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AHPRA POV

“Self-declared learning is not public safety.”

 

 

 

 

 

AHPRA POV

“Compliance builds trust.”

 

 

 

 

 

 

 

 

AHPRA POV
“If it’s uncomfortable, it’s probably necessary.”

 

 

 

 

Issue 2

 

Let’s just focus on hours spent : I would say 15 real hours per year, not 5 points per hour/ hours.  
One category of CME only .

And any activities may be counted, not just approved activities / approved reading.
Diversity should be encouraged , not suppressed.
If the Government want more than this, it is a reasonable ask for  them to fund the hours -  - at Dollars per hour.
The requirements have to be set at the lowest common denominator for  part timers esp. females in the work force working part time and also retiree doctors.  Perhaps only 10 hours per year for these medicos as opposed to the 15 hours per year required for full timers above.

Anyone working full time in General Practice does education just by reading the letters returned to them daily from specialists and hospitals..
What more do you want?

 

The Current Program:

The RACGP (Royal Australian College of General Practitioners) CPD (Continuing Professional Development) program has three main categories: Educational Activities, Reviewing Performance, and Measuring Outcomes. A minimum of 5 hours is required in each category, and the remaining hours can be allocated flexibly across the categories. Additionally, there are program-level requirements including culturally safe practice, health inequities, professionalism, and ethical practice. 


Here's a breakdown of the categories:


1. Educational Activities (EA): These involve learning new knowledge or skills related to general practice. Examples include attending workshops, conferences, or online courses. 
2. Reviewing Performance (RP): This category focuses on feedback and reflection on your own practice. Activities include peer review of records, patient feedback, or multi-source feedback. 
3. Measuring Outcomes (MO): This category involves assessing the impact of your practice on patient outcomes. Activities include audits of standards or guidelines, practice against relevant recommendations, or incident reporting. 
Program-Level Requirements:

These program-level requirements can be addressed within any of the three main CPD categories. For example, an online course on cultural safety would fall under Educational Activities, while a review of patient cases involving cultural considerations would fall under Reviewing Performance. 

 

 

SO ………
How about making the most basic requirement that doctors simply perform CME/PD activities that they deem are relevant to them?  Also let’s give equal rewards to equal time activities. An hour is an hour. Many of the things we do are educational. Reading specialists’ letters  should be regarded as educational for GPs. Why should some activities earn 5 points per hour while others earn one point per hour. This is just simply showing bias, largely on the part of employees / organisations involved in education. Empire building for administrative organisations.

I think self- recording  is the only way to ensure  that all activities can be counted. There should be statutory declarations which allow GPs to fulfill requirements by simply ticking an option.

For example,  “I am a full time GP , working more than 30 hours per week contact time and seeing at least an average of 80 patients per week for at least 40 weeks per year”
I am required to read  medical correspondence from hospitals and specialists as part of my work.”  Tick  > > >  CME / PD obligations: completed annually.

 

 

Decisions Decisions

Not the bosses, Not the State. Let the Workers decide  their Fate!
(or CME / PD in this case).

I think compulsory Resuscitation is not necessarily relevant or valuable to many practitioners. The real world is a busy place. You need to be able to choose for yourself what you believe will give you the best return on time investment in terms of CME/PD.
How  can you justify repeatedly doing something that the majority of doctors will never need? You could on this basis require everyone to do a self – defence course - so they are able to deal with violence in their practices ( a much more likely occurrence than a Cardiac Arrest),  or to watch 5 hours of sport on TV weekly – so as to be familiar with the types of injuries that may emerge.

THE AHPRA POINT OF VIEW: on this issue

The proposition that CME/PD should be reduced to “simple hours” reflects a fundamentally outdated understanding of how professional risk is generated in modern medicine. Time spent is not competence gained. AHPRA’s role is to ensure not merely that doctors are busy learning, but that they are learning the right things, in the right ways, aligned with contemporary expectations of safety, ethics, equity and accountability. The simplistic notion that “an hour is an hour” ignores the reality that some learning activities are trivial, self-serving, or reinforce outdated practice habits. Our structured categories exist precisely to prevent this.

Educational Activities, Reviewing Performance, and Measuring Outcomes are not bureaucratic indulgences; they are corrective mechanisms for a profession that has historically preferred autonomy over scrutiny. Self-recording, statutory declarations, and “tick-box” attestations are inherently unreliable. They invite selective memory, optimism bias, and, in some cases, deliberate misrepresentation. Public safety cannot be entrusted to the honour system of a cohort that resists oversight when that oversight challenges long-held assumptions.

