Duncan Rudkin tells Neil Trainis the General Pharmaceutical Council had to take the best decisions possible regarding March’s assessment in light of the information it had at the time…
There is nowhere to hide and Duncan Rudkin knows it. Not that the chief executive of the General Pharmaceutical Council wants to conceal himself or avoid talking about the regulator’s calamitous handling of the registration assessment in March. Quite the opposite.
He is relaxed and happy to set the record straight, to try and explain what went wrong, why candidates were kept in the dark for eight months about when the June and September exams last year, postponed because of the pandemic, would take place. And why, once clarity had been provided, many found they were unable book places at test centres run by Pearson Vue, appointed by the GPhC to provide sittings.
Students took to Twitter to vent their spleen and air their grievances. Why, they asked, were they being put through such unnecessary stress and anxiety when preparing for an exam was nerve-racking enough?
Other pharmacy bodies wanted to know why there was not enough capacity for students to sit the exam. Candidates in Scotland agonised over the prospect of having to travel long distances to centres that were not booked up.
Duncan justifiably suggests that since the GPhC had never staged an assessment during a pandemic, one that had forced society into the unknowns of social distancing, mask-wearing and constant virtual communication, challenges were inevitable. Yet he is also quick to point out the GPhC was not oblivious to the impact those challenges had on students.
“We would all recognise, as the Council does, that it's been a very difficult year for candidates for a whole host of reasons, primarily because of the challenging circumstances that many of them were facing both personally and at work during the pandemic and the way they have risen to that challenge as key members of the workforce which has been hugely impressive,” he says.
“The public at large have a lot to thank them for but also those who supported them throughout that time, their colleagues, their senior pharmacists they've been working with, their family and friends as well and acknowledge how challenging a time it has been for them.”
Motivated to safeguard welfare of students and trainees
The uncertainty of not knowing when the rescheduled assessments would take place took its toll on candidates but Duncan persuasively points out the delay was mitigated by the GPhC’s creation of a provisional register to allow them to work and help pharmacies on the frontline.
There was a need, he says, to strike a balance between maintaining “standards of entry” to the register “to protect patient safety” and supporting the NHS and community pharmacy during the pandemic. In his eyes, the provisional registration scheme allowed the latter to be achieved, although some people in positions of influence, including English Pharmacy Board chair Claire Anderson, thought the GPhC should have scrapped the March assessment and registered all prov-regs.
One view was they had proven themselves in intensely difficult circumstances and needed to continue channelling their energies into serving their local communities during Covid-19, not be distracted by an assessment that had become more of a nuisance than a necessity. Duncan does not share that view.
“First and foremost has to be for us as a public interest regulator maintaining standards for entry to the register so patients can be sure about the safety and quality of care they are going to be given by new entrants to the profession both during the pandemic but over the long term because we're talking about people's careers over many years and decades,” he says.
“We also felt it was important to minimise the risk of blockages or gaps in the pipeline of new entrants to the profession, so we had to think about 2020 but also 2021 and the impact of any decisions we made in future years.
“And throughout all of that in parallel, we were very motivated to do as much as we could to safeguard the welfare of students and trainees and also to make sure their work was given proper recognition, so these were all factors that, in the face of the reality that it would not be possible to run the assessment sittings in the summer and autumn of 2020 as we normally would have done, we then had very quickly to work out what the alternatives were and how we were going to implement those.”
Duncan says scrapping March’s assessment “would have risked compromising public safety and it could have potentially left those individuals throughout their careers with a question mark about their suitability to go on the register.”
Not enough capacity for students
But that was hardly the most pressing issue the GPhC faced. An important objective, he insists, was to explore “the art of the possible through a procurement process to find a partner to work with to put in place an online platform” and that led them to Pearson Vue.
“That process itself took quite a long time, to work through the procurement process and then finalise those arrangements. Throughout that whole time we were frequently reminding ourselves, as others were reminding us, of the need that candidates were going to have for information and that we have to balance giving information as quickly as possible but also with the highest possible degree of confidence in that information.
“What we didn't want to do was give information which we would then have to change. That was where we ended up with the timing around the dates.”
Once that hurdle had been cleared, it soon became clear that between the GPhC and Pearson Vue, not enough capacity had been created for students to sit the assessment. But ultimately, Duncan says, the two of them “were able to respond to that…through a great deal of hard work which made a big difference for individuals.”
“The capacity issue was critical. Essentially, the challenge we all had, ourselves and Pearson Vue, was the social distancing and other restrictions limiting capacity in their centres and the large number of candidates who wanted to sit,” he insists.
“The booking process had those difficulties and for the candidates involved, that must have been an added stress and worry at what was already a difficult time.
