Background paper:

Producing new Education Standards for Providers and Learning Outcomes for Students

Author: Ben Pearson

Date: August 2019

1

Welcome to the ESR Expert Advisory Group The groups will re-visit draft Education Standards for education and training providers and Learning Outcomes for students. There are two advisory groups, one for Optometry and for Ophthalmic Dispensing.

The purpose of the Education Strategic Review (ESR) is to review and make recommendations on how the system of optical education and training should evolve so that registrants are equipped to carry out the roles they will be expected to perform in the future.

Following the GOC Council discussions relating to findings from the ESR consultation on draft Education Standards for education providers and Learning Outcomes for students, we accept that further work is required.

At the first meeting of the Expert Advisory Group (EAG) we will identify the categories of learning outcomes based on our Standards of Practice for Optometrists and Dispensing Opticians that form part of three themes required to become a safe and effective practitioner. The themes are:

Knowledge Skills Behaviour and values

In later EAG sessions we will ensure that each standard and outcome is clear and concise.

Whilst each EAG contributes its expertise to a range of ESR related documents, we will report back to our stakeholders via an online survey and seek feedback into this process. It is our aim that everyone will have had the opportunity to contribute and have their voice heard.

You will be provided with copies of the following:

For the Optometry EAG: The Optometry Handbook 2015

For the Ophthalmic Dispensing EAG: The Dispensing Handbook 2011

Both can be found here: https://www.optical.org/en/Education/core-competencies--core-curricula/index.cfm

For both groups:Preparing Students for Safe and Confident Practice in a Changing Optical Sector: Education Strategic Review draft Education Standards and Learning Outcomes consultation November 2018: https://consultation.optical.org/standards-and-cet/education-strategic-review/user_uploads/draft-education-standards-and-learning-outcomes-3.pdf

Standards of Practice for Optometrists and Dispensing Opticians: https://www.optical.org/filemanager/root/site_assets/standards/new_standards_documents/standards_of_practice_web.pdf

2

You will also need a copy of other health regulator standards or learning outcomes:GMC Outcomes for Students: https://www.gmc-uk.org/-/media/documents/outcomes-for-graduates-a4-20190717_pdf-78071845.pdf

HCPC Standards of Education and Training: https://www.hcpc-uk.org/globalassets/resources/standards/standards-of-education-and-training.pdf

GPhC Initial Consultation on Education and Training Standards for pharmacists: https://www.hcpc-uk.org/globalassets/resources/standards/standards-of-education-and-training.pdf

3

Contents

Welcome to the ESR Expert Advisory Group..............................................................2Letter of Invitation to the Optometry Expert Advisory Group.......................................6Letter of Invitation to the Ophthalmic Dispensing Expert Advisory Group...................7EAG Terms of Reference............................................................................................8

Purpose................................................................................................................... 8Membership and Chair.............................................................................................8EAG Optometrists....................................................................................................9EAG Dispensing Opticians.....................................................................................10

Effective Participation................................................................................................11Frequency of Meetings, Location and Notice............................................................11Group Governance....................................................................................................11Introduction...............................................................................................................13Consultation feedback on draft Education Standards and Learning Outcomes........14

Content..................................................................................................................14Design....................................................................................................................14Drafting..................................................................................................................14Detail......................................................................................................................14

Key Approaches to Education for UK Health Professions.........................................15General Medical Council (GMC)............................................................................15Health and Care Professions Council (HCPC).......................................................17General Pharmaceutical Council (GPhC)..............................................................18Structure and content of the standards..................................................................19Competence and assessment hierarchy................................................................20

Designing Learning Outcomes..................................................................................21Learning outcome models......................................................................................21Scope of Practice...................................................................................................23

Annex One: Summary of Comments from ESR Education Standards and Learning Outcomes Consultation 11.18 - 02.19.......................................................................24

General Content.....................................................................................................24Design....................................................................................................................25Drafting..................................................................................................................25Notes..................................................................................................................... 26

4

Figure 1 ESR overview infographic...........................................................................12

Figure 2 Basic Curricula needs.................................................................................13

Figure 3 Overview of GMC approach to education...................................................17

Figure 4 Overview of HCPC approach to education.................................................18

Figure 5 Overview of proposed GPhC approach to education..................................20

Figure 6 Miller’s pyramid of clinical competence.......................................................20

Table 1 Selection of verbs, adjectives and nouns used by the GMC and the GPhC to construct learning outcomes……………………………………………………….……..20

Table 2 Miller’s Learning Levels - as set out by the GPhC (2018) ……...…..……....22

5

Letter of Invitation to the Optometry Expert Advisory Group

GOC Education Strategic Review Invitation to join the Expert Advisory Group to consider the development of Education Standards and Learning Outcomes for Optometry

I am delighted to invite you to take part in an Expert Advisory Group (EAG) for the General Optical Council’s (GOC) Education Strategic Review (ESR). The Group will consider the development of Education Standards for providers and Learning Outcomes for students of Optometry.

It follows the most recent Council meeting and ESR consultation which identified the need for further work to ensure the Education Standards and Learning Outcomes are fit for the future.

We hope that members of the group will take a forward-looking perspective to participating, to help us ensure that our proposals related to the Education Standards and Learning Outcomes maintain public safety, meet future patient needs and take account of good educational practice, professionalism and health service delivery in all four countries of the UK.

