Questions and answers

These are questions that were raised during the 2015 consultation in relation to the proposed CPD Scheme. Click on the question to reveal the answer.

Is this a consultation or preparation for implementation?
The new CPD scheme for osteopaths outlined in this consultation is a proposal that will be further shaped by the views and suggestions of osteopaths and others gathered by the GOsC in the course of this public consultation exercise.
What we are proposing has been developed by osteopaths and for osteopaths over a number of years, taking into account what has been learned from the 2012 revalidation pilot and the recent extensive review of the existing CPD scheme. It also aims to satisfy public expectations of patient safety, care quality and the fitness to practise of health professionals.
Your views are crucial in helping us ensure a CPD scheme that is demonstrably effective, is appropriate to your practice and patients, and is affordable and achievable. This consultation period gives everyone the opportunity to be involved and make a contribution to building a scheme suitable for the osteopathic profession.
Why do we want to change the current CPD scheme?
Through extensive work in partnership with osteopaths we have developed a new scheme which better supports practice, patient care and CPD.
The current CPD scheme was introduced in 2005 and since then we have monitored its application in practice, including feedback from osteopaths, osteopathic organisations and CPD providers, and in 2011-12 we conducted an extensive formal review. We have also been part of wider Government-led discussions among health regulators and others, concerned that current CPD systems do not offer the public adequate assurance that a health professional is actually keeping all essential skills up to date and is fit to practise.
Working closely with osteopaths and osteopathic organisations across the UK, and testing ideas with patients, we are looking at strengthening the osteopathic CPD system by building on what we know is already working well. The proposed CPD scheme on which we are now consulting has many familiar features, but suggests clearer requirements in areas where there is evidence that practice could be improved. Most importantly, the proposed scheme aims to address the risk of professional isolation by fostering a culture of peer support and creating collaborative learning environments.
More information about the background to the proposed new CPD scheme is available in Introducing our new CPD proposals. You can also watch the introductory video.
Will I have to take an exam as part of the new CPD proposals?
No, there is no exam involved.
We believe the CPD process should focus on osteopaths improving their practice, through reflection and continuous learning, not rely on a pass/fail test. Giving osteopaths the scope and opportunity to share knowledge and experience, and seek improvements, is likely to produce better outcomes in terms of both safety and quality of practice.
Detailed information about our proposals is available in the draft CPD Guidelines.
I agree with 90 hours CPD over three years, but I don’t agree with the fixed requirement of 30 hours per year. Why can’t there be greater flexibility?
As with the existing CPD requirements, the new scheme proposes that osteopaths continue to complete 30 hours of CPD per year. This supports a culture of continual learning and avoids the less satisfactory prospect of an osteopath neglecting their professional development for, say, two years and cramming up to 90 hours of CPD into the first or final months of a thee-year cycle. It would be difficult to show engagement with the scheme if an osteopath crammed all 90 hours into one year of the cycle in normal circumstances.
However, we expect there to be a degree of flexibility in the process – unlike our current scheme – so we anticipate osteopaths receiving automated feedback telling them how they are getting on compared to others.
This consultation exercise encourages osteopaths and others to suggest adjustments that will help to achieve the best outcome. More information is available in the draft CPD Guidelines.
I’m an osteopath involved in postgraduate education and specialist areas of practice. Can my work to develop the profession and mentor others count as CPD?
The short answer is potentially yes under the new proposed CPD scheme, while this would not be the case with the current process.
The proposed new CPD Guidelines advocate a broad approach to what constitutes ‘acceptable’ CPD:
‘CPD is any activity that maintains, enhances and develops osteopathic professional practice. CPD includes any learning undertaken by an osteopath and can include courses, seminars, practical sessions, e-learning, reading, research, individual study and any other activities that can advance practice. Undertaking CPD is an ongoing aspect of professional practice’.
It goes on to describe professional practice:
‘Professional practice can include clinical work, education, research or management responsibilities. Over the course of a three-year CPD period, CPD should be appropriately balanced over the whole of an individual’s practice. So, for example, an individual who only undertakes clinical work and holds no management or teaching responsibilities might confine all their CPD to clinical work. However, an osteopath who undertakes one day a week in education should undertake an appropriate proportion of their CPD in the area of education or teaching practice, in addition to their CPD in clinical practice. Over the course of a three-year period, osteopaths with management responsibilities should be able to demonstrate balanced CPD in this area.'