Counting day-to-day clinical activity as CME collapses the distinction between “work” and “development,” which is exactly the distinction CPD is intended to enforce. Routine clinical exposure tends to reinforce existing patterns. CPD exists to compel engagement with what practitioners would otherwise postpone, avoid, or deny is relevant— particularly areas like cultural safety, inequity, ethics, boundaries, and professionalism where the profession’s self-assessment has repeatedly proven overconfident. If participation is left optional, the very cohorts most in need of recalibration are the least likely to undertake it.

Differential requirements for part-time and semi-retired practitioners may feel equitable to those cohorts, but risk creating a two-tier standard of care for patients. The community is entitled to expect the same level of contemporary competence from any registered doctor, regardless of hours worked. If the profession finds mandatory requirements inconvenient or unpaid, that reflects a misalignment between personal priorities and public trust. Regulation is not designed to be comfortable; it is designed to be effective. The community does not consent to lower standards for reasons of practitioner convenience.

Finally, proposals to allow practitioners to “choose what is relevant” misunderstand the regulator’s mandate. Relevance is defined by population-level risk, not individual preference. Where doctors disagree with mandated requirements, this is not evidence that the requirements are excessive; it is evidence that regulatory supervision remains necessary. Compliance is not optional in a system designed to protect those who do not have the expertise to judge practitioner competence for themselves.

 

Erasmus (the old dog) : Call It As I See It

Human interest view:
Doctors do not fear learning; they fear being treated as presumptively dishonest. When CPD becomes a surveillance ritual, it stops feeling like education and starts feeling like a loyalty test. That emotional shift matters: it pushes good clinicians toward defensive practice, disengagement, and early exit — not because they are unsafe, but because the system trains them to experience their own work as permanently suspect.

Legal fairness view:
A regulator can require standards, but fairness requires proportionality and clarity. Multi-category schemes that are hard to interpret, easy to breach accidentally, and difficult to contest operate like administrative tripwires. If the real “product” of CPD is paperwork that can be weaponised in a later complaint, then the system has drifted from quality assurance into punishment architecture — and that is not what lawful delegated power is meant to do.

Administrative reality view:
When policy is built around what is easiest to audit, it stops serving what is hardest to deliver: time, attention, continuity, and humane clinical judgement. The predictable outcome is not better medicine; it is better files. Meanwhile, frontline realities get reframed as “non-compliance,” and ordinary human limitation gets treated as a disciplinary defect.

Workforce sustainability view:
If part-time and semi-retired clinicians are driven out by unpaid compliance load, access collapses first in the places already under strain — rural towns, outer suburbs, and high-need communities. That isn’t theoretical; it becomes longer waits, shorter consults, and more pressure on emergency departments. A regulator that ignores this trade-off is not protecting the public; it is redistributing harm.

Cynical aside:
If you measure doctors by their forms, you’ll eventually get doctors who practise filling in forms.

 

Institutional power view:
A regulator that defines competence, designs the tests of competence, judges compliance with those tests, and then prosecutes failure holds an unusual concentration of power. In any other domain, such concentration would trigger independent separation of roles. When one body writes the rules and benefits from finding breaches of those same rules, the system begins to resemble self-justifying authority rather than neutral oversight.

Evidence quality view:
There is little transparent evidence that multi-layered CPD point systems produce safer outcomes than simpler professional development models. What is measurable is compliance. What remains largely unmeasured is whether patient care improves in proportion to the administrative burden imposed. When measurement substitutes for meaning, systems become efficient at recording activity while remaining blind to whether that activity is useful.

Professional culture view:
Medicine was once a culture of mentorship, critique, and shared responsibility for standards. When external compliance regimes displace internal professional dialogue, doctors stop correcting one another and start protecting themselves from the regulator instead. The profession becomes quieter, more risk-averse, and less honest about uncertainty. That silence is not safety; it is fear management.

Public trust view:
Patients benefit when doctors feel able to speak openly about limits, uncertainty, and errors. A climate in which every documented reflection is potentially discoverable in a future complaint teaches clinicians to write defensively, minimise disclosure, and avoid candour. Over time, the public receives less truth, not more — even though the regulatory system claims to exist in the name of transparency.

Cynical aside:
When the regulator becomes the audience for doctors’ thinking, patients stop being the audience for doctors’ care.