The new GPhC Pre-Registration Manual was published yesterday! It's worth a read for all pre-registration trainees, pre-registration tutors and training providers alike. You can find a copy at: http://www.pharmacyregulation.org/preregmanual. The manual covers all of the essential information about the requirements set out by the regulator, the GPhC. There are some changes from the 2011/12 training year and these are as follows:

1.  The GPhC have provided more information about extenuating circumstances for completing the registration process within the set time period – eight years since starting the degree course for MPharm graduates (see sections 3.1.5-7).

“Limits may be extended if training has been interrupted or been completed part‐time due to:
  • documented, extended periods of illness
  • maternity/paternity leave/pregnancy
  • disability requirements
  • serving in the Territorial Army

If you feel that your circumstances may meet the criteria above then please contact the GPhC http://www.pharmacyregulation.org/content/contact‐us

Limits will not be extended to accommodate:
  • part‐time training for non‐extenuating circumstances
  • breaks in training for gap years
  • breaks in training for other non‐essential lifestyle reasons
  • additional periods of study resulting from failing an MPharm degree or OSPAP
  • additional periods of study resulting from negative tutor assessments during preregistration training
This list is not exhaustive.”

2.  The GPhC has been explicit about what should be in a learning contract, if you choose not to use their proforma (see section 4.1).

“You enter into a learning contract with your tutor, which summarises how your training year will be delivered and must include:
  • your trainee details
  • your tutor details
  • details of where your training will take place
  • how you will be supervised”

3.  The GPhC has provided greater clarity about conflicts in training regarding significant relationships (see section 4.3).

“To make sure there is an objective relationship between trainees and tutors, you must not train anywhere that you:
  • have a significant financial interest in
  • have a significant relationship with a director, owner or employee.
Significant relationships include:
  • any family relationships, such as father, mother, aunt, uncle, cousin etc.
  • marriage /civil partnership
  • girlfriend/boyfriend/partner
  • financial dependency or commitment”

4.  The GPhC has provided guidance on part-time training hours (see section 4.5.1).
“Part‐time means working at least 17.5 hours per week, over at least three days per week.”

5.  The GPhC has been explicit that a trainee’s exam eligibility may be affected by being absent from training for more than 40 days (see section 4.8.2).
“If you are absent for more than 40 days, it may affect your eligibility to sit the registration assessment or to register on a particular date, as you may have to undertake additional training.”

6.  Trainees may now be supervised by other healthcare professionals. This is a change from last year’s requirements that said, “7. A tutor should work together with their trainee ensuring appropriate support and should directly supervise their work on a regular basis. The tutor must ensure that a pharmacist is directly supervising a trainee at all times.”

The new requirements in sections 4.10.2 and 3 say:
“During the training year, you may be supervised for agreed periods by another healthcare professional, such as a pharmacist other than the designated tutor, a pharmacy technician or nurse. These supervisors are practice supervisors.

Your designated tutor remains responsible for you at all times, even when you are being supervised by a practice supervisor. Your designated tutor must know who is supervising you.”

7.  The GPhC states in section 4.10.5 that tutors must be approved by the GPhC, although it is unclear what the approval process involves other than compliance with the standards expected of all pharmacists and using the tutor development resource.
“Tutors must be approved by the GPhC. Tutoring rights may be withdrawn if a tutor fails to act in accordance with the GPhC’s Standards of conduct, ethics and performance http://www.pharmacyregulation.org/standards/conduct‐ethics‐and‐performance."

It then says in section 4.10.6 that “there is further guidance in the tutor development resource http://www.pharmacyregulation.org/tutor‐development‐resource"

8.  Although there was previously an expectation that trainees completed their training in their designated site, this is now reworded. Section 4.11.1 states:
“Trainees commit to a 52 week training plan at the training site, as stated on the application to enter pre‐registration form http://www.pharmacyregulation.org/forms submitted to the GPhC. This application should have been sent at least eight weeks before the start of the period of training.”

9.  The GPhC also specifies in section 4.11.2 that the training site must be approved for the full training period. This has not been specified previously.
“The training programme must be agreed by the GPhC prior to the start of training, and the training site must have been approved for the full period of pre‐registration training before you will be allowed to start your training.” 