The working group will not be a formal part of the GOC’s governance structure and does not have a decision-making or project management role; this role remains the responsibility of the GOC’s Council and Executive team. Its sole purpose is to ensure that the new Education Standards and Learning Outcomes are fit for the future.

We intend the group to get underway in the late Summer of 2019 and to meet at regular intervals at our London-based office. Please note that as a member of this group, you will agree to your name being published.

The GOC will pay travel expenses to each working group member for attendance retrospectively and on presentation of original receipts, in line with our travel and subsistence policy. It will not be possible to include deputies/alternates, but we hope members will nevertheless be able to attend most, if not all, meetings. The dates of the EAG meetings are:

Tuesday 24th September Tuesday 5th NovemberTuesday 10th DecemberTuesday 14th JanuaryTuesday 18th FebruaryTuesday 17th March

I would be grateful if you could indicate whether or not you wish to accept this invitation by responding to Paula Thompson at pthompson@optical.org by Friday 16th August.

I very much hope that you can join us for this important work, and we look forward to hearing from you soon.

Yours sincerely,

Dr Subo ShanmuganathanDirector of Education (interim)

6

Letter of Invitation to the Ophthalmic Dispensing Expert Advisory Group

GOC Education Strategic Review Invitation to Expert Advisory Group to consider the development of Education Standards and Learning Outcomes for Ophthalmic DispensingI am delighted to invite you to take part in an Expert Advisory Group (EAG) for the General Optical Council’s (GOC) Education Strategic Review (ESR). The Group will consider the development of Education Standards for providers and Learning Outcomes for students of Ophthalmic Dispensing.

It follows the most recent Council meeting and ESR consultation which identified the need for further work to ensure the Education Standards and Learning Outcomes are fit for the future.

We hope that members of the group will take a forward-looking perspective to participating, to help us ensure that our proposals related to the Education Standards and Learning Outcomes maintain public safety, meet future patient needs and take account of good educational practice, professionalism and health service delivery in all four countries of the UK.

The working group will not be a formal part of the GOC’s governance structure and does not have a decision-making or project management role; this role remains the responsibility of the GOC’s Council and Executive team. Its sole purpose is to ensure that the new Education Standards and Learning Outcomes are fit for the future.

We intend the group to get underway in the late Summer of 2019 and to meet at regular intervals at our London-based office. Please note that as a member of this group, you will agree to your name being published.

The GOC will pay expenses to each working group member for attendance retrospectively and on presentation of original receipts, in line with our travel and subsistence policy. It will not be possible to include deputies/alternates, but we hope members will nevertheless be able to attend most, if not all, meetings. The dates of those meetings are:

Monday 30th SeptemberMonday 4th NovemberMonday 9th DecemberMonday 13th JanuaryMonday 17th FebruaryMonday 16th March

I would be grateful if you could indicate whether or not you wish to accept this invitation by responding to Paula Thompson at pthompson@optical.org by Friday 16th August.

I very much hope that you can join us for this important work, and we look forward to hearing from you soon.

Yours sincerely,

Dr Subo ShanmuganathanDirector of Education (interim)

7

EAG Terms of Reference

September 2019

PurposeThe purpose of the Expert Advisory Groups (“the Groups”) is to advise and assist on matters relating to the development and delivery of the General Optical Council’s (GOC) Education Strategic Review (“the Review”), as follows:

contribute expert knowledge in the further development of the Education Standards for providers and the Learning Outcomes for students;

provide expertise in the development of the Practical Skills and Procedures document for newly qualified professionals;

provide advice, support and assistance in the creation of the Assessment Framework.

The Group is not a representative body and has no legislative and decision-making power, delegated authority or any role in project management.

Membership and Chair The GOC invites members to participate on the basis of skills and experience relevant to the ESR and not in any representative capacity. Members may change depending on the expertise required as the Review progresses.

The Group will be chaired by the interim Director of Education, or in their absence the Head of Education. Meetings will be organised and administered by the Project Team.

From time to time other participants may be invited to attend a meeting of the Group in full or in part, where that is relevant to the Group’s work. The Group may be asked for ad hoc feedback between meetings by email or by phone.

The Group is comprised as follows:

8

EAG Optometrists

Name Organisation Sector

Dr Subo Shanmuganathan Chair GOC

Prof. Gunter Loffler Glasgow Caledonian University Education

Prof. John Siderov Huddersfield University Education

Dr Nik Sheen Cardiff University/HEIW/WOPEC Education/NHS Wales, CET provider

Hilary Tompsett Formerly of Kingston University SW Education/EdCom

William Holmes Manchester University/Optometry Schools Council/Optical Confederation/AOP Council/COO Council Education

Dr Rebekah Stevens University of West England Education

Sally Gosling College of Optometrists Professional body, CET provider

Poonam Shah NHS England Commissioner

Dr Nav Gupta IP optometrists Education visitor panel – OO member

Prof. Barry Mitchell Academic Former Lay Chair EVP

Jennifer Chaston Patient Patient

Sarah Canning Moorfields Eye Hospital NHS – Head of Optometry

Dr Imran Jawaid Queens Medical Centre NHS ophthalmologist and research scientist (previously optometrist), CET provider, EdCom