Above all, the proposed new scheme encourages osteopaths to take a balanced approach that ensures your CPD reflects the full range of your osteopathic practice. So if you provide mentoring as part of your practice, then keeping up to date your mentoring skills will be important, but your CPD should also reflect the skills needed to manage the range of patients you routinely see in clinical practice. 
I’m non-practising. How can I fulfil the objective activity requirement?
We appreciate that if you do not have contact with patients, it will not be possible to obtain patients’ feedback and other types of objective activity may be more challenging. However, there are other forms of feedback: for example, someone who is engaged only in teaching or research could invite student or colleague feedback. It is also possible to discuss your approach to hypothetical cases with colleagues. The critical issue here is to consider what is the best way in which your work can be enhanced and how you can use the input of others to help you identify your CPD needs?
CPD Standard 2 refers to ‘Objective activity’, but in the introductory video you refer to ‘Objective feedback’. Is it the same thing?
Yes, this is the same thing.
Objective activity is a broad term for any activity where the views or experience of others provide you with information about your practice that helps you to make improvements or enhance your skills. Feedback from a colleague observing your practice or from your patients are good examples of an objective activity that will help you to reflect on your practice and select CPD that will further develop your knowledge and enhance the quality of your care.
More information is available in the Resources and case studies: Objective activity document.
I don’t know how to do a clinic audit or collect patient feedback. Where can I find help?
The GOsC website for osteopaths, the o zone, offers a number of tools for collecting feedback on your practice, and these have been trialled by osteopaths. Another good place to start is the website of the National Council for Osteopathic Research, which also offers NCOR’s Audit Handbook for Osteopaths, an introduction for those with little or no knowledge of practice audit.
A completed example and analysis of patient feedback is also available in the dummy CPD folder in the Resources and case studies: Osteopathic Practice Standards document.
Further information to help osteopaths understand the objective activity requirement of the proposed new CPD scheme is available in the Resources and case studies: Objective activity document.
Why the focus on communication and consent?
We know from complaints about osteopaths dealt with by the GOsC and from claims handled by professional indemnity insurers, that there is a prevalence of problems around communication and consent in osteopathic practice. This is particularly significant because of the physical nature of osteopaths’ interactions with patients.
The GOsC and others are looking at improvements in teaching and guidance to address this and, to support this, the new CPD scheme proposes that osteopaths regularly refresh their knowledge and skills in the area of consent at least every three years. This approach should also meet public expectations about incorporating areas of high risk into any scheme that provides assurance of continuing fitness to practise.
More information is available in the Resources and case studies: Communication and consent document.
Why would I want to talk to another osteopath about my practice?
Professional isolation is a significant risk factor in any profession.
The peer discussion review process is intended to be supportive, creating for osteopaths the opportunity and secure environment in which to reflect on areas for potential development in their practice, assisted by feedback and advice from a colleague they respect and trust. Osteopaths are encouraged to choose a reviewer whose opinion you respect and who can bring fresh perspective to your practice. The reviewer could be an osteopath or another health professional. The proposals suggest that these peer-to-peer discussions could be arranged within regional osteopathic groups, or under the auspices of an educational institution, an advanced practice group or Osteopathic Alliance member organisation. Or, you can choose your own arrangements independently.
Osteopaths working with us developed the peer discussion process, and actively tried it out, in pairs and in small groups. They told us that discussing practice candidly with a colleague seemed quite daunting at the beginning, but the support and constructive suggestions of colleagues had, they felt, produced real benefits both to their practice and to themselves.
More information, along with case studies of osteopaths who have piloted a Peer Discussion Review, is included in the draft Peer Discussion Review Guidelines.
Could the peer review process not be open to wide range abuse?
The peer review process is not a pass/fail test – it is about continual learning and personal development and support for individuals – both personally and professionally. Cheating will mean the osteopath loses out on these benefits. The fundamental aim underpinning the new CPD proposals is to offer all osteopaths a supportive environment in which they can explore any concerns they have about practice and gather feedback from a professional colleague whose views and suggestions could add value to practice.
Many osteopaths tell us that they rarely have the opportunity to discuss their practice development with a peer and report feeling professionally isolated. The peer discussion review process aims to make the sharing of expertise an integral part of all osteopath’s professional development.
