Welcome! COC members are appointed based on their expertise so CONGRATULATIONS on your appointment!
As a member of the COC, you have the opportunity to have a major impact on the profession and patient care. You represent the profession in making the best decisions for training future practiioners and influencing practice and services through the utilization of peer-reviewed standards.
This program will answer some of the main questions new COC members often have. In addition, the second part of the orientation is a webinar that will be presented on Wednesday, July 25 at 2:00 p.m. eastern time. It will cover more of the logistics of what is involved, such as how to prepare for meetings and what happens at the meetings. For now, check out the new COC member FAQs that follow.
The COC consists of 20 members. Two of these members are non-voting: the ASHP Board of Directors (BOD) liaison (past president of ASHP) and the Director, Accreditation Services Division (ASD), who serves as the COC secretary. There are six voting members whose appointments come from pharmacy partner organizations. Each partner organization is dedicated to advancing pharmacy training and provides names for selection for a dedicated position from the organization. Each organization has one position on the COC. These include:
American Pharmacists Association (APhA)
Academy of Managed Care Pharmacy (AMCP)
American College of Clinical Pharmacy (ACCP)
American Association of Colleges of Pharmacy (AACP)
Pharmacy technical educators (must be a pharmacist)
A PGY2 pharmacy resident.
In addition, there are two voting public members. The remaining ten voting members are based on having representatives from PGY1 and PGY2 programs.
Non-commission attendees at the meeting include: ASHP Accreditation Services Division (ASD) staff, as well as contract surveyors, and invited guests from some professional pharmacy organizations that have interests in pharmacy residency programs and pharmacy technician training programs (e.g., APhA, ACCP, AMCP, AACP, ACPE, etc.) also attend the meetings and may participate in open discussions, but do not vote.
Lead surveyors (ASHP accreditation services staff and contract surveyors) are present to answer any questions you may have about a program that is being reviewed at the Commission meeting.
These are the activities that will require your time as a COC member:
- Two COC meetings per year, held in March and August. The meetings are three days each and you'll need preparation time plus travel time. Some days are on the weekend to reduce time away from your work place.
- The National Residency Preceptors Conference (NRPC), which is held every other year on even years (e.g., 2012, 2014) for three days.
- The Midyear Clinical Meeting. COC members attend townhalls that are held during the meeting. In addition, we register you for the RLS workshop as an observer and practitioner surveyor training as a participant.
- COC members are asked to go on a minimum of four surveys per year as a guest surveyor (except the resident member, who attends one as an observer). The practitioner surveyor training will prepare you for this experience. ASHP covers your expenses to participate in surveys, COC meetings and NRPC. If you are involved with a COC meeting or townhall at the Midyear, the registration fee for the Midyear is waived for you.
- Altogether you may be away from your work place approximately 25 days per year.
- In addition, serving on the COC requires a thorough understanding of the accreditation standards. It is recommended that you review them before each meeting: http://www.ashp.org/menu/Accreditation/ResidencyAccreditation.aspx. Click on "Regulations and Standards."
The Commission develops standards, surveys pharmacy residency programs and technician training programs against the standards and recommends length of accreditation. The ASHP Board of Directors approves all recommendations, as is their fiduciary responsibility. ASHP assumes all liability for actions taken by the Commission on Credentialing.
At your first August meeting your role is mostly observation so you can become more comfortable with how the commission works. You are welcome to ask questions as well as participate in discussions. However, you will not be able to vote at this meeting.
Appointments to the Commission are calendar year appointments (even though ASHP's year is June - May). You will receive a yearly reappointment letter each Spring. However, the initial intent is that you will serve on the Commission for a 3-year time period.
Being on the Commission increases your awareness of emerging issues in accreditation that will have an impact on residencies and technician training programs. The Commission accredits both residencies and technician training programs. You will be expected to vote on both types of programs.