Claire Slade Boots Director of Professional Services Employer

Josie Forte Specsavers/FODO/GOC Companies Committee/ employer/Council lead, CET provider

EAG Dispensing Opticians

Name Organisation Sector

9

Dr Subo Shanmuganathan Chair GOC

Dean Dunning Bradford College Education/practising DO

Simon Butterfield ABDO College Education

Jay Dermott CANDI college Education

Dr Julie Hughes Anglia Ruskin University Education/EVP

Alicia Thompson ABDO Exams Education/professional body/EdCom, CET provider

Daniel Williams Low vision patient Patient

Sarah Joyce ASDA Superintendent Optometrist Employer

Jeet Saimbi Scrivens Director of Professional Services Employer

Gill Robinson SpecsaversDirector of Professional Training and Development

Employer/DO trailblazer group apprenticeships, CET provider

Jay Varia Moorfields Hospital, Principal Optometrist/UCL Institute of Ophthalmology NHS/practising optometrist/ honorary lecturer

One to be confirmed

Sally Powell Education visitor panel lay Chair

Kathy Start Nursing education EdCom lay member

Paula Baines CLO (former Vision Express CLO) Standards Committee/EVP CLO memberGlenn Tomison FODO/GOC/Manchester University Standards Committee/DO/Council member GOC

10

Effective Participation Each Group member agrees to:

attend regular meetings and actively participate in the Group’s work to produce timely documents, and make apologies for absence in advance where they are unable to attend to Paula Thompson at pthompson@optical.org

ensure that any changes to optical education are focused on maintaining public safety and meeting future patient needs

advise on aspects of the Review work in the context of the GOC’s public protection role

maintain a genuine interest in the initiatives and the outcomes of the ESR project the publication of their names as part of this group

Frequency of Meetings, Location and Notice It is anticipated that the Group shall meet every four to six weeks at the GOC offices in London, or via telephone or video conference. Dates and time of meetings will be scheduled far in advance, but this might change depending on need and as the Review progresses.

Unless otherwise agreed, an agenda and supporting papers, will be emailed to each member of the Group approximately five working days before the date of the meeting.

Group Governance The Group and its members will operate in accordance with all relevant GOC policies and procedures, including those relating to confidentiality, conflicts of interest, fees and expenses, hospitality, and good conduct. More information on our policies can be found here: http://www.optical.org/en/about_us/our-governance/index.cfm together with links to our equality, diversity and inclusion policy.

The work of the Group, its membership and these Terms of Reference will be reviewed regularly. The GOC reserves the right to modify the Group’s membership at any time in accordance with the needs of the ESR.

11

12Figure 1 ESR overview infographic

Introduction The GOC will shortly begin the process of constructing new Education Standards for Providers and Learning Outcomes for Students. We have already produced a first draft which was subject to a public consultation in late 2018 and we have amassed a substantial evidence base over the past two years.

Two EAG’s have been created for two separate optic professions; optometry and ophthalmic dispensing. The membership will include representatives from education and training providers, students, employers, the GOC visitor panel, the NHS, professional examination bodies and patients. We understand that by their nature EAG’s can only accommodate the physical capacity of available room space. We therefore intend to set up an online survey tool which people may use to reflect, comment and feedback into the work of the groups.

In this process the GOC will focus on the types of knowledge, skills and behaviour required to become a safe and effective practitioner. It will identify the core clinical competencies currently required for optometry and ophthalmic dispensing professions and the learning outcomes to be built around these. Each outcome will be assigned a level using Miller’s hierarchy of clinical competence:

Level 1: Knows Level 2: Knows how Level 3: Shows how Level 4: Does

We intend to subject each outcome to a S.M.A.R.T. test which will assess if the standard/learning outcome is specific, measurable, attainable, realistic and time-bound. We will use grammar judiciously to ensure each standard/outcome is clear and concise. We will link the outcomes to our professional standards and continuing education and training development (CET) because the road to registration as a professional practitioner is the start of a life-long journey of education.

The current GOC competencies are highly detailed and prescriptive. Moving to learning outcomes will provide education and training providers greater flexibility to respond to changes that have been identified during the ESR such as the increasing elderly population and changes in the delivery of health care and the impact of new technology.

The approach of the GOC will be to uphold the principles of good regulation; to be proportionate, accountable, consistent, and transparent. Our role as the health regulator is to protect the public and our standards and learning outcomes must reflect this. The public safety interest is an important dimension education and training providers must consider when designing their curricula (see Figure 2).

13

Labour market needs

Academic

Curricula

Public Safety

Figure 2 Basic Curricula needs

Consultation feedback on draft Education Standards and Learning OutcomesAs part of the ESR, a consultation on draft Education Standards and Learning Outcomes was opened on 12 November 2018 and closed on 25 February 2019. Five hundred and thirty-nine responses were received from individual registrants, universities and professional bodies and organisations. Seventy-one per cent of respondents disagreed that the draft Standards and Learning Outcomes were fit for purpose. A summary of comments about the general content, design, drafting and detail of the drafts is provided in Annex 1.