However, in common with any educational process, quality assurance is important for all concerned. Not only osteopaths but the public, too, should have confidence in the process. The GOsC will apply an appropriate process for auditing peer discussion reviews between osteopaths to minimise the risk of collusive activity. It is likely that Peer Discussion Reviews offered and conducted under the auspices of educational institutions and other osteopathic organisations will include their own, independent quality assured mechanisms. The GOsC would audit a higher proportion of reviews between osteopaths arranged outside of these more formal networks.
The proposed CPD scheme is a not a ‘soft’ option. If an osteopath fails to engage in the CPD process, or does not undertake all the required activities, they will be removed from the Register of osteopaths and prevented from practising. Meeting the CPD standards is a statutory requirement for registration.
If the peer discussion review process identifies the need for further development, the osteopath will be expected to undertake this CPD to ensure they meet the current standards. We will also be monitoring implementation of the proposed scheme to ensure that the Peer Discussion Reviews are working properly. More information on how we plan to audit and quality assure the proposed CPD scheme is set out in the draft CPD guidelines.
Can the same two osteopaths review each other?
Yes, the same two osteopaths can review each other.
It is suggested, under these proposals, that such arrangements are more likely to be audited by the GOsC in the interests of quality assurance, and this strategy is outlined in the draft CPD Guidelines. This will help to minimise the risk of collusive activity and will also help us to provide feedback to support those osteopaths undertaking Peer Discussion Reviews more locally. By this we mean those reviews conducted outside the auspices of a regional group, educational institution or other CPD provider, for example.
Will you have to change your peer reviewer from cycle to cycle?
This is not a requirement of the proposed scheme but we can see there are pros and cons of both continuity and change. Keeping the same reviewer might encourage consistency, but changing peer reviewer might give the osteopath more challenge and encourage development.
This might be a factor in any risk-based approach to auditing the scheme.
By getting osteopaths to conduct peer reviews, isn’t the profession doing the GOsC’s job?
It is the responsibility of everyone in the profession to develop a supportive learning community, ensuring that osteopathic practice continues to improve for the benefit of osteopaths and patients. This is a feature of a successful and maturing profession.
There are many ways in which a review could take place: osteopaths working with colleagues, osteopaths with an employer, osteopaths who are part of a regional group or a member of the Osteopathic Alliance. As a fall-back the GOsC can also conduct the review.
Based on feedback to date from the profession, choosing their own peer reviewer should enable the osteopath to discuss their CPD and practice in an environment in which they feel professionally comfortable. This encourages osteopaths not only to engage with the process of continual learning and development, but help also to focus on safe and effective practice and the overall quality care provided.
This does not mean the GOsC would not be closely involved in monitoring the CPD process. Our proposals relating to quality assurance and audit are set out in the draft CPD Guidelines.
If I conduct another osteopath’s Peer Discussion Review and sign them off, but a subsequent a GOsC audit concludes they have not met the CPD Standards, will I be liable in any way?
If we find significant differences, we may provide advice about this to both parties. However, we recognise that this is not a precise science – the key outcome is to help osteopaths to conduct discussions in a way that supports and enhances practice. The reviewer will not be penalised in any way, unless there is clear evidence of collusion.
What is the minimum CPD one can submit at the end of Year 1, and Year 2?
As with the existing CPD requirements, the new scheme proposes that osteopaths continue to complete a minimum of 30 hours of CPD each year (at least 15 hours of which should be learning with others). However, there would be flexibility for each osteopath to choose when they undertake the activities they need to do to meet the CPD Standards during the three-year cycle. Through the IT system, we hope to be able to provide automated feedback to osteopaths about what they need to complete in order to move to the next CPD cycle.
How can I meet the new CPD requirements when I practise on animals?
The Osteopaths Act governs the osteopathic care of human patients and, whether or not your practice involves animals, to remain registered with the GOsC you must meet the CPD requirements in relation to human patients.
The proposed new CPD scheme does encourage osteopaths to take a balanced approach to ensure your CPD reflects the range of your osteopathic work. So, for example, an osteopath with osteopathic teaching responsibilities would include CPD to enhance their professional practice in osteopathic teaching.  However it is essential that all registered osteopaths undertake CPD that is applicable to the osteopathic care of human patients. All osteopaths registered with the GOsC are required to undertake CPD – this includes those osteopaths who may be registered as non-practising. This is to ensure that registered osteopaths continue to maintain their fitness to practise as osteopaths even if they are not currently caring for patients. This could include a range of activity from shadowing other practitioners and discussing case scenarios, to reading relevant materials and attending courses.