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PROBLEM-BASED LEARNING: A STRATEGIC

LEARNING SYSTEM DESIGN FOR THE EDUCATION


OF HEALTHCARE PROFESSIONALS IN THE
21ST CENTURY
Matthew Choon-Eng Gwee
Medical Education Unit and Department of Pharmacology,
Yong Loo Lin School of Medicine, National University of Singapore, Singapore.

Problem-based learning (PBL) was first implemented by McMaster University medical school in
1969 as a radical, innovative, and alternative pathway to learning in medical education, thus setting
a new educational trend. PBL has now spread widely across the globe and beyond the healthcare
disciplines, and has prevailed for almost four decades. PBL is essentially a strategic learning system
design, which combines several complementary educational principles for the delivery of instruction.
PBL is specifically aimed at enhancing and optimizing the educational outcomes of learner-centered,
collaborative, contextual, integrated, self-directed, and reflective learning. The design and delivery of
instruction in PBL involve peer teaching and learning in small groups through the social construc-
tion of knowledge using a real-life problem case to trigger the learning process. Therefore, PBL
represents a major shift in the educational paradigm from the traditional teacher-directed (teacher-
centered) instruction to student-centered (learner-centered) learning. PBL is firmly underpinned by
several educational theories, but problems are often encountered in practice that can affect learn-
ing outcomes. Educators contemplating implementing PBL in their institutions should have a
clear understanding of its basic tenets, its practice and its philosophy, as well as the issues, chal-
lenges, and opportunities associated with its implementation. Special attention should be paid to
the training and selection of PBL tutors who have a critical role in the PBL process. Furthermore, a
significant change in the mindsets of both students and teachers are required for the successful
implementation of PBL. Thus, effective training programs for students and teachers must pre-
cede its implementation. PBL is a highly resource-intensive learning strategy and the returns on
investment (i.e. the actual versus expected learning outcomes) should be carefully and critically
appraised in the decision-making process. Implementation of PBL can be a daunting task and will
require detailed and careful planning, together with a significant commitment on the part of edu-
cators given the responsibility to implement PBL in an institution. PBL can offer a more holistic,
value-added, and quality education to energize student learning in the healthcare professions in the
21st century. Successful implementation of PBL can therefore help to nurture in students the
development of desired “habits of mind, behavior, and action” to become the competent, caring, and
ethical healthcare professionals of the 21st century. Thus, PBL can contribute to the improvement
of the healthcare of a nation by healthcare professionals, but we need to do it right.

Key Words: challenges, issues, opportunities, outcomes, problem-based learning


(Kaohsiung J Med Sci 2009;25:231–9)

Address correspondence and reprint requests to: Dr Matthew C.E. Gwee, Medical Education Unit, Yong Loo Lin School
of Medicine, 10 Medical Drive Block MD 11, National University of Singapore, Singapore 117597.
E-mail: phcmgce@nus.edu.sg