The comments, in brief, concerned:

ContentWhilst some respondents felt they were comprehensive; the general feeling was negative. The Learning Outcomes were described as too generalised and not containing specific measurable competencies, were not located within a recognised educational framework (such as Miller’s Pyramid of Clinical Competencies or Bloom’s Taxonomy), could be interpreted and acted upon to different levels of understanding and knowledge, were incomplete, repetitive and lacking in specific clinical requirements.

DesignThe new framework attracted praise for being less prescriptive than the current competencies, as did common domains across the profession. However, it was suggested from a respondent that for the purposes of curricula design, delineating the outcomes into three themes entitled “Knowledge”, “Skills” and “Behaviour” would be preferable. The format of the draft was also criticised for being “difficult to understand” and a contents page was suggested.

DraftingAlthough some respondents thought the drafts were jargon-free, well written and easy to understand, the overwhelming feeling was negative, particularly concerning the Learning Outcomes. They were described as incomplete, slightly ambiguous, varying considerably in length, not using plain English, repetitive and clumsily constructed with attempts made to specify the curriculum within them.

DetailThe draft outcomes were described as open to interpretation, requiring clarification, missing detail in some areas (e.g. related to contact lens opticians), requiring greater detail to clarify the depth of knowledge required in professional practice and offering no advancement in knowledge for dispensing opticians.

14

Key Approaches to Education for UK Health Professions As part of our research on regulating education leading to registration as a professional practitioner, we looked at three different approaches adopted by three of the UK health regulators, the General Medical Council, the Health and Care Professions Council, and the General Pharmaceutical Council.

General Medical Council (GMC)The GMC identified nine areas of concern about doctor’s performance based on its fitness-to-practice data within its 2017 Generic Professional Capabilities (GPC) framework. This framework describes the interdependent essential capabilities that underpin professional medical practice in the UK and contains three fundamental domains:

Professional values and behaviours (Domain 1) Professional skills (Domain 2) Professional knowledge (Domain 3)

Six further domains are also contained within the framework and include capabilities in:

Health promotion and illness prevention (Domain 4) Leadership and team working (Domain 5) Patient safety and quality improvement (Domain 6) Safeguarding vulnerable groups (Domain 7) Education and training (Domain 8) Research and scholarship (Domain 9)

The GMC’s Learning Outcomes for graduates published in 2018 are built around the first three fundamental domains in the 2017 GPC framework focussing on:

Outcomes 1 Professional values and behaviours,

Professional and ethical responsibilities Legal responsibilities Patient safety and quality improvement Dealing with complexity and uncertainty Safeguarding vulnerable patients Leadership and team working

Outcomes 2 Professional skills,

Communication and interpersonal skills Diagnosis and medical management Prescribing medications safely Using information effectively and safely

Outcomes 3 Professional knowledge,

The health service and healthcare systems in the four countries Applying biomedical scientific principles

15

GMC Generic professional capabilities framework: https://www.gmc-uk.org/-/media/documents/generic-professional-capabilities-framework--0817_pdf-70417127.pdf

Applying psychological principles Applying social science principles Health promotion and illness prevention Clinical research and scholarship.

The Learning Outcomes include sections that map to the targeted domains in the 2017 GPC framework. Some Learning Outcomes are similar to those in the professional framework but at a level appropriate for the stage of their training. They include a single overarching outcome for graduates:

“Medical students are tomorrow’s doctors. In accordance with Good medical practice, newly qualified doctors must make the care of patients their first concern, applying their knowledge and skills in a competent, ethical and professional manner and taking responsibility for their own actions in complex and uncertain situations.”

Three stakeholder groups are responsible for delivering the Learning Outcomes. They are:

Medical schools which must provide an education that allows newly qualified doctors to meet all the outcomes, including practical procedures,

Local education providers working with medical schools must provide and quality manage clinical placements, and

Medical students who are responsible for their own learning.

The GMC has 10 standards that organisations responsible for educating and training medical students and doctors are expected to meet. Published in 2015, Promoting excellence: standards for medical education and training, are organised around five themes:

Learning environment and culture (Theme 1)

“making sure that the environment and culture for education and training meets learners’ and educators’ needs, is safe, open, and provides a good standard of care and experience for patients.”

Education governance and leadership (Theme 2)

“making sure that organisations have effective systems of educational governance and leadership to manage and control the quality of medical education and training.”

Supporting learners (Theme 3)

“making sure learners get effective educational and pastoral support, so they can demonstrate what is expected”

Supporting educators (Theme 4)

“making sure that educators have the necessary knowledge and skills for their role, and get the support and resources they need to deliver effective education and training”

Developing and implementing curricula and assessments (Theme 5)

16

GMC Outcomes for graduates: https://www.gmc-uk.org/-/media/documents/outcomes-for-graduates-a4-20190717_pdf-78071845.pdf

“making sure medical school and postgraduate curricula and assessments are developed and implemented to meet GMC outcome or approval requirements.”

The GMC has also outlined a core set of Practical skills and procedures which includes a minimum level of performance that newly qualified doctors must have when they start work for the first time.

It outlines three levels of competence that newly qualified doctors must demonstrate:

Safe to practice in simulation, Safe to practice under direct supervision, and Safe to practise under indirect supervision.