It is important as you participate in COC activities that you declare any conflicts of interest. If your program is being reviewed you should not be present for the discussion. For other programs, even if there may be a perceived conflict you should abstain from voting and discussion about that program. You may be asked to discuss issues. However, your conflict should be clear to the Commission.
In order for the Commission to be able to accomplish all its work, review of programs is divided into four subgroups. You will be assigned to one of the groups and will be responsible for reviewing the programs assigned to your group. Your group will be making recommendations on length of accreditation to the full Commission on your programs. Discussions about progress revolve around trying to be consistent and fair between programs. As mentioned previously, be sure to declare any conflicts of interest before discussing a program you may have a conflict with.
In addition to program review groups, there are other small groups that meet during COC meetings, including a Standards Committee, a group that meets to discuss technician issues and miscellaneous other groups as topics present themselves.
The COC provides a forum to have professional, open dialogue that seeks to improve training for pharmacists and technicians to improve the care provided by pharmacists.
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Let's review the real meaning of accreditation. Accreditation is a voluntary process in which a profession engages in self-regulation. It's purpose is to improve services and protect the public. Here is the formal definition: "the act of granting approval to a postgraduate residency program after the program has met set requirements and has been reviewed and evaluated through an official process (document review, site survey, review and evaluation by the Commission on Credentialing)."
Making accreditation decisions involves many challenges, such as answering the question, "What proves a standard has been met?" In addition, we contantly must strive for consistency among surveyors and for transparency so that programs can understand how we evaluate their programs.
As accreditors, we get our share of criticism. These often include that we are too "ivory tower," too rigid, our standards are too complex and that there is excessive focus on process vs outcomes. Programs must see the value of accreditation to undertake the process and as a COC member you will have opportunities to help programs appreciate that the effort is worth the benefits.
Accreditation is an important process that can make a real difference by fostering improvement to programs and the practice of pharmacy in general.
Pre-Candidate: The status that may be granted to a pharmacy residency program that has submitted a completed application indicating intent to seek "candidate" status. Programs may be in a pre-candidate status for no more than fifteen months. Purposes of this status include assisting the program in recruiting a resident through participation in the Resident Matching Program, posting their information on the ASHP online residency directory and allowing them to start to build evaluation process in Resitrak (online system provided to any residency in the accreditation process). Programs in this status must submit an application for accreditation when training of the first resident begins.
Candidate: The status granted to a pharmacy residency program that has a resident(s) in training, has applied to ASHP for accreditation, and is awaiting the official site survey, and review and evaluation by the Commission on Credentialing. A survey does not occur until after 9 months has elapsed since resident training began. As soon as the program receives ASHP-accredited status, its status is retroactive to the date of receipt of application, and includes those residents who were pursuing the residency at the time application for accreditation was submitted.
Preliminary Accreditation: After the initial site survey, the survey team may recommend "preliminary accreditation" for the program if the team concurs that the program has met a substantial portion of the applicable standard(s). A letter from ASHP will be sent to the program if preliminary accreditation is granted. Official accreditation status does not occur until after a Commission on Credentialing meeting and the ASHP Board of Directors reviews the Commission's recommendations.
Accredited: The COC will not recommend accreditation of a program until it has been in operation for one year and has had at least one graduate. If accreditation is granted, it shall be retroactive to the date on which ASHP's Accreditation Services Division, received a valid and complete application for candidate status. Failure of the program to submit reports as requested may result in accreditation being withheld. A program granted accreditation will continue in an accredited status until the Commission on Credentialing recommends further action. A certificate of accreditation will be issued to a program that has become accredited.
ASHP regards evaluation of accredited residency programs as a continuous process; accordingly, the Commission on Credentialing (COC) shall request that directors of accredited programs submit periodic written status reports to assist the COC in evaluating the continued conformance of individual programs to the applicable accreditation standard(s). Written reports shall be required from program directors at least every 3 years. To maintain accreditation, programs must comply with all requests from ASHP for written reports.
