not meet the definitions put forward by the professional standards authority, the department of health and social care, and others. that the process did not amount to revalidation was repeatedly conveyed to the cftp advisory group. it was also noted in the "cftp interim evaluation report" produced for the gphc by solutions for public health that the gphc's framework did not amount to revalidation, but this explanation was removed and was not present in the final report published publicly by the gphc. the gphc did not advise of the significance of the change in name, in its public consultation. the above details were not included in the consultation documents and were not shared by the gphc with the wider audience at its engagement event in london on 16 may 2017. likelihood of a registrant’s records being checked the gphc checks the records of 1 in 40 registrants each year. this means that a registrant could go through his/her career of many years without ever having his/her records checked by the gphc or anyone else. if the records are deemed unsatisfactory, he/she could be given two further chances to put this right. such a framework is not capable of robust early detection of deficient practice. this was a key expectation of the gmc’s revalidation framework following the shipman inquiry. claims regarding the naming of the process the gphc asserted that the change from cftp to "revalidation" was made due to concerns over the negative connotations associated with the term “fitness to practise”. this reasoning is implausible and likely dishonest (a behaviour which the gphc says damages public confidence and undermines integrity). the gphc has not renamed its fitness to practise committee or fitness to practise declarations; stopped requiring registrants to complete a “fitness to practise” declaration annually; or taken any other discernible steps to avoid the use of this term. the term "fitness to practise" is used repeatedly on its website and in its policies. it is also a term referred to extensively in the pharmacy order 2010, the act of legislation which gives the gphc its powers. it is also used repeatedly in the gphc’s “revalidation framework” document. the framework does not meet the gphc’s own definition of revalidation. at a meeting in november 2013, the gphc’s governing council explored a means of implementing a framework for assuring continuing fitness to practise. the meeting papers stated: “the terms ‘revalidation’ and ‘continuing fitness to practise’ are subtly different. in the gphc’s view ‘revalidation’ implies a fixed point assessment whereas ‘continuing fitness to practise’ suggests a review of practice viewed on a continuum. the latter better describes the thinking outlined in this proposal, so that term will be used from now on.” in 2014, a page was created on the gphc’s website explaining why it was looking to implement a cftp framework and not revalidation. on that page, under the heading “what happened to revalidation?”, it stated: “we have been working on the introduction of new arrangements for assuring continuing fitness to practise for some time, and initially this was called ‘revalidation’. we have decided not to use the word ‘revalidation’ anymore because it has a very specific meaning relating to a particular method of assuring continuing fitness to practise.” as at 5 february 2017, this had been changed to “we have been working on the introduction of new arrangements for further assuring standards for safe and effective pharmacy practice for some time, and initially this was called ‘revalidation’. we have decided not to use this term anymore because it was not well understood.” the webpage has since been removed from the gphc’s website. in the version of the evaluation report of the cftp pilot published on the gphc’s website in february 2017, it explains that the general medical council (gmc) and nursing and midwifery council (nmc) revalidation models include a fixed-point assessment of the registrant’s fitness to practise. the report confirms the gphc’s continued commitment at that point not to develop a revalidation model (which it had earlier said implies a fixed-point assessment): “the gphc’s direction of travel is to move away from a process of a fixed point assessment for assurance… given the psa guidance on the cftp model being proportionate to risk, this makes sense.” that the framework does not amount to revalidation was acknowledged by the gphc and other pharmacy stakeholders at a cftp advisory group meeting on 11 october 2017. the advisory group requested that the gphc’s governing council be asked, at its meeting the following day, to change the name of the framework from “revalidation” to an alternative which accurately reflects its nature. the advisory group was subsequently informed by email on 1 november 2017 that the council had decided to retain the name “because of its relative ease of understanding and they felt we needed to do more to explain the type of assurance that it provided to the public”. there is no record in the minutes of the council’s meeting of 12 october 2017 of this being discussed, though revalidation was discussed. effects of improperly calling its process “revalidation” calling the process, inaccurately, "revalidation", could have at least the following effects: it creates the impression that the gphc's approach to regulation, as a whole, is more robust than it is. the gphc misleads the public and others as to the nature of the process, and that the assurance in respect of public protection is greater than the process actually affords. this occurs each time that it uses the term, including through its continued use. in order to register, registrants must submit a false declaration each year, that they have undertaken revalidation, when in fact they have not. in using the term, pharmacy organisations and registrants join the gphc, unwittingly or otherwise, in misleading the public and others as to the nature of the process. it may de-professionalize the pharmacy profession. if it is accepted that pharmacists can “revalidate” annually simply by creating six records with very little chance that they will be reviewed by anyone, let alone