Each stipulated procedure is assigned a level of competence and broadly relate to:

Assessment of patient needs, Diagnostic procedures, Patient care, Prescribing, and Therapeutic procedures.

Health and Care Professions Council (HCPC)The HCPC’s main purpose is to protect the public by setting and maintaining standards of proficiency and conduct for the professions it regulates.

An education and training programme which meets the HCPC’s 2017 Standards of education and training allows a student who successfully completes that programme to meet the Standards of proficiency.

The Standards of proficiency are the professional standards that all registrants must meet in order to become registered with the HCPC and remain on the register. They set out the threshold standards considered necessary to protect the public and are unique to each of the HCPC’s registered professions which include arts therapists, biomedical scientists, chiropodists, podiatrists, clinical scientists, dietitians, hearing aid

17

GMC Standards for medical education and training: 20190717_pdf-78071845.pdf

Practical Skills and Procedures

Programme Curriculum

Standards for medical education and training

GMC Learning Outcomes

GPC Framework

Figure 3 Overview of GMC approach to education

dispensers, occupational therapists, operating department practitioners, orthoptists, paramedics, physiotherapists, practitioner psychologists, prosthetists, orthotists, radiographers, social workers in England, and speech and language therapists.

Education and training providers are responsible for ensuring that their programme learning outcomes meet the Standards of proficiency for the relevant part of the HCPC register. The learning outcomes must ensure that learners understand and are able to meet the expectations of professional behaviour, including the Standards of conduct, performance and ethics. The structure, duration and range of practice-based learning must support the achievement of the programme learning outcomes and the standards of proficiency.

Practice educators must undertake regular training which is appropriate to their role, learners’ needs and the delivery of the learning outcomes of the programme.

General Pharmaceutical Council (GPhC)The GPhC published new draft initial education and training standards for pharmacists and providers in January 2019 as part of its 2017-20 strategic plan. The aim is to take account of recent developments in the delivery of initial education and training, and to give pharmacists the knowledge, attitudes and behaviours they will need for future practice.

An important change will be integrating its standards for the full period of initial education and training. The GPhC currently sets separate standards and learning outcomes for the four-year MPharm degree and for the pre-registration year. The GPhC wishes to bring pharmacist initial education and training into line with other clinical healthcare professions by integrating academic study and workplace experience. Proposed learning outcomes will cover the full period of initial education and training. The GPhC stipulates that universities, employers, health education and training organisations and bodies responsible for funding must work together to achieve this.

18

HCPC Standards of proficiency: https://www.hcpc-uk.org/standards/standards-of-proficiency/ HCPC Standards of conduct, performance and ethics: https://www.hcpc-uk.org/standards/standards-of-conduct-performance-and-ethics/HCPC Standards of education and training: https://www.hcpc-uk.org/globalassets/resources/standards/standards-of-education-and-training.pdf

Standards of education and training

Programme Learning Outcomes and Curriculum

Standards of conduct, performance and ethicsStandards of proficiency

Figure 4 Overview of HCPC approach to education

In addition, the GPhC proposes to strengthen the current selection and admission standard. Providers will have to assess the professional skills and attributes of prospective students as well as their academic qualifications. By that the GPhC means their:

Interest in person-centred care, Ability to work with other people, Professionalism, Problem-solving abilities, and Numeracy skills.

Structure and content of the standardsThe standards are in two parts. Part 1 are initial education and training (IET) standards for pharmacists - learning outcomes, which include the knowledge, skills and professional behaviours a student pharmacist must demonstrate at the end of a programme leading to registration with the GPhC. Part 2 are IET standards for providers including requirements for a programme delivering the learning outcomes in part one.

The learning outcomes in Part 1 are organised under four domains linked to a standard from the GPhC’s nine standards for pharmacy professionals which include:

Domain 1: Person-centred care, linked to…o Effective Communicationo Respect for personal privacy and confidentiality

Domain 2: Professionalism, linked to…o Professional behaviouro Professional judgement

Domain 3: Professional knowledge and skills, linked to…o Speaking up about concernso Professional knowledge and skills

Domain 4: Collaboration, linked to…o Partnership workingo Effective leadership.

Part 2 of the standards focuses on key features of curricula that deliver the learning outcomes in part 1. Providers can use different models to deliver the standards for the IET of pharmacists and they have been written in such a way that is not prescriptive about delivery.

Part 2 of the standards are grouped into 9 domains:

Selection and admission,

19

Practical skills and procedures: https://www.gmc-uk.org/-/media/documents/practical-skills-and-procedures-a4_pdf-78058950.pdf

GPhC Standards for Pharmacy Professionals:https://www.pharmacyregulation.org/sites/default/files/standards_for_pharmacy_professionals_may_2017_0.pdf

Equality, diversity and fairness, Resources and capacity, Managing, developing and evaluating initial education and training, Curriculum design and delivery, Assessment, Support and development for student pharmacists and people delivering initial

education and training, Learning in practice, and Learning in practice supervision.

Competence and assessment hierarchy The outcome levels are based on an established competence and assessment hierarchy known as “Miller’s pyramid of clinical competence” (see Figure 6).

