About the standard
In December 2020, the Alberta government passed Bill 46: Health Statutes Amendment Act, 2022 (No. 2). This bill requires CPSA to move our existing Continuing Competence program from the Health Professions Act (HPA) to a CPSA standard of practice. This change gives regulatory colleges, including CPSA, greater flexibility to make adjustments to their standards as needed.
In order to fulfill our legislative duty, CPSA has started working on a draft standard for our existing Continuing Competence program that:
- follows a similar format to the existing regulation;
- depicts current requirements for regulated members to participate in CPSA’s Continuing Competence program (no changes to requirements have been made);
- includes all elements that are required to be enforceable;
- aligns with the Alberta Health Framework for Continuing Competence Standards of Practice; and
- will be supported by the Continuing Competence Program Manual, a document recommended by Alberta Health.
CPSA is currently in the process of developing the Program Manual, which will be available when the Continuing Competence standard takes effect in spring 2023.
The draft standard was approved by CPSA Council for consultation at their May meeting.
Your opinion matters
Changes to CPSA’s Standards of Practice impact your day-to-day practice. Your feedback is important to us, but please note CPSA has a limited ability to incorporate additional changes on the Continuing Competence standard as this requirement is driven by legislation. The new standard is anticipated to come into effect in spring 2023.
Feedback may be provided via survey, email, or the comment form below. Consultation closes on July 6, 2022.
Once amendments are finalized and approved by CPSA Council, members will be notified via direct email and The Messenger newsletter. The new standard is anticipated to come into effect in spring 2023.
We respect your privacy
All feedback is subject to CPSA’s Privacy Statement. CPSA reviews all comments before publication to ensure there is no offensive language, personal attacks or unsubstantiated allegations.
CPSA members, partner organizations, other health care professionals and Albertans are invited to provide feedback from June 6 to July 6, 2022. Council will consider non-nominal feedback when approving final amendments to the standard this spring.
Other feedback on this standard
The document is challenging to read in the absence of reading the references and the listed companion document. My obligations as a regulated member regarding the 3 listed areas are not completely clear to me having read the document. Although I am familiar with the CPD requirements I am not familiar with the general assessment and competency assessment requirements and not sure if these are regular annual obligations as a member or if these are areas focused on members with an identified difficulty?
Members are advised that "Details on how to fulfill the requirements below can be found in the Continuing Competence Program Manual." This Continuing Competence Manual seems to be a key companion document but I am unable to find this on the CPSA website. If it is a part of the standard it will need to be easily available to regulated members as an issue of knowing and following the standard. It is challenging to review this standard without reference to this companion document and I suggest linking it in the request for comments.
In general I do not favour reference to secondary documents in standards of practice. There is a well established and publicized process for regulated members to be aware of any changes to the standards of practice, but a secondary document could be changed or updated, changing the obligations of members, without members being aware. Although this would allow the college to be more nimble, for example requiring CPD on a specific and important emerging topic the risk of inadvertent member non-compliance is, in my opinion, too great. (I also think that the recent use of linking an activity to the permit renewal likely means that this is not required.)
Reference is also made to the CFPC Mainpro requirements document. A weakness of this CFPC document is the very vague way that it addresses leaves of absence from practice on an individual and ad hoc basis (contact the CFPC to discuss). I think that this can disadvantage individuals who are already potentially vulnerable and would prefer to see the interface of CPD and leave of absence (e.g. parental leave, illness and caregiver leave) explicitly addressed in the CPSA document.
These comments are intended to be constructive and to assist the CPSA in the creation of a robust and easy to understand standard of practice.
Thank you for taking the time to review the draft standard and share your feedback with us, Dr. Johnston.
It’s absolutely challenging to comment when a fundamental piece, like the program manual, isn’t available. Unfortunately, timelines require CPSA to develop the standard for consultation and approval, then focus on the manual. I can confirm it will contain current program rules (e.g., Continuous Professional Development, Physician Competence Assessment), as well as clarifying what to expect (e.g., General Assessment) and will function similarly to Advice to the Profession documents.
Referring to a secondary document can certainly be challenging, but it is often preferential than combing documents like these that could result in a 50-page standard. We do this regularly when referring to other standards within a standard of practice to ensure consistency if one should be updated out of sequence with another.
Your feedback on the CFPC document has been highlighted for the Continuing Competence Committee and Executive Team’s consideration.
Standards of Practice Advisor
Whilst introducing new controls on the profession might seem like an improvement there are going to be unintended consequences. Having seen this developed in other jurisdictions it is predictable that some doctors will leave or retire early.
This work will not be remunerated and the cost borne by the physician. The impact on an already beleaguered profession’s moral will not be positive.
In addition this extra checking of competence implies a profound distrust and undermines the doctor’s autonomy.
In assessing this proposal secondary documents are mentioned but their content is not available. Does this imply that standards could be created without our knowledge?
I have concerns that these proposed changed will be detrimental to recruitment and retention of doctors in Alberta.
The law has to be applied in a way that minimally impacts the profession. I would like to see how the college has interpreted the law and it’s justifications.
Thank you for taking the time to review the draft standard and share your feedback with us, Dr. Zapf.
I’m sorry it was not clearer on the consultation page that this is not a change from the current process/expectation: CPSA has been responsible for physician competence under Part 3 of the Health Professions Act (page 50) since 2000.
If you have any other questions, please let me know.
Standards of Practice Advisor
The PPIP program Should remain volentary. I feel especially for smaller community based practices that does not have multiple staff members available to drive some of these tasks- it will add more stress and frustration than benefit at present- and eventually impact time spend in clinical practise in an extremely overloaded medicine setting currently. With virtual medicine , taking over community covid care , "regular " care and not to mention all the care that has " heaped " up over the last 2 years and now coming in - I find I have very very little time for anything other than clinical practise and keeping up with CPD requirments.
As laboratory physicians, QA and QC activities are a regular part of our practice and we can see the value of a physician practice improvement program. However, most of the supporting documentation is aimed towards physicians seeing patients in an office practice. While the emphasis on these physicians is understandable, lab physicians often feel that their medical practices are not acknowledged and find it difficult to apply guidelines or standards that are developed for clinicians to their lab medicine practice. It would be helpful to have further dialogue to help those physicians who do not see patients in office settings, like lab physicians and those working in diagnostic imaging, comply with the CPSA standards.