the gphc, then it can be argued that little public safety assurance is required in the regulation of pharmacists. as such, pharmacists pose little risk to the public, and the role is straightforward. reduced confidence in revalidation frameworks provided by other regulators, if public perception of the meaning of revalidation alters to accommodate the gphc's lower standards. it may suggest that the regulatory practise of pharmacists and pharmacy technicians is more advanced than it is in reality, misleading the public as to the confidence it can have in one or both groups. this may then be used to advance government policy objectives in respect of the use of the groups (or one group instead of another) in the health service. pharmacist registration assessment the gphc exam or gphc registration assessment exam was set by the royal pharmaceutical society of great britain, but since september 2010 has been the responsibility of the gphc. the examination takes place on two occasions each year: the summer (the last friday in june) and the autumn (the last friday in september). candidates are required to pass it in order to register with the gphc and to be able to practise as pharmacists. it is taken by those who have completed their university studies and gained an mpharm degree, and completed a year of pre-registration training. in explaining the importance of the pharmacist registration assessment, the gphc said: "it is a national standard... if you talk to the public and you talk to patients, that is something that genuinely matters - that they can be reassured that all of the good work that goes on in schools of pharmacy and in pre-registration training has at the end a moment where we can say, as a national regulator, that a standard has been met. there are very few objective ways of doing it, but an examination is one of those... there has been an exam since 1993... we've thought about it long and hard and we've concluded that an examination as a national standard to demonstrate to the public that a standard has been met is really quite crucial... it is fair. everybody gets the same one. you cannot say that your examination was harder than somebody else's, or easier, and that's again something that is genuinely reassuring. there are so many assessments over the course of four years in a school of pharmacy, it's quite hard to compare them. we're comfortable with the fact that the learning outcomes are met across the nations but it's very hard to say that at any one moment - because it's not true - that everybody had the same assessment, and this is the only moment currently where that is the case. that's an important reassurance for the public. the other signoff in pre-registration is a tutor signoff. and those of you who know anything about assessment will know that a one-to-one signoff is one of the less reliable forms of assessment. it's quite rich because there's a lot of interaction involved, you know the person well, but that in itself can cloud your judgement, so on the scale of reliability and validity, it might be quite valid but it's not necessarily that reliable. that's why as a general principle you never use one kind of assessment in a high-stakes year of training, so that's another reason it's there. and there is another aspect that we cannot ignore. despite the best efforts of schools of pharmacy and pre-registration training, there are individuals who get to the exam and fail it dismally... who get zero in calculations, for example, or 30% or 20%. so clearly there is a need for that final backstop for those individuals who for whatever reason have made it that far. so there is a genuine public protection reason for having the exam, so that's our rationale for keeping it." potential collusion / failure of integrity of the pharmacist registration exam in march 2021 during the covid-19 lockdown, graduates (who had passed the mpharm exam and completed a year of pre-registration training) were allowed to practice as "provisionally registered pharmacists" from the 1st of august 2020, without sitting a registration exam to verify their competence or fitness to practise. 2600 candidates, including many provisionally registered pharmacists, sat exams on either the 17th or 18 march 2021, in order to register with the gphc as pharmacists. following the assessment on the 18th of march, there were reports on social media that many questions on the 18th of march sitting were the same as those which appeared on the 17th. some candidates who sat the exam on the 17th had reportedly shared what questions were on the exam with some of those sitting it on the 18th, in chat groups used by candidates. the reports included that at least 30 questions were similar, "both papers were nearly identical", the "majority" of questions were the same and "at least 50% of the questions came back". the gphc responded, stating "there have been some concerns raised by candidates that the papers for each sitting were the same or very similar, and that this could have an impact on which candidates pass the assessment." it stated that "the majority of questions were different, with some questions appearing similar but having appropriately different answers" but acknowledged that "a number of questions were the same". the gphc has not stated that it will conduct any investigation into the reports, or that it will discount the questions that were repeated on the 18th. it appears that all candidates who sat the exam on the 18th were eligible to register as pharmacists, without any investigation or corrective action taking place. a freedom of information request was submitted for the number of questions which appeared on both exams. the gphc initially refused to provide the information. however, following a decision from the information commissioner's office, it stated: "we held a computer-based registration assessment on the 17 march 2021 and again on the 18 march 2021. on each day, there was a 40-question part 1 paper and a 120-question part 2 paper and the papers were different. in total, 14 identical questions were used in both part 1 papers and 62 identical questions were used in both part 2 papers." july 2021 pharmacist