Accredited programs will be re-examined by site survey about every 6 years. ASHP may accredit the program for a period not to exceed 6 years, award conditional accreditation, or withhold accreditation. The Commission on Credentialing, on behalf of ASHP, may request written reports at any time between the 6-year site survey intervals (for example, 1 year, 3 years or 6 years). Typically, if accreditation is granted for less than 6 years, only a written report is required for the Commission to take further action (rather than a site visit). Failure of the program to submit reports as requested may result in reaccreditation being delayed or withheld, conditional accreditation, or withdrawal of accreditation.
Conditional Accreditation: This is the status awarded by ASHP to a program that is not in substantial compliance with the applicable accreditation standard, as usually evidenced by the degree of severity of non-compliance and/or partial compliance findings. Programs must remedy identified problem areas and may undergo a subsequent on-site survey. If cited areas are not resolved, the program will lose accreditation.
If a program is not accredited at the March COC, ASHP will pull programs from the resident matching program so that a candidate is not matched with an unaccredited program.
Match the definitions with the type of accreditation:
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There are seven principles in the accreditation standards, listed below:
Principle 1: Qualifications of the Resident
The resident will be a pharmacist committed to attaining professional competence beyond entry-level practice.
Principle 2: Obligations of the Program to the Resident
The pharmacy residency program will provide an exemplary environment conducive to resident learning.
Principle 3: Obligations of the Resident to the Program
The resident will be committed to attaining the program's educational goals and objectives and will support the organization's mission and values.
Principle 4: Requirements for the Design and Conduct of the Residency Program
The resident's training will be designed, conducted, and evaluated using a systems-based approach.
Principle 5: Qualifications of the Residency Program Director (RPD) and Preceptors
The residency program director (RPD) and preceptors will be professionally and educationally qualified pharmacists who are committed to providing effective training of residents.
Principle 6: Minimum Requirements of the Site Conducting the Residency Program
The organization conducting the residency will meet accreditation standards, regulatory requirements, and other nationally applicable standards and will have sufficient resources to achieve the purposes of the residency program.
Principle 7: Qualifications of the Pharmacy
The pharmacy will be organized effectively and will deliver comprehensive, safe, and effective services.
When reviewing programs, you'll find that some parts of the standards are cited more frequently than others. The most frequent findings are reported after each meeting and it will be helpful for you to be aware of them. Here are the most recent frequent findings for PGY1 programs. (Note: "CF" indicates that the item is a "critical factor," which is given more weight in determining ratings.)
March 2012 Top Areas of Partial Compliance with PGY1 Pharmacy Residencies (n=68)
Residency Program Issues:
88% Not all preceptors have made adequate contributions to the total body of pharmacy knowledge & meet 4/7 preceptor criteria- CF
83% Preceptors have not adequately developed & documented descriptions of learning experiences – CF
72% Preceptors development is inadequate/ RPD does not have a plan for improving the quality of preceptors' instruction
62% Preceptors do not adequately apply clinical teaching roles or provide criteria based feedback – CF
62% Preceptors do not complete all aspects of the assessment plan – CF
60% Customized plans for residents are not documented/implemented/updated adequately - CF
Service Issues at the site:
53% Services are not of a scope and quality commensurate with identified patient needs.
44% Pharmacists do not prospectively help develop individualized patient treatment plans – CF
41% Automated medication system & software do not support a safe medication use system – CF
38% Unit dose is not complete & does not extend to all patient care areas - CF
34% Pharmacists do not adequately design and implement medication therapy monitoring plans for patients-CF
Here are the most recent frequent findings for PGY2 programs.
March 2012 Top Areas of Partial Compliance with PGY2 Pharmacy Residencies (n=46)
Residency Program Issues:
87% Preceptors do not ensure all aspects of the assessment plan are completed (e.g. self-evaluation)
80% Preceptors have not adequately developed and documented descriptions of learning experiences - CF
69% Customized plans for residents are not documented/implemented/updated adequately – CF
63% Preceptors development is inadequate/ RPD does not have a plan for improving the quality of preceptors' instruction
41% Not all preceptors have made adequate contributions to the total body of pharmacy knowledge & meet 4/7 preceptor criteria- CF
-Service Issues at the site:
54% Pharmacists do not prospectively develop individualized patient treatment plans - CF
54% Pharmacy does not ensure a safe and effective controlled floor stock system.
