Fay Goddard: Three steps to filling the gap

To read or not to read – that is the question many advisers are asking in relation to qualification gap-fill. For those not yet facing this part of the RDR challenge, gap-fill means bridging any gaps in learning outcomes that have not been covered through examination. With thousands of advisers already holding a level four (or above) qualification, undertaking structured CPD to plug their personal gaps is top priority.

We know this by the numbers attending PFS gap-fill sessions that we are running around the country, where the majority of regional gap-fill events have reached maximum capacity.

However, following publication of the FSA’s policy statement PS11/01, there is one aspect that is causing some consternation and debate.

To quote the FSA: “Gap-fill should be structured, rather than unstructured, CPD. However, if structured CPD is not available to fill the gap identified, then an adviser may complete the gap by reading suitable material. We expect that such cases would be for a minority of gaps, if any.”

Before jumping to the conclusion that this message means that “reading” is automatically unstructured, we need to be clear about the difference between structured and unstructured CPD. The Chartered Institute of Personnel & Development has broadly defined structured CPD as following a three-step process:

Training needs analysis: identifying gaps in competence, knowledge, etc, giving rise to desirable future learning outcomes

Learning interventions: activities, regardless of type or medium, undertaken to address the required learning outcomes specifically

Review: establishing that the intervention did its job, and confirming that the learning outcome has been achieved

Point two is particularly important as, in our view, provided the three steps are followed, reading learning material that has been created to meet a clearly defined learning outcome can meet the structured CPD definition. An individual would need to complete the third step by considering carefully whether they have fully understood the material and verifying that the activity has met the learning outcome.

This is a very different proposition to reading topical articles or even technical material that may be very useful, but not designed to meet specific learning needs. So there are two types of reading.

It is on the former basis that the CII has built its gap-fill tool, so we are confident that provided advisers undertake the second and third steps diligently they will have met the requirement. It is also worth noting the ultimate decision regarding verification of whether an adviser has fulfilled the requirement will be down to the FSA accredited body that an adviser selects to provide their statement of professional standing. The CII, along with other bodies, has applied for accredited body status but the FSA will not be publishing the list of successful applicants until later this year.

Meanwhile, my advice to all of you with gap-fill obligations is to take advantage of all the support available that is designed to meet clearly specified gaps, whether it is attending events, accessing on-line training or correctly utilising specified learning material.

Fay Goddard is chief executive of the Personal Finance Society