20

GPhC Consultation on initial education and training standards for pharmacists: https://www.pharmacyregulation.org/sites/default/files/document/consultation_on_initial_education_and_training_standards_for_pharmacists_january_2019.pdf

BehaviouSkill

Knowledg

Programme Curriculum

GPhC initial education and training standards for providers

GPhC initial education and training standards: Learning outcomes for Pharmacists

Standards for Pharmacy Professionals

Figure 6 Miller’s pyramid of clinical competence

Figure 5 Overview of proposed GPhC approach to education

Designing Learning Outcomes Four UK health regulators have adopted Learning Outcomes as part of their provision for initial education and training. They are the General Medical Council (GMC), the General Dental Council (GDC), the General Chiropractic Council (GCC), and the General Pharmaceutical Council (GPhC).

Whilst the GPhC’s learning outcome levels are based on “Miller’s Pyramid of Clinical Competence", they are not organised around the levels. They are organised around themes (or domains) related to public safety. In contrast, the programme outcomes of an education and training provider are likely to be aligned with their qualification award level on the NQF and may have been through an assurance process administered by an independent body (such as OFQUAL). ABDO’s course in Ophthalmic Dispensing was accredited as a Level 6 course by OFQUAL whilst the GOC’s stated competencies relate to our public safety requirements and are not aligned to NQF levels.

Learning outcome modelsWhilst the structure of the GMC’s outcomes (along with the approach of other regulators) is not hierarchical, it does group its outcomes around three themes relating to values and behaviours, skills and knowledge as described above. This is a sensible and flexible approach as it allows the creation of many categories based around our duty to protect the public. Moreover, we note concerns raised in responses to the ESR draft standards and learning outcomes consultation, that the outcomes need to be measurable, attainable, realistic, and deliverable within a timescale.

Specific Measurable Attainable Realistic Time-bound.

A learning outcome should aim to be SMART and clearly articulate what is expected. A comparison of verbs, adjectives and nouns used by the GMC and the GPhC to construct their learning outcomes is contained in Table 1.

Table 1 Selection of verbs, adjectives and nouns used by the GMC and the GPhC to construct learning outcomes

General Medical Council (2018) General Pharmaceutical Council (2018)

Verbs

Adjectives/ Nouns/ Verbs/

Verbs/ Adverbs

Adjectives/ Nouns/ Verbs/

Prepositions/ Adverbs Prepositions/ AdverbsConjunctions/   Conjunctions/  

Nouns/   Nouns/ Determiners

 

Determiners   Adverbs  

Access Reliable Information Act * Openly & honestly

Accurately * Record Apply Professional JudgementAcknowledge And Discuss Apply The LegalAct With Integrity Critically Evaluate Guidance

21

Adhere To Responsibilities Demonstrate The ValuesAgree Medication Plan Demonstrate Effective DiagnosticAnalyse Clinical Phenomena Demonstrate Effective LeadershipApply Epidemiological Data Develop Effective StrategiesAssess Patient’s Capacity Effectively Promote HealthyAssess And Determine Engage * EffectivelyCommunicate * Clearly Engage In ResearchDemonstrate Clinical Responsibilities Ensure The QualityDemonstrate Working Collaboratively Implement Appropriate StrategiesDescribe Emerging Trends Proactively Support PeopleExplain The Relationship Proactively Participate InDescribe/Apply The Principles Respond Appropriately ToEvaluate Clinical Complexities Take Responsibility ForEvaluate The Determinants Take Into ConsiderationExplain And Demonstrate Take Appropriate ActionsIdentify/Assess The Need(s) Understand And MeetIdentify Appropriate Strategies Understand And AddressInterpret The Results Understand And PerformMaintain * Confidentiality Undertake * SafeMake Clinical Judgements Work In PartnershipManage The Uncertainty Work Collaboratively WithPropose A Plan      Provide * Explanation      Raise And Escalate      Recognise Potential Impact      Respect Patient’s Wishes      Review Sociological Concepts      Safely And Sensitively      Seek Informed Consent      Select Appropriate Forms      Support And Motivate      Take Professional Responsibility      Take A History      Understand The Processes      Work * Effectively      

The construction of learning outcomes varies in complexity. Some are simple and contain a caveat, for example “Apply (1) professional (2) judgement (3)…in all circumstances”. Other outcomes contain contingent provisions which determine the meaning of the outcome. Such a contingency could be “Take (1) into (2) consideration (3) factors that affect people’s behaviours in relation to health and wellbeing”. Overall, the GPhC’s proposed outcomes are shorter and less specific compared to the GMC’s which contain more outcomes, have greater structural variance and are more prescriptive.

There are different approaches to writing outcomes with assessment implications. Current GOC competencies are prescriptive and as such produce a binary outcome: the provider does or does not meet the stipulated competence. Less prescriptive

22

outcomes may allow providers to be more flexible in delivering their outcomes. They may be accompanied by a framework which will assist an assessment officer in determining whether the outcome is delivered at an appropriate level. Miller’s learning levels set out in the Pyramid of Clinical Competence is used by the GPhC to describe and assess outcomes (see Table 2).