54% Facilities do not promote safe and efficient work environment
43% Services are not of a scope and quality commensurate with identified patient needs.
COC meetings operate under a modified form of Roberts Rules.
Confidentiality surrounding meetings is important. As a COC member, you can discuss COC issues when we are together - but not when you leave. It is crucial that sites should only hear about COC decisions directly through ASHP correspondence.
Remember that all conflicts of interest must be declared at meetings before discussions begin.
As a COC member, you will be recognized by wearing COC ribbons at the Midyear and you will have special seating at the Midyear townhalls.
On the lighter side, it is a COC tradition that on Saturday of the August meeting, we recognize outgoing members and share "stories" of Commission business (and fun) experiences with that member during their time on the Commission.
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Demand for residency training and growth of number of programs: In 2012 over 1,200 applicants were not able to match as there were not enough PGY1 positions. Growth keeps occuring but is not keeping pace with the demand. As programs continue to grow, the COC needs to be able to address this growth in programs and increased responsibility.
Duty hours: The COC will be implementing in 2013 pharmacy-specific duty hours which were approved by the COC in March 2012.
Multisite: Programs must determine if they meet the criteria for being a multisite program and, if so, must meet additional requirements, such as site coordinators, etc. Multiple site programs continue to develop resulting in challenging surveys. This policy was approved in August of 2010.
Critical Factors: Critical factors are elements of the standards that have been determined to be very important and are, therefore, given more weight in accreditation decisions. Developing and using the critical factors are another consistency strategy adopted by the COC.
Consistency Criteria: Programs talk to each other and compare notes. If they see differences in how programs are evaluated, it brings up issues of consistency and fairness. As accreditors, we strive for maximum consistency in the criteria we use to determine accreditation and length of accreditation (1, 3, or 6 years). The critical factors and consistency criteria are a major tools in this effort. The consistency criteria continue to be reviewed and revised.
Transparency: Programs want to know by what criteria they are being evaluated. To increase transparency, our goal is to publish the critical factors and consistency criteria after a series of final reviews by the lead surveyors and COC.
New Standards: A draft of a new standard for pharmacy technician education and training programs has been developed and is in the process of review and comment. The goal is approval in 2013. In addition, work is beginning on an update to the residency standards. The standards will be revised with streamlining in mind due to the initiative to increase residency capacity.
Board Certification: For newly approved BPS pharmacy specialties, this requirement will be enforced on the first day of January two years after the first offering of the certification examiniation. (Note: This will require PGY2 RPDs in Ambulatory Care to become ambulatory care board certified by January 1. 2014.) Within two years after BPS approves a new specialty, RPDs will need to become Board certified.
The tone of a survey is meant to be collegial - colleagues helping colleagues. Be positive, supportive and provide suggestions. Also, remember that you are a visitor to the organization you are surveying and act accordingly. Remember that the most important goal is to improve training.
A word of caution: Avoid talking too much about "my place" - how you do things where you work. Remember the goal is to help the program meet the standards. They can choose how to do so.
You will receive a handbook on basics for surveyors. It will fill you in on more details on express reports, survey etiquette and other important information.
Last Check Up!
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We are excited to have you as a member of the COC!
We hope this program has been helpful. There's more to learn: Don't forget the webinar on Wednesday, July 25, 2:00 - 3:00 p.m., as well as the live orientation with Janet Teeters, Director, Accreditation Services Division preceding the COC meeting. This will be a dinner meeting on the evening of August 12, 2012. Time and location coming soon.
Bring your questions!
See you August 12 in Bethesda!
