Appendix 9: 2023-25 RACGP CPD quality assurance and compliance framework for providers
Conduct of CPD quality assurance assessment
The Royal Australian College of General Practitioners (RACGP) undertakes regular monthly quality assurance assessment (QAA) of continuing professional development (CPD) activities to ensure compliance and to initiate quality improvement.
QAA is an audit function and is applied to a minimum of general practitioner (GP) CPD activities under the Australian Medical Council guidelines for CPD homes and CPD provider activities, promotional materials and administrative requirements.
QAA of a CPD activity may be undertaken to ensure alignment to RACGP CPD Activity Standards and the CPD Provider Agreement, to review the appropriateness of activity hours assigned to a CPD provider activity or GP’s records, and/or to review information received through feedback or if requested by the RACGP.
QAA (Figure 1) will be conducted where potential risks to quality of CPD or alignment to the RACGP CPD Activity Standards and the CPD Provider Agreement are identified or may exist. QAA will also be conducted randomly across all CPD provider activity and GP records.
QAA review is to be initiated:
- For all new CPD providers
- For CPD provider activities that are 20 hours or more
- For CPD provider activities that meet all the MBA CPD activity types and/or hours in a single activity
- To investigate adverse member, participant, provider, or staff feedback
- on a random selection of provider CPD activities for adherence to the RACGP CPD standards,
administrative requirements and operations or compliance as set out in the CPD Provider Agreement.
Conflict of Interest
Conduct of audits will be aligned with the RACGP Conflict of Interest policy.
Figure 1. CPD Program quality assurance assessment process
Conduct of the QAA for CPD provider activities
QAA generally requires a review of all activity materials, including presentations and use of CPD Program branding. The materials are reviewed for consistency with the requirements of the CPD Activity Standards (Appendix 1) but other methods can also be used.
The following steps outline the RACGP's process for conducting a QAA and the requirements for compliance during and after.
1. Methods used to conduct a QAA
QAA may include any of the following
- a request for activity materials
- an RACGP representative attending the activity
- a meeting with relevant provider representative/s to discuss aspects of the activity
- conducting a feedback questionnaire with GPs who have completed the activity
- a comparison of an activity against another similar provider activity
- a full CPD activity review
2. Notification of a QAA
The RACGP CPD staff member will notify the provider of the QAA and the method/s that will be used to conduct it. If requested, the provider must provide all written, visual or audio materials, including presentations, as well as online access to CPD activity content where applicable, within seven working days of written request or as otherwise agreed to with the RACGP CPD staff member.
3. The QAA review
The review will be undertaken by the RACGP CPD staff member to determine whether the activity meets the CPD Activity Standards and the administrative requirements of the provider agreement. Where required, it may be referred to senior CPD Program staff, National Clinical Lead - CPD and medical educator(s) or subject matter expert(s).
4. Outcome of a QAA
Following a QAA, the RACGP will notify the provider of the outcome in writing.
No action required
- The activity is consistent with required CPD Activity Standards and/or the Provider Agreement and no further action is required
Recommendations for improvement
- Recommendations for improvement of the CPD activity must be actioned within seven days of receipt of written notification, or by agreement with the RACGP CPD staff member. The RACGP staff member will work with the provider on resolving any issues that may arise in relation to implementing the recommendations.
Revised promotion of a CPD activity
- The RACGP may publish a notice on its website advising GPs that the relevant CPD activity is under review and, until further notice, may not receive CPD Program recognition for hours.
- The provider is required to publish the same notice on their website.
Restriction of access to the CPD dashboard
- The provider will have restricted access to the CPD dashboard to submit activity notifications until completion of the QAA and will not be able to resume access to notify of further CPD activities until it has received written approval from the RACGP.
5. Non-compliance with the QAA
CPD Providers must cooperate in all required aspects of the QAA. Failure to adhere to the request for a QAA (eg, by failing to provide materials upon request and within the specified time frame or failing to comply with a request to meet or to implement the QAA recommendations), will result in restrictions being applied. Restrictions may include:
- suspension of approval of the activity, which will prohibit advertising the activity as an ‘RACGP approved activity’
- removal of permission to use RACGP CPD logos
- removal or adjustment of CPD hours allocation to the activity
- suspended access to the CPD Provider dashboard
- termination of the CPD Provider Agreement.
6. Appealing a decision
There are escalation points in all CPD decision processes and no one person will have authority to reject an application or place restrictions on CPD Provider activity. However, if the provider wishes to appeal either the outcome of an application for approval of an activity, or the outcome of a QAA, an expert panel may be convened to consider and review the decision (Figure 2). The provider will be asked to bear the costs to convene an expert panel. Further information is outlined in the RACGP complaints process.
Figure 2. CPD Program investigation and review process
The RACGP encourages GPs to provide feedback on their experience. This section is designed to give providers some examples of the type of complaints that have resulted in initiation of a QAA.
A complaint may arise when:
- notification is received of a provider’s failure to, for example, maintain proper records, advise the RACGP of participating GPs’ entitlement to CPD hours for the relevant activity, issue certificates of attendance to participating GPs, or to provide the RACGP with the activity application or notification and the activity report within the required timelines
- a multiple-choice questionnaire is used to direct GPs to a particular product or service, or to a product manufactured or distributed by a sponsor, as the preferred method or treatment
- the promotional material for an activity may be perceived as exerting pressure on participating GPs to prescribe drugs manufactured or distributed by a sponsoring pharmaceutical or medical products suppliers
- the assessment of competency is insufficient for the teaching of advanced procedural skills, highlighting a potential risk to patient safety
- the activity has not been consistent, either in content presented or methodology, with advertising or as described on the RACGP ‘Browse’ web page.
De-identified trends and data will be reviewed on a quarterly basis and results used for continuous quality improvement of the CPD Program.