In a rare turn of events, the RACGP is arguing that AHPRA’s plans do not go far enough.
If more nurses and pharmacists want to prescribe like doctors, then they had better be ready to do CPD like doctors, the RACGP argues in its submission to an AHPRA-wide consultation on registration standards.
The health practitioner regulator is currently in the process of updating recency of practice and CPD requirements for all registered professions bar medicine.
Under the proposed new standards, all practitioners with an endorsement on their registration would have to do an additional 10 hours of CPD each year.
This would capture the nurses, midwives and podiatrists who have undertaken additional training in order to prescribe medicines. These boards have already individually put in requirements for practitioners with endorsements to do an additional 10 hours of CPD.
Perhaps more relevant for general practice is the fact that this rule would capture pharmacists who prescribe – if and when the planned prescribing endorsement goes through.
But the RACGP was doubtful that an additional 10 hours of CPD would be robust enough.
“The RACGP notes that endorsement for scheduled medicines increasingly enables health practitioners to undertake activities that rely on advanced clinical reasoning, differential diagnosis, prescribing decision-making, recognition of red flags and management of diagnostic uncertainty,” its submission read.
“These are competencies that require ongoing development and regular application in practice. In the RACGP’s view, CPD requirements should be proportionate to the responsibilities associated with prescribing and autonomous clinical decision-making.
“An additional 10 hours annually does not appear equivalent to the expectations placed on other prescribing professions and may not provide sufficient assurance to the public that practitioners are maintaining competence in these activities.”
Medical practitioners, the college pointed out, are required to complete 50 hours of CPD annually in order to maintain registration.
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While it stopped short of explicitly recommending 50-hour CPD years for non-medical prescribers, the college did note that CPD requirements should reflect “consistent regulatory expectations”.
The RACGP also said that CPD for non-medical prescribers should focus on the diagnosis and management of the specific conditions that the practitioner is qualified to treat but may not necessarily see regularly.
“For example, a practitioner may complete postgraduate training relating to the diagnosis and management of specific conditions but subsequently have limited exposure to those conditions for an extended period,” the college said.
“In such circumstances, CPD should include requirements that support maintenance of clinical competence through relevant education, case review, peer discussion, audit activities or other profession-specific mechanisms that demonstrate contemporary knowledge and skills.”
The AHPRA consultation also asked whether it would be reasonable for practitioners moving to a new area of practice (e.g. non-clinical to clinical) to “ensure they have sufficient training and/or qualifications to achieve competency in the new area”.
The RACGP likened this to removing board oversight on changes to scope of practice.
Needless to say, it was not impressed.
“The RACGP does not support an approach that relies solely on practitioners’ self-assessment of competence and compliance with professional codes of conduct,” the college wrote.
“The RACGP considers that appropriate safeguards are required when practitioners expand or change their scope of practice, including clear education and training requirements, strong clinical governance, and structured support for transitions into new areas of practice.
“Board oversight is a critical component of these safeguards and should be retained to promote patient safety, practitioner accountability, and public trust in the regulatory system.”
AHPRA is also looking to standardise recency of practice requirements. All practitioners (bar medical) would need to be able to demonstrate 150 hours of practice over the previous 12 months or 450 hours of practice over the previous three years in order to qualify for registration.