Kaohsiung J Med Sci May 2009 • Vol 25 • No 5 231


© 2009 Elsevier. All rights reserved.
M.C.E. Gwee

THE DARK AGES OF MEDICAL EDUCATION educational planners responsible for this project
declared that they intended to take a radical (“fresh
Throughout the 19th century, and until about the last and new”) approach to the design and delivery of
2–3 decades of the 20th century, the design of the under- their medical curriculum to “…get away from the
graduate medical curriculum was highly discipline- standard building-block structure…from shoving a lot
specific with little cross talk across disciplines. The of content down their throats because they don’t retain
delivery of instruction was then highly teacher-directed it very long anyway. Let’s try and get them actively
(teacher-centered) and also highly lecture-based. This involved…” [3].
was the era of the instructional paradigm in which Indeed, in 1969, McMaster University Medical
the student role in the teaching/learning process was School implemented its new medical curriculum,
mainly that of a passive recipient of abundant content which set a new, radical and innovative trend, and
knowledge (or information) delivered by the teacher offered an alternative pathway for learning in medical
(“sage-in-center stage”). education. The McMaster curriculum was imple-
What then can we expect as the educational out- mented as problem-based learning (PBL), primarily aimed
comes from such a traditional educational environ- at overcoming what the educational planners per-
ment? Several major limitations [1,2] have already ceived to be the many shortcomings of the then cur-
been identified, including: rent (traditional) medical curriculum [1–3]. In fact,
• Information overload resulting from student acquisi- even after almost three decades, Boud and Feletti [4]
tion of abundant content knowledge (“…informa- still consider PBL as “…the most significant innovation
tion that taxes the memory but not the intellect.”) [1]. in education for the professions for many years. Some argue
• Development of rote-learning habits by students that it is the most important development since the move of
through MRR (memorize, recall, regurgitate)—often professional training into educational institutions.”
abetted and intensified by tests on recall of factual
content knowledge (information).
• Teaching inputs as the primary focus of instruction WHAT IS PBL?
with little attention to student learning outcomes.
• High dependency of students on teachers for their PBL is, essentially, a strategic learning system design,
learning needs, including what, how, and when to which combines several complementary educational
learn. principles for the delivery of instruction. PBL is spe-
• Inadequate attention to student acquisition of more cifically aimed at enhancing and optimizing the edu-
enduring educational process and life skills, including: cational outcomes of learner-centered, collaborative,
higher-order cognitive (intellectual) skills (critical think- contextual, integrated, self-directed, and reflective learn-
ing, reasoning, and problem-solving); and some ing. Barrows and Tamblyn [5] provided a simple
generic “soft” skills in the attitudes (affective) domain operational definition of PBL as “…the learning that
of learning (interpersonal, communication, team- results from the process of working toward the understand-
work, and leadership). ing or resolution of a problem. The problem is encountered
first in the learning process.”

THE MCMASTER UNIVERSITY INITIATIVE:


SETTING A NEW TREND IN MEDICAL PBL: WHAT ARE ITS KEY FEATURES AND
EDUCATION ITS LEARNING STRATEGY?

“In the mid-1960s, an exceptional event occurred. McMaster An important and basic tenet of PBL is that it is problem-
University gave birth to a medical school so different it first learning, i.e. students attempt to problem-solve a
sent ripples of astonishment throughout the educational medical case even before receiving any formal learn-
world” [3]. ing on the subject matter. Usually, a real-life medical
In the 1960s, the Canadian government identified case (a problem) triggers the learning process for stu-
a need to establish a medical school in McMaster dents, i.e. the problem serves as the starting point
University in Hamilton, Ontario. At the outset, the for learning relevant content knowledge required to

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PBL: education for healthcare professionals

