The pandemic caused by COVID-19 and the beginning of Russia’s full-scale invasion of Ukraine have had an impact on the activities of both public and private institutions. More attention has been given to developing digital technologies, hybrid work formats, education, etc.
These changes have also affected the continuous professional development (CPD) system for healthcare workers. The Ministry of Health has set the goal of improving the approach to CPD and the functioning of the electronic CPD system for medical professionals. On September 29 of this year, the government adopted Resolution No. 1036, introducing a series of key changes that affect both healthcare professionals and CPD providers, as well as the state itself.
What has changed in the CPD system?
From now on, CPD activities are not only related to the medical field but also to rehabilitation, pharmaceutical, and medical services that go beyond just medical and rehabilitation assistance.
The forms of conducting CPD activities have also changed: the concept of an electronic training course and peer groups have been introduced as forms of self-education.
Electronic training courses have been present in our lives for a long time; however, in the context of CPD, they have now become legally possible.
At the same time, introducing peer groups is a significant achievement because the government recognizes the value of healthcare workers learning through exchanging experience and knowledge. A certificate from the healthcare institution that organized them, signed by its manager, will serve as confirmation of participation in such events.
What alterations are in store for public agencies?
The government has assigned roles in managing the electronic CPD system, whose function is to process data and other information related to the CPD of healthcare workers. This has allowed for the allocation of responsibilities among key entities.
The Ministry of Health is designated as the owner of the electronic CPD system and the custodian and holder of data within it. The administrator of the electronic system is the Testing Board for Professional Competence Assessment of Higher Education Trainees in Medicine and Pharmacy (hereinafter referred to as the Testing Board). The technical administrator is the SOE “Electronic Health.”
Furthermore, the interaction mechanism between the electronic CPD system and other electronic resources has been improved (including the Unified State Register of Legal Entities, Individual Entrepreneurs, and Public Associations, the Unified State Electronic Education Database, and the electronic healthcare system). This enhancement ensures that data does not circulate chaotically. The information exchange between the electronic CPD system and other electronic resources will be carried out through the “Trembita” system and based on agreements on information interaction between the Ministry of Health and the owner of another resource.
What has changed for medical professionals?
Starting from January 1, 2024, CPD will become mandatory for all healthcare sector employees falling under the professions listed in the following sections of the Qualification Characteristics Directory:
- Managers (those with an education in the field of knowledge 22, “Healthcare”).
- Professionals (including pharmacists).
- Specialists (including medical nurses).
This innovation applies to employees working in healthcare institutions, educational institutions specializing in healthcare, as well as in trade unions and public associations within the healthcare sector.
The government has also clarified when healthcare workers are obligated to undergo CPD: for most specialties, this obligation arises upon receiving a document of higher or specialized secondary education and a certificate as a specialist doctor, pharmacist, or specialist pharmacist.
Another innovation for healthcare sector employees is the opportunity to challenge the actions of the CPD provider related to organizing or conducting CPD activities using a specific procedure.
What has changed for CPD providers?
For them, the government has established certain additional obligations:
- CPD providers organizing non-formal education events will be required to officially approve educational programs in addition to the existing mandatory event cards.
- CPD providers must publish information on their official website about events for which they award CPD points. However, participant registration for such events can only begin after the Testing Board has entered information about the event into the electronic CPD system.
Government agencies that wish to become or are already CPD providers do not need to register as CPD providers or enter information about their events into the electronic system. The same rule applies to healthcare institutions that conduct CPD events in a peer group format.
Some changes are also introduced for legal entities planning to become CPD providers. They will be required to provide copies of certain documents (regarding academic integrity, methodology for assessing acquired knowledge, etc.) during the registration as CPD providers. Additionally, they will need to provide information about any legal relationships with manufacturers, sellers, or importers of rehabilitation aids.
The registration process for CPD providers has also been clarified. Now, the Testing Board has the authority to reject the registration of a legal entity as a CPD provider and provide a 5-day period for rectifying any deficiencies in the registration documents.
Does the government’s decision have drawbacks?
Undoubtedly, the changes in the CPD system are mostly positive, although they may face resistance from healthcare professionals and CPD providers, as newness and associated uncertainties often provoke negative reactions.
Whether individual entrepreneurs are required to undergo the CPD remains unclear: they are not considered healthcare institutions but engage in medical practice and may employ staff. The same applies to rehabilitation specialists who can soon practice medicine independently. Therefore, not all healthcare workers are employed in medical institutions. On the other hand, individual entrepreneurs already undergo the CPD, so this ambiguity needs to be addressed in the upcoming amendments to the resolution.
The requirement for individuals with professional or higher medical and pharmaceutical education who work in trade unions and public associations in the healthcare sector to undergo the CPD is also not entirely clear. In practice, such individuals are involved in administrative activities and do not participate in patient care. However, if they work in such organizations concurrently, and their primary place of work is a healthcare institution, they are already included in the CPD system.
Furthermore, the document lacks consistency in its terminology. The concept of evidence-based medicine has been replaced with two different terms – “principles of evidence-based medicine/evidence-based rehabilitation” and “principles of evidence-based medical/pharmaceutical/rehabilitation practice.” This inconsistency also extends to the concept of assistive devices for rehabilitation, which are mentioned in some places as “assistive devices (assistive technologies),” even though assistive technologies encompass a broader category. Inconsistent terminology may lead to varying interpretations by those implementing the new legislative provisions.
Another drawback worth noting is the lack of a clear list of grounds for refusing registration as a CPD provider. The government’s commented decision allows the Testing Board to refuse registration, but it does not clearly list the reasons for such refusal. This enables the Testing Board to arbitrarily determine when to reject potential CPD providers and when not to.
Another questionable change is the provision that allows government agencies not to register as CPD providers and not to enter information about their events into the electronic CPD system. This implies that the government acknowledges that CPD activities developed by government agencies are of high quality by default. However, exempting government agencies from the obligation to register in the electronic CPD system raises several questions. This approach could create inconvenience for healthcare professionals and certification committees. Personal educational portfolios of healthcare workers may become incomplete, requiring new procedures for entering and verifying such certificates in the electronic CPD system. There is also a risk of creating separate registries of CPD programs within government agencies.
The resolution’s previous version had envisaged the introduction of CPD for pharmacists and nurses in 2023. However, this did not happen due to Russia’s military aggression. Implementing mandatory CPD for all healthcare sector employees from 2024 will only be possible after approving additional regulatory acts governing these processes.
Therefore, the medical community eagerly awaits leadership and timely communication from the Ministry of Health while developing the above documents to ensure the new changes are fully implemented. The effectiveness of any changes in the CPD system will be measured by the results of their implementation.
The authors do not work for, consult to, own shares in or receive funding from any company or organization that would benefit from this article, and have no relevant affiliations