Table 2 Miller’s Learning Levels - as set out by the GPhC (2018)

Learning levels Description

Level 1 – KnowsKnowledge that may be applied in the future to demonstrate competence. Assessments may include essays, oral examinations and multiple-choice question examinations

Level 2 – Knows how Knows how to use knowledge and skills. Assessments may include essays, oral examinations, MCQs and laboratory books

Level 3 – Shows howDemonstrates student can perform in a simulated environment or in real life. Assessments may include OSCEs, simulated patient assessments, taking a patient’s history etc

Level 4 – Does Can act independently and consistently in a complex but defined situation. Assessments may include OSCEs or other observed assessments

Other frameworks include Bloom’s taxonomy, used to classify educational learning objectives into levels of complexity and specificity and the UK NQF which define and link levels and credit values of different qualifications.

Scope of PracticeWith respect to professions regulated by the GOC, it is not within the remit of the ESR to alter the legal scope of practice. The content of the ESR reflects current clinical practice within the optometric professions with public safety at its heart. It is primarily focused on high risk areas of clinical practice and the knowledge, skills, values and behaviours required to be a safe practitioner. The work and experience of other health care regulators will assist us with our work, and we intend to adopt elements of each including:

The use of S.M.A.R.T. as a test of the overall quality of drafting, Miller’s pyramid of clinical competencies to assess whether the outcome meets an

appropriate level, Using appropriate grammar Broadly linking education outcomes with our professional standards and

continuous education training and development (CET).

23

Annex One: Summary of Comments from ESR Education Standards and Learning Outcomes Consultation 11.18 - 02.19

This only includes stakeholders who agreed to their responses being made public.

General ContentPositives: Competencies are good; like references to 2016 practice standards It covers the remit very well Very comprehensive, the interpretation and the analysis of requirements is all

encompassing The education standards are fine

Negatives: Why change something that's works fine as it is? More specific clinical requirements needed There doesn't appear to be an overarching educational philosophy guiding the draft

Education Standards and Learning Outcomes and this is unfortunate They cover the broadest spectrum of education levels ranging from say level 2

(GCSE) (e.g. LO 1.2) to level 7 (LO 1.8). This is a consequence of having a single set of standards and learning outcomes

Many of the Learning Outcomes are either written in such a way that they could not easily be measured or are sufficiently vague as to be measurable at several different levels. In a model that allows providers to educate students to the point of registration, this raises serious concerns over how rigorous the assessment and monitoring processes would require to be to ensure outcomes are fully met

The most severe risk is that the draft learning outcomes could be interpreted and acted upon to very differing levels of understanding or knowledge, giving little guarantee of professionals entering the register at the same level for their category

I am concerned that Learning Outcomes (LO'S) are generalised and do not contain specific measurable competencies and would therefore make it difficult if not impossible for the LO's to be assessed with equal rigour by all stakeholders. this will result in a variation of standards.

They do not appear to be located within any educational framework (e.g. Bloom’s Taxonomy). This leads to a lack of clarity for educators, education visitors and the public with regard to the level at which they should be assessed/how they should be assessed. A variety of terms are used but without any definition (e.g. knowledge, ability, understanding, analysis, apply, diagnose)

They are not written in a way that facilitates clear assessment of achievement of learning outcomes and are too vague in many places to allow clear delivery of consistent outcomes

I feel that it is incomplete and that the learning outcomes are pitched at the wrong educational level for both Optometrists and Dispensing Opticians

It seems very repetitive and much of it seems superfluous The Learning outcomes are great for a profession 10 years ago but are not

relevant to the direction of travel since

24

The learning outcomes do not provide any guidance on the practical skills required by students

DesignPositives: The new framework is more open and less prescriptive Common domains across the profession is a welcome move to encourage shared

learning and inter-professional respect It is a good idea to have the same learning outcomes for DOs and optometrists as

far as possible It is helpful that there is a great deal of commonality between DO and optometrists

as it will make career progression course much easier to design and make optometry a much more inclusive profession

An infographic of the different sections would be useful

Negatives:

The outcomes contain elements of knowledge, skills and behaviour in varying mixes across the four domains. This makes curriculum design more cumbersome than it needs to be. We suggest delineating the outcomes into three domains entitled ‘knowledge’, ‘skills’ and ‘behaviour’

The format is hard to understand in the beginning, as far as language is concerned it's not hard, but the structure flow is hard to understand

It lacks a contents page, which would be useful to find a point easily

DraftingPositives:

Well written, clear, thorough and structured well The language is clear, overall easy to read Easy to understand with no jargon, short and to the point The document is worded very well and flows well The structure of the draft is easily understandable and accessible. The language

used is accurate I think the draft is good, slightly wordy and pompous in its language

Negatives:

Some of the statements are slightly ambiguous and do not make the outcome entirely clear

The learning outcomes need to be more concise to ensure standardization across providers*

The outcomes vary considerably in length and are often clumsily constructed with attempts made to specify the curriculum within them

Some of the outcomes are unmeasurable and need further refinement Not precise enough, open to interpretation. Not complete and the language is

woolly Learning outcomes need to be measurable if they are to be assessed properly, so

their meaning needs to be clear. These are not They do not define the breath or depth of knowledge required There seems to be a lot of repetitiveness throughout

25

Used complicated language which was not easy to follow Language vague, the public will be at risk Plain English required Terms used in the learning outcomes are not defined (e.g. knowledge of,

understands, ability to) The phrases “understands” and or “is able to” are redundant. Many of the other

words that follow these phrases work well on their own Would “trainee” be a better description than “student” as it will include apprentices

and those moving from one profession to another The Standards are complete, but I find the language used too broad in its nature

Detail

Negatives The draft outputs are open to interpretation by providers. For example 3.1 refers to

a 'range of conditions and patient groups'. If the current system of a standardised final assessment in the SfR is to be replaced, there must be more robust outcomes than these to avoid significant variability

Each learning outcome in Domain 1 covers a huge range of knowledge, skills and behaviour that would be difficult to meaningfully measure in a defined way, and are clumsily constructed.