understand or resolve various issues related to In the second tutorial (session 2), the students recon-
the problem case. Thus, regular practice in problem- vene in their respective groups after the self-study
solving is another key feature of the PBL process period to perform the following:
[6,7]. Moreover, case-writers often construct PBL • Share and evaluate the new knowledge and in-
problem cases that contextualize and integrate learn- formation (new evidence) acquired by group
ing across disciplines and, therefore, a problem case members
usually includes issues relating to population, be- • Reanalyze the problem in the light of new evidence
havioral and the life sciences, as well as the clinical available
sciences. • Reformulate and refine the preliminary hypotheses
Typically, intensive small-group tutorials are used generated
for the delivery of instruction in the PBL process with • Integrate and apply the refined hypotheses generated
the teacher serving as the tutor (or facilitator) whose to explain the key issues related to the problem case
role it is “to expedite the intellectual and interpersonal • Resolve the problem case
process for the group” [8]. The PBL tutorials usually con- The primary purpose of tutorial session 2 is, there-
sist of two sessions of about 2 hours, each devoted to fore, to reanalyze, evaluate, integrate and then apply the
each problem case, with an intervening self-study period new evidence obtained to explain and/or to resolve the
of about 4–5 days for information searching and gath- problem case.
ering. The self-study period creates opportunities for
students to undertake self-directed learning [6,7] and,
therefore, laying a firm foundation for lifelong contin- DYNAMICS OF THE PBL TUTORIAL
uing self-education. PROCESS
Each tutorial session has its “specific process, goals
and outcomes” [6]. The first tutorial (tutorial session 1) “…when the objective is critical thinking…, or problem-
consists mainly of brainstorming as follows: solving…, and the development of qualities such as sensitiv-
• Presentation of the problem-case by a member of the ity, cooperation and zest for discovery, discussion pedagogy
group offers substantial advantages” [9].
• Problem analysis through reviewing the facts of the The PBL tutorial process applies the principles of
problem case interactive teaching and learning using discussion pedagogy
• Hypothesis generation to develop ideas to explain [9]. The small group learning design creates opportunities
various aspects of the case for student-centered and collaborative learning character-
• Formulation of learning issues (learning objectives) ized by “…joint goals, mutual rewards, shared resources,
to guide identification of the content knowledge and complementary roles among members of a group” [10].
hat needs to be learned in order to either refute or The process essentially consists of students engaged
confirm any hypothesis generated and, thus, to in constructive conversation among themselves and
have a better understanding of the case facilitated by their tutor, mainly through brainstorming
• Identifying the appropriate learning resources (e.g. in which students critically analyze, debate and clarify
textbooks, internet, or professional expertise) from ideas and issues, and then mutually reach consensus
which to search for and gather information relevant to explain or resolve a problem. The dynamics of the
to the case PBL tutorial process is, therefore, specifically aimed
• Assigning tasks to group members to search at actively involving students in teaching and learn-
for information related to the learning issues ing from and with one another, i.e. in peer teaching and
formulated learning in an “All teach All learn” mode.
Tutorial session 1 is, therefore, primarily aimed at Thus, in the PBL tutorial process, students learn
identifying the facts of the case through problem analysis, through social interaction in which they are required
generating hypotheses (ideas) about the case, formulat- to co-construct their own meaning and understanding
ing learning issues to guide relevant learning that is of knowledge that needs to be learned, “…rather than
required to explain or resolve the case, and identify- having knowledge delivered to them in already organized
ing the learning resources for information search and form” [11]. Peer teaching and learning is recognized as
gathering. a powerful pedagogical strategy to enhance higher-order

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M.C.E. Gwee

cognitive processes among members of a group. This context), and knowledge elaboration (i.e. creating
has been clearly emphasized by Brookfield [12] in his opportunities for active discussion)
statement “…the peer support provided by a group of • Cooperative learning theory: relating to the process
others also trying to do this is a powerful psychological of collaborative small group learning
ballast to critical thinking efforts.” • Self-determination theory: relating to external and
Furthermore, according to Abercrombie [13], such internal motivators of learning
discussion pedagogy promotes clinical judgment, and • Control theory (of human behavior): relating to in-
he has clearly expressed that “Discussion in a group does fluencing human behavior (including the desire
for thinking what testing on real objects does for seeing… to learn) through satisfying one’s basic needs for
Instead of seeing our own mistakes by contrast with the state- survival, including belonging, love, power, free-
ments of an unquestioned authority, as in the traditional dom, and fun.
pupil-teacher relationship, we see a variety of interpreta-
tions of the same stimulus pattern, and the usefulness of
each must be tested in its own right.” PBL: SOME ISSUES, CHALLENGES,
OPPORTUNITIES
Providing and receiving feedback
An important practice in PBL is for tutors and stu- Any institution responsible for the education of health-
dents to devote about 10–15 minutes near the end of care professionals and contemplating implementing
each tutorial session to provide and receive feedback PBL as a way of learning for their students must have
from each other. This focusing on what factors en- a clear understanding of the strengths and limitations
hanced or inhibited group achievements of tasks and of PBL as a pedagogical strategy. This section will pro-
individual performance in tutorials, including the vide some insights on the issues, challenges, and op-
perceived impact of one’s own behavior on others portunities associated with the practice of PBL. These
and on group functioning. It is expected that such reg- will hopefully guide curriculum planners and devel-
ular feedback sessions help nurture the development opers in their decision-making.
of reflective learning in students and, consequently, the
development of greater self-awareness leading to self- Curriculum options
initiated remedial action (i.e. metacognition). Thus, stu- PBL can be implemented as a full (complete or pedi-
dents can develop personal insights of their strengths gree) curriculum in which the entire (or almost entire)
and limitations with respect to a given area of learn- curriculum for the education of healthcare profes-
ing. According to Halpern [14] and Maudsley and sionals is designed and delivered through PBL, just
Strivens [15], such self-awareness (metacognition) is as in the case of the highly teacher-directed, lecture-
an important attribute of critical thinkers. based and discipline-specific curriculum of the 20th
century. Armstrong has already drawn attention to
this issue, as she cautioned “replacing all lectures with
PBL: ARE THERE ANY THEORIES discussion groups or tutorials would merely substitute one
SUPPORTING ITS PRACTICE? lop-sided system with another” [16]. It is also well recog-
nized that students have a diversity of learning styles
The Contextual Learning Theory has often been advo- and offering only one way of learning through PBL
cated as the main theoretical underpinning for PBL, may disadvantage some students. Several institu-
which has been highlighted by Boud and Feletti [4]: tions have successfully implemented PBL as a hybrid
“problem-based learning is grounded in the belief that curriculum combined with other learning strategies
learning is most effective when students are actively in- (e.g. lectures, practical classes). Armstrong has, in
volved and learn in the context in which knowledge is to fact, made the point that “hybrids usually display
be used.” However, according to Albanese [10], there strength and adaptability” [16].
are also other theoretical underpinnings, which pro-
vide stronger support for the PBL strategy, including: Implementation of PBL
• Information processing theory: relating to prior knowl- Careful and strategic planning is required in the
edge activation, encoding specificity (i.e. learning in implementation of PBL, especially in institutions that

