Wales and Northern Ireland)
9) Should the current requirement 29 be a learning outcome and be incorporated with Preparing for Practice as learning outcome 6.5?
Yes No Unsure
Please provide any comments below: The proposed learning outcome (6.5) would be appropriate as written for inclusion in Preparing for Practice. However, we would suggest that Standards for Education should also include a requirement for providers to ensure that equality and diversity is taught as part of any programme.
We are considering whether it would be more appropriate to integrate the Requirements relating to Equality and Diversity throughout the other Standards instead of having a separate Standards relating to Equality and Diversity. This would ensure that Equality and Diversity issues are fully embedded throughout. The proposed integrated requirements would be: Requirement 3: Students must only provide patient care in an environment which is safe and appropriate. The provider must comply with the relevant legislation and requirements requiring patient care, including equality and diversity, wherever treatment takes place. Requirement 5: Supervisors must be appropriately qualified and trained. This should include training in equality and diversity legislation relevant for the role. Clinical supervisors must have appropriate general or specialist registration with a regulatory body. Requirement 19: Examiners/assessors must have appropriate skills, experience and training to undertake the task of assessment, including appropriate general or specialist registration with a regulatory body. Examiners and staff should have received training in equality and diversity relevant for their role. 10) Should we take this approach? Yes
No Unsure
Please provide your comments below: The frequency of training in equality and diversity relevant to the role of the supervisor, examiner or assessor should be stated (for example, every two or three years). This should also take account of training received in a different role to prevent unnecessary duplication.
10) This consultation focuses on a number of specific changes to the Standards for Education. Whilst we are not proposing to make major changes or review our overall approach to quality assurance of
education and training leading to initial registration at this early stage, are there any other changes to the Standards for Education we should consider now or in the future? Yes
No Unsure
Please provide any comments below: We would urge an emphasis on being proactive to meet anticipated patient needs, rather than reactive to issues and problems.
Preparing for Practice Please see the revised list of Learning Outcomes here. Clinical: We have been asked by the Medicines and Healthcare Products Regulatory (MHRA) to consider including pharmacovigilance and recognising/supporting adverse reactions to medicines in the learning outcomes for dentists. We have sought advice and propose to introduce the following learning outcome: 1.2.7 Identify adverse effects possibly due to medicines and initiate action to manage and report them
11) Do you agree that we should include the additional learning outcomes within the clinical learning outcomes relating to patient assessment (for dentists only)? Yes
No Unsure
Please provide comments below: We would also urge that 1.2.7 is included as a learning outcome for dental care professionals (DCPs) who see patients through direct access.
Professionalism: We are developing further the Standards for raising concerns and duty of candour and addressing similar issues raised by the Francis Report: 7.4 Recognise the importance of candour and effective communication with patients when things go wrong, knowing how and where to report any patient safety issues which arise. 12) Do you agree that we should include the learning outcomes set out in 7.4 as an additional learning outcome for all registrant groups?
Yes No Unsure
This is essential.
13) Are there any other changes we should make to the learning outcomes to better protected patients (for example, in the light of the Francis Report)? Please provide any comments below:
The proposed changes appear to be comprehensive.
14) As outlined in the previous questions, this consultation focuses on a limited number of specific changes to Preparing for Practice. Whilst we are not proposing to make major changes or review our overall approach to Quality Assurance of education and training leading to initial registration at this early stage, are there any other changes to Preparing for Practice, we should consider either now or in the further for example Direct Access?
Yes No Unsure
Please provide any comments below:
The issue of direct access for DCPs needs to be addressed in the education and training leading to initial registration for DCPs, and more specifically with regard to Preparing for Practice. The knowledge of legislation in relation to independent practice by DCPs, as well as the importance of a holistic approach to care, needs to be developed and embedded within training curricula.
Regulatory Impact When the Standards for Education were introduced in 2012, the GDC asked questions, as part of the preceding consultation, to help it as a regulator fully to understand the impact on stakeholders. The aim of the standards remains the same with this revision: to provide a clear framework, within which the GDC’s expectations of education and training providers are outlined. This assists us to fulfil our regulatory role of ensuring that students qualifying on awards and programmes leading to registration meet the level we require for safe and independent practice. Ultimately, a decision on whether a training programme or award is accepted for registration purposes will be based on providers meeting these standards.
We have learnt from our earlier consultation that providers allocate resources to support the collection of evidence and the setting up of systems to capture the data required in the standards. We continue to believe the resultant benefits include:
regulation of education and training provision that is fair, impartial, consistent and evidencebased in its judgements
improved assurance, derived from a more consistent and transparent regulatory approach, on the standards of new registrants
a clearer focus on outcomes – education and training providers will need to ensure that students achieve, rather than simply cover all learning outcomes by the end of the programme, which should achieve a more consistent level of competence
a clearer focus on quality assuring the assessment – more evidence based, systematic and can be audited more effectively and instantly
a minimal increase in regulatory burden e.g. by providers using information provided to other regulatory bodies
a more targeted and risk-based regulatory approach
improved flexibility for training providers to enable innovation and improvements in the way their programmes are delivered and assessed.
With the development and consolidation of regulatory requirements within the same Standards for Education, the GDC would like to hear your views again on the same questions about the perceived benefits and costs. Following the GDC implementing the revised standards, please describe the impact you would expect to see on the following areas: 15) Quality of patient safety during and after training.
Positive Negative Neither
Please provide any comments below:
Although we would suggest that issues regarding patient safety are not often related to training, but more frequently arise due to poor practise that develops post registration.
16) Education and training provider operating costs and resources.
Increase Decrease Little change
Please provide any comments below:
We would anticipate that the changes would have a significant effect on costs.
17) Assurance about students’ readiness to practise on completion of the programme.
Positive Negative Neither
Please provide any comments below: Assurance on readiness to practise can only gained by students demonstrating a consistent achievement of the learning outcomes; students must be able to show that they have reached the necessary standard to be considered as a ‘safe and competent beginner’. The proposals provide a clearer framework to set out these standards.
18) Student experience during training and their clarity about the standard to be reached.
Positive Negative Neither
Please provide any comments below:
N/A
Implementation (For education providers and awarding bodies only) Subject to the outcomes of this consultation, we aim to implement changes to the Standards for Education and Preparing for Practice as quickly as possible whilst minimising any additional burdens on education providers. We know that some providers are in the transition phase towards fully delivering the learning outcomes as set out in Preparing for Practice.
19) Do you agree that we should implement the changes to Standards for Education and Preparing for Practice from October 2014? (Any programme re-inspections that are required in 2015 will be based on current GDC documents.)
Yes No Unsure
Please provide any comments below:
N/A
20) What has your experience been of gathering documentation to demonstrate the mapping of the Standards for inspections? N/A
Thank you for your response. Your views are important to us in the continued development of the Standards for Education and Learning Outcomes.