There is a standard relating to supporting students, but we think this would benefit from being expanded. Similarly, we think it would be helpful to include a standard about supporting all educators (academics as well as visiting teachers from practice), supervisors, assessors and examiners in relation to training and resources

There are areas missing compared to the core competencies, for example for contact lens opticians there is now nothing related to verification of contact lenses and I found nothing related to determination of prescription needed of contact lenses

There are sections of the learning outcomes which need to be clarified, such as 1.10 - what are complex contact lenses? Therapeutic, scleral, multifocal, toric, high prescription? Some of the categories in this list represent specialised fitting, experience of which would be difficult to provide for all trainees. Clarity is required.

There appears to be too much weight allocated to Anatomy, Physiology and abnormal ocular conditions. These are unnecessary and are merely being used as a route to push 'MECS' and refraction services

Greater detail would be useful to clarify the depth of knowledge required in professional practice

Learning Outcomes as they stand offer no advancement in knowledge for DOs

Notes (from consultation respondents):

* S1.5 states: “Provide opportunities throughout the programme for students to learn and participate regularly in reflective practice, including reflection on case-based discussion, peer review and clinical audit, so as to engage in a process of continuous learning and development.

Is peer review relevant at undergraduate level? There may be a place for peer learning but best not to be too prescriptive regarding this.

26

S2.8 states: “Ensure that all staff involved in the design and delivery of programmes (including clinical experience) are professionally competent to fulfil their roles.” How would this be judged?

S2.10 Ensure there are sufficient resources to deliver each programme in accordance with these standards, including teaching and support staff, equipment and facilities, and access for students to all relevant forms of clinical experience. More detail on this is appropriate such as the number of FTE staff and staff to student ratios to maintain appropriate standards.

S3.2: What does it mean to develop a programme “holistically”?

S3.3 states: “Ensure that students are equipped to practise competently and safely in any geographic location in the UK as an optometrist, dispensing optician, contact lens optician, or optometrist independent prescriber, and are aware that contractual requirements vary in different countries and regions of the UK.” This would suggest that students exit being able to practice in any location doing anything??

S4.5 states: “Develop appropriate arrangements with third parties, including professional bodies, employers, hospitals and other education providers, to ensure that students receive early, frequent and varied observational and practical experience, and a greater level of clinical skills development during their placements.” What is meant by ‘early’ and ‘frequent’ and when it says “greater”, greater than what?

S5.7 states: “Seek to facilitate professional mobility for prospective students with experience of working in the eye health sector where this is feasible and in doing so, take into account GOC guidance on the accreditation of prior learning.” This is aimed at pathways for optical assistants etc. to go on to become DO’s / OOs – they note the GOC guidance on the accreditation of prior learning, but fail to comment that the Universities should also have rules around accreditation of prior learning.

With regard to Learning outcomes:

1.2: Optometrists clearly undertake many more health assessments than simply refraction. This LO needs to be re-written to reflect the professional standards that we currently work to in all areas of practice. Why also is there such a focus on the case history here with all other aspects of the routine ignored?!?

1.8: Understands and applies knowledge of pharmaceuticals, pharmacology and microbiology to patient care. Understands the principles of independent prescribing and the legislation relating to the use and supply of exempt and controlled drugs. [Standard 7] Does this mean we have to include the theory of IP in our UG curriculum?

27

1.16: As a newly qualified optometrist, has all necessary knowledge and clinical skills for the delivery of primary care service contracts in the UK. – primary care service contracts are likely to include MECs/PEARS/post-cataract/etc and be different in their delivery and protocols across the country. Is this really what is meant here?

With regard to 1.4, 2.5, 3.7, 3.8, 3.9, 4.2, 4.3, 4.4, 4.6…how can we evidence these during the undergraduate programme? Do they have to be demonstrated as a competency?

*******************

Optometry 1.16: ' ...has all necessary knowledge and clinical skills for the delivery of primary eye care service contracts in the UK'. This encompasses all the other learning outcomes, making the remainder apparently obsolete.

Optometry 1.5: covers optics, BV, CL, LV, refraction and accommodation in one outcome!

Having specified that Dispensing Optician is a level 5 qualification, 2 learning outcomes are included which would be deemed level 6 by a University:

1.13: '… able to use peer-reviewed and clinical literature...'

3.1. '...able to critically evaluate research and developments in optical and vision science...'

Domains 2-4 restate the standards for optical students and could be replaced by a single learning outcome to this effect. Contact lens opticians will already have demonstrated learning outcomes in Domains 2-4 by becoming dispensing opticians prior to commencing CLO training to what extent would they need to demonstrate these LOs again, or in a specific CL capacity?

END

28