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PBL: education for healthcare professionals

have already been deeply entrenched and entrapped the support of skilful and dedicated case writers; from
in a traditional 20th century curriculum in the educa- the viewpoint of physical and technical support, one
tion of students. Paying attention to the following needs to consider the availability of suitable tutorial
will pay dividends: rooms (particularly when student numbers are large),
• Have a clear understanding of the basic tenets of as well as the availability of appropriate technological
PBL, including its practice and philosophy, before resources (e.g. internet facilities).
attempting to design a PBL curriculum
• Ensure a deep commitment to planning and Sustaining ongoing PBL programs
development as implementing PBL can be a Not only is it important to ensure the successful
daunting task implementation of PBL in an institution, but one also
• Form a PBL committee consisting of members has to ensure that an ongoing successful program can
from various disciplines, including members from be sustained. Thus, obtaining regular feedback from
the basic sciences as well as clinicians students and their tutors is critical to identify emerg-
• Prepare students and teachers for a significant ing problems early, and for remedial action to be
mindset change prior to implementation; this can taken when deemed necessary. Ongoing training for
be an onerous task. Moore has already cautioned new cohorts of students and teachers should also be
that, in the experience of Harvard Medical School, included to help sustain the practice of PBL.
“considerable resistance, skepticism and outright hos-
tility emerged during the planning process” [17]. Culture and learning
Thus, specific training and faculty development A basic tenet of PBL is the need for an open discussion
programs must be organized to prepare students style in PBL tutorials, but this may conflict with the
and teachers for their new roles in the PBL process. more reserved Asian communication style. Although
the Asian communication style can be a barrier and,
The PBL tutor therefore, a hindrance to learning in PBL, it is a problem
“The problem-based learning (PBL) tutor is one of the most that can be overcome and, consequently, enhance stu-
important elements in PBL” [18]. dent learning in PBL, if teachers and students are
The success or failure of PBL tutorials is often informed about and clearly understand the dynamics
determined by the commitment and tutoring skills of of the PBL process. Another related issue is that of
the PBL tutor. It is the tutor who sets the brainwaves language. Many higher education institutions in Asia
in motion and, therefore, the pulse and tone of dis- now prefer and expect their students to use the English
cussions. In fact, the tutor usually creates a “mirror language in PBL tutorials, although many students
effect”, because the enthusiasm of students in tutori- lack proficiency in English, as it is neither their spoken
als often reflects the enthusiasm of the tutor in his/ nor national language. Gwee has already addressed
her role as the facilitator of the learning process [8]. these issues in a previous publication [23].
There are several important issues relating to the role
of PBL tutors, including whether tutors should be PBL: same name but different game
experts or otherwise. Institutions intending to im- “…PBL is interpreted in widely different ways. PBL in
plement PBL must therefore pay particular attention action is currently characterized by many different strate-
to the “selection and training of tutors… a critical com- gies. This variety has important consequences for evalua-
ponent of PBL.” [18,19]. Several scholars have ad- tion and research since findings from one PBL institution
dressed the arguments over the role and choice of may not be applicable or relevant to another also employ-
PBL tutors and have provided much insight on the ing the problem-based approach” [24].
issues [18–22]. PBL has now spread widely across the globe, and
beyond the original confines of medicine and other
Logistics, including manpower support health sciences curricula into many other disciplines
It is important to appreciate that PBL is a highly [25,26]. Asian healthcare educators started adopting
resource-intensive educational strategy requiring a and implementing PBL with much vigor in the mid-
large range of logistical support. This includes: the 1990s [23]. The adoption of PBL, as an active learning
availability of well-trained and committed tutors and strategy for students in the 21st century, by so many