“As quickly as those issues came to light, particularly and most significantly, the challenge that a number of candidates who experienced in Scotland booking test centres, the team at the GPhC with Pearson's support, did work ultimately quite effectively and very quickly with a real sense of purpose and commitment to resolve those issues for people.
“When we look at the outcome, we were able ultimately to provide the exam to a large number of candidates, the vast majority of whom were able to sit at centres that in many cases would have been nearer than the large centres they would have had to use in normal times.
“So yes, there were those challenges with the booking system which were very regrettable, very unfortunate but were essentially a consequence primarily of the capacity challenge we were experiencing.”
It is put to Duncan that the GPhC was simply unable to foresee and pre-empt those capacity issues.
“The context, of course, included that this was the first time that we were doing anything like this and it was playing out in real time and the Pearson's system and operating model had been well tried and tested by then by a number of different clients.
“This was the first time it was going to interact in a dynamic, real-time way with the GPhC candidates at scale and with very large numbers and in a way that would have been impossible fully to test in a testing environment.”
Panic amongst candidates at one point seemed to spread to the GPhC. They displayed no clear thinking when they sent an email to some overseas candidates on February 2 telling them they would not be able to sit the March exam remotely or at a local test centre before doing a U-turn just 13 days later and allowing them to do it online irrespective of time differences.
“We were learning as we went,” Duncan says. “One of the things we've been very open about is where we've got things wrong, just as we would expect everybody in pharmacy to adapt and learn and where necessary change, we had originally concluded it would not be possible for overseas candidates to sit.
“It became clear that there were a number of people who were very concerned about that, those candidates who were highly motivated to sit the exam, and so we took further steps to explore how we could enable that and ultimately we did for the majority of those candidates make that possible.
“So yes, that was a change from what we'd originally said but it was the right thing to do, to respond constructively, to go that extra mile to make that possible for those candidates overseas to sit the assessment.”
The GPhC’s appointment of Pearson Vue should also be questioned given the capacity issues. Duncan is asked if the GPhC regrets choosing them to provide assessment sittings.
“That's a very good question. We have to look at the outcome ultimately. The arrangements we put in place with Pearson Vue enabled the registration assessment to take place in a way that I and the Council can be confident in in terms of security, integrity and fairness and an experience for candidates which, in some cases in the run-up to the exam, was troubling.
“Actually, for the majority of candidates involved, relative to a normal year, (they had) much shorter journeys than they would normally have had in smaller test centres which has some advantages. So I think the answer is one has to make the best decisions possible in light of the information available at any point in time and that was the approach we've taken throughout.
“So I'm going to resist the temptation to look at this through the lens of hindsight and say we made decisions at the time which enabled us to achieve the kind of outcomes we were looking for which are the ones I've set out, and completely recognising during the course of that, there were all sorts of stresses and concerns for candidates generally in terms of the overall time taken and the length of time they had to wait but also for a number particularly affected by those booking issues.”
Sorry for any distress caused
Duncan is adamant the procurement process the GPhC followed “was very thorough, comprehensive and competitive” but does not say how many assessment sitting providers they approached.
“I'm not trying to be evasive but there are some rules about procurement information which are very important in terms of commercial sensitivity.
"But in general terms, the reassurance we can provide is that was a legally sound and competitive procurement process (and) we explored different models of serving this as well bearing in mind that we were in the situation of not knowing what the pandemic situation was going to be at the point of delivery. We certainly explored options with a number of potential providers.”
There are lessons to be learned and Duncan does not shy away from that. On the contrary, he says it’s in the GPhC’s DNA to learn from its mistakes, just as it would expect its registrants to learn from theirs.
Naturally, he has regrets, such as the GPhC predicting a lower exam pass rate this year than in previous years just a few weeks before students were due to sit the March assessment – hardly the kind of statement to inspire confidence in students who were already finding it tough to prepare.
“I think it was regrettable. I regret it, I'm sorry for any distress it caused to those individuals,” Duncan says. “It was the case and remains the case that it was not a prediction from an education point of view. It was simply for financial planning purposes, a very conservative planning parameter that was used and referred to in that paper in a way which, as I've said, was very regrettable and unfortunate.”
With the Professional Standards Authority monitoring the general performance of the GPhC, the pressure is on even if it is a natural side-effect of scrutiny. The government, as Duncan is only too painfully aware, is still keen on reducing the number of healthcare regulators.
“We will answer (the PSA’s) questions as we've been trying to answer your questions and a lot of the same information will form part of those answers.
“Throughout the pandemic, we've kept closely in touch with the Professional Standards Authority as you would imagine and we proactive in updating them on the situation we were facing with the assessment, the arrangements we put in place in relation to provisional registration and the exam and the rationale for all of that.
“And of course, given their role, I would expect that their focus, like ours, will be very much on where we took the right steps and still are taking the right steps particularly to maintain standards for entry to the register and to protect patient safety and their quality of care.”