10.  The GPhC has provided more detailed guidance on changing sites to another training organisation (see section 4.13.1 b) and this is as follows:
“This is a high risk option and we would not advise trainees to do this. You should consider that:
  • you may have a contractual obligation to your employer for the full training period
  • it could be considered as unprofessional conduct to revoke an agreement you have made with your employer
  • your new site must have current approval as a training site from the GPhC for the full training period
  • your eligibility to sit the registration assessment for the first time may be affected
  • all previous progress reports must be disclosed to your new tutor
However, if you feel that you have no alternative but to move organisations during your training year. Requests to move must be approved beforehand by the GPhC. Please contact us to discuss arrangements  http://www.pharmacyregulation.org/content/contact‐us.”


11.  In section 5.6 the GPhC states that tutors in all sectors must comply with the requirement to work full time. 
“If your tutor cannot work full time ‐ at least 28 hours over four days per week ‐ with you, the GPhC will consider the approval of more than one tutor (known as a joint tutoring arrangement). These agreements must be approved in advance and apply to all areas of practice.”

12.  There is a new duty placed on trainees to check regarding whether their tutor is eligible to start training on the agreed date (see section 5.9).
“You should check that your proposed start date is not affected should your tutor be under investigation by the GPhC. If this is the case, we will carry out an assessment to determine their continuing suitability to act as a tutor, pending the outcome of the investigation. You should contact us http://www.pharmacyregulation.org/content/contact‐us in order to check if there will be an impact on your proposed start date.”

13.  The GPhC has issued more guidance on what is wanted in a training plan. Further information can be found on the application for approval for the provision of pre-registration training 2012 (http://www.pharmacyregulation.org/sites/default/files/APPLICATION%20FOR%20APPROVAL%20FOR%20THE%20PROVISION%20OF%20PRE-REGISTRATION%20TRAINING%20FORM%202012.pdf).

“6.4.1 A structured training plan that shows how you will meet our performance standards  http://www.pharmacyregulation.org/performance‐standards must be sent to the GPhC as part of the approval of your training site.
You and your tutor should review this training plan together and produce a tailored outline of your training year to ensure that everything can be covered in the time available. Ideally, this should be a week‐by‐week plan which includes dates for the quarterly progress reviews, annual leave and training days. It should also give an indication of the area of practice that will be the focus of a given week, either on‐or‐off‐site.
Whether a plan is provided by the employer or produced jointly at the start of the training period, it should provide sufficient scope of practice and appropriate supervision to achieve all of the performance standards http://www.pharmacyregulation.org/performancestandards, which should be mapped to the weekly activities.”

14.  When reporting progress to the GPhC a progress report form must still be completed every 13 weeks and only sent to the GPhC if unsatisfactory. However the third and final progress report at the 39 week stage must be sent to the GPhC as it is a required part of the application to sit the registration assessment (and they need to be advised of all periods of unsatisfactory training). This was a change to the requirements last year and has carried forward for this year too.

15.  There are a few more frequently questions and answers regarding how a registration assessment paper is put together and these can be found at section 8.4.

16.  The previous requirement (below) regarding extended training and absence has been removed.
“20. Trainees who are starting an extra period of further training (because they have not achieved competence in all of the Performance Standards and have had their training extended) should follow these regulations and leave entitlements will apply pro rata.”

17.  The requirement on trainees and tutors to “complete a training survey provided by the GPhC towards the end of the 52 weeks.” has been removed.

18.  The “Requirements for Extra Training following failure in the Registration Assessment” have been removed. This may be because they will appear in the assessment regulations when published.

All in all, the new training manual is offering extra clarity and guidance around the GPhC’s regulations for pre-registration training.  We note the introduction of the idea of “practice supervisors” with interest!  As we also note the removal of any requirement to complete a GPhC feedback survey at the end of the year.  There is still no mention of specific standards for tutors and the four aspects of the role – role model, people manager, trainer/coach and assessor – continue to define the GPhC’s expectations and inform the self assessment and development required of the tutor.