Appendix 9: CPD quality assurance and compliance
Conduct of CPD quality assurance
The following outlines the steps and methods used by The Royal Australian College of General Practitioners (RACGP) to undertake quality improvement and investigate or review non-compliance.
A quality assurance assessment (QAA) of a continuing professional development (CPD) activity can be undertaken to ensure alignment against RACGP CPD Activity Standards and the CPD Provider Agreement (Provider Agreement). If requested by the CPD Program Coordinator, providers must participate in the QAA process in a timely manner.
A QAA (Figure A9.1) can be initiated by the RACGP to undertake:
- a routine audit of CPD activities that have been selected at random
- an investigation into adverse feedback received by a participant or a complaint about a CPD activity
- a review of the provider’s adherence to administrative requirements and operations or compliance as set out in the Provider Agreement.
Following the QAA, feedback is given to the CPD Provider that may require no further action or identify opportunities, recommendations and/or requirements for improving the activity.
Figure A9.1. CPD Program quality assurance assessment process
Conduct of the QAA
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 employed.
The following steps outline the RACGP process for conducting a QAA and requirements for compliance during and after.
Methods used to conduct a QAA
At the RACGP Program Coordinator’s discretion, any or all of the following methods to conduct a QAA may be undertaken:
- request for activity materials
- RACGP representative attending the activity
- meeting with relevant provider representative/s to discuss aspects of the activity
- conducting a feedback questionnaire with GPs who have completed the activity.
Notification of a QAA
The RACGP Program Coordinator 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, within seven working days of written request or as otherwise agreed with the program coordinator.
The QAA review
The review will be undertaken by the RACGP Program Coordinator. To determine whether the activity meets the CPD Activity Standards and the administrative requirements of the Provider Agreement, the program coordinator may refer information and/or materials provided to senior CPD Program staff and subject matter experts.
Outcome of a QAA
Following a QAA, the RACGP will notify the provider of the outcome in writing.
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 (for example, 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 of permission to allocate CPD hours to the activity
- suspended access to the CPD Provider dashboard
- termination of the CPD Provider Agreement.
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 Program Coordinator. The RACGP Program Coordinator will work with the provider on resolving any issues that may arise in relation to implementing the recommendations.
Following a complaint
If so directed by the RACGP, the following conditions may be applied during a QAA.
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 points.
- 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 online 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.
Challenging 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 challenge 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 A9.2). The provider will be asked to bear the costs to convene an expert panel.
Figure A9.2. CPD Program investigation and review process
Examples of complaints
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.