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M.C.E. Gwee

disciplines and institutions, led to its adaptation to limitation of such assessment in the affective domain
suit individual requirements in practice. As a conse- of learning is that they may inherently lack psycho-
quence, there are now many different versions of PBL metric reliability and validity. Special attention must
which may differ quite considerably from the original therefore be paid to the design and selection of a rig-
McMaster model, as well as from each other. Com- orous assessment strategy together with the formula-
parisons of the results of outcome studies reported by tion of relevant test items in such assessment [32].
PBL practitioners in different institutions can therefore
pose serious difficulties and cause much confusion Returns on investment
in the interpretation of the results from such studies The returns on investment from PBL can be quite a
[24,27,28]. contentious issue, especially in view of PBL being a
highly resource-intensive educational strategy to imple-
PBL: the need for assessment ment. Perhaps it is best to review this issue through a
“[There is a need to design] …an assessment plan that comparison of the actual educational outcomes (as sub-
respects PBL principles, is reliable and valid, and has no stantiated in the literature) with the expected educa-
negative steering effect [on student learning]” [29]. tional outcomes (as intended in the design principles,
All educators are aware of the steering effect of i.e. the expected outcomes based on theoretical con-
assessment on student learning and the common siderations). Many educators have great expectations
adage that “assessment drives learning”. It has also been of the educational outcomes from PBL because it is
emphasized that “students don’t respect what you expect, aimed at enhancing and optimizing learner-centered,
they respect what you inspect”! In this context then, it is collaborative, contextual, integrated, self-directed, and
imperative to ensure that assessment must also be an reflective learning. Educational outcomes from PBL
ongoing part of any PBL curriculum. First, there is a are therefore expected to go beyond just knowledge
need to assess knowledge acquisition by students (i.e. acquisition. PBL can be expected to equip students
assessing the cognitive domain of learning) for which with a more enduring educational process and life
a clinical, scenario-based, multiple choice question type, skills, including the higher-order cognitive skills of
which incorporates testing of higher-order thinking critical thinking and reasoning, and problem-solving, as
skills and problem-solving skills would serve the pur- well as “soft” skills in the affective domain of learn-
pose: “…we are unequivocally on the side of multiple- ing such as interpersonal, communication, team-work,
choice questions” [30,31]. It should be noted that the and leadership.
problem-solving ability is highly dependent on having However, a review of the literature strongly sug-
an adequate and relevant knowledge base, in the gests that there is a mismatch between the actual (as
sense that it is dependent on how factual knowledge reported in literature) and expected (based on educa-
is constructed, contextualized and organized into a tional strategies used) educational outcomes from
conceptual framework to facilitate retrieval in the PBL. In fact, several studies in the past have con-
problem-solving process [30]. cluded that there is generally little or no difference in
Assessment in PBL must go beyond just testing knowledge acquisition and clinical skills between
cognitive learning—it must also include the as- students from traditional approaches and those from
sessment of learning outcomes in the affective (atti- PBL curricula, even when students are tested for
tudes) domain, a value-added outcome of the PBL higher-order thinking [33]. In his editorial, Norman
curriculum. Such assessment will need to involve, provided a critical and excellent overview on this
as precisely as feasible, documentation of specified issue [34], in particular drawing attention to “…what
observed behaviors and attitudes in a given situation may lie beyond PBL” with respect to “…how concepts are
or context, or in the actual work environment. The learned”. Nevertheless, Norman clearly stated that “the
end-of-tutorial feedback session (self–peers–tutor) solution is not advocacy of return to a traditional, discipline
serves as a useful and informal (formative) assessment oriented curriculum” [34]. However, student acquisi-
procedure, often with the need for more formal tion of interpersonal skills and the joy of learning from
(summative) self, peer and/or tutor ratings on specific a PBL curriculum are well documented, as attested to in
items relating to, for example, interpersonal, com- the statement of Albanese: “Even if knowledge acquisition
munication and team-work (group) skills. A major and clinical skills are not improved by PBL, the enhanced

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PBL: education for healthcare professionals

work environment for students and faculty that has been a PBL strategy to nurture student learning in the
consistently found with PBL is a worthwhile goal” [35]. affective domain?
It is noteworthy that a more recent systematic
review was undertaken by Koh et al in which they Opportunities
searched for “…evidence of the effects that problem-based “To build the colleges we need for the 21st century… we
learning in medical school had on physician competencies must consciously reject the Instruction Paradigm and
after graduation” [36]. The authors concluded that restructure what we do on the basis of the learning para-
PBL “…during medical school has positive effects on digm” [41].
physician competency after graduation, mainly in social “[Medical] Schools have yet to create a truly learner-
and cognitive dimensions.” In his commentary on the centered environment that makes active, self-directed learn-
work of Koh and his colleagues, Norman expressed ing under the close tutelage of interested faculty members
that, “For years we have endured debate about the relative the core of the experience” [42].
merits and weaknesses of problem-based learning. Now There is now global consensus on the need for a
there is good evidence that the method delivers on some major shift in the educational paradigm, from the tra-
very important issues. The next step is to determine why ditional teacher-directed instruction to more student-
the method works.” [37]. Similarly, Wood expressed centered learning. The major paradigm shift is expected
“The review confirms what most educators have come to to provide better educational preparation for students
believe on the basis of hundreds of less rigorous reports to meet the demands and challenges of a globalized
that, compared with traditional learning, problem-based knowledge-based economy in the 21st century [41,42].
learning has some beneficial effects on some psychosocial In this context then, PBL represents a highly student-
outcomes of undergraduate medical education” [38]. centered learning paradigm that has stood the test of
time for almost four decades now, and is still spread-
Challenges ing widely across the globe (some criticisms notwith-
Although PBL represents a strategic learning system standing) [22]. No other educational innovation is
design which combines several learning principles known to have lasted this period of time.
and is strongly underpinned by educational theories Therefore, PBL offers educators of healthcare pro-
and principles [10], Dolmans et al also pointed out fessionals and students excellent opportunities to de-
that “…in educational practice, problems are often en- sign and deliver instruction to their students with a
countered, such as tutors who are too directive, problems primary focus on student learning outcomes and on active
that are too well structured, and dysfunctional tutorial student participation in the learning process. More-
groups” [39]. Thus, the greatest challenge to the suc- over, as a strategic learning system design, PBL is also
cessful implementation of PBL is how best to success- aimed at enhancing and optimizing collaborative, con-
fully combine the key learning principles of PBL into textual, integrated, self-directed, and reflective learning
a coherent practice which would result in beneficial which add further educational value to the learning
outcomes in the education of healthcare profession- outcomes expected from PBL.
als in the 21st century. Important issues, which impact
on the practice of PBL (as discussed above), should
provide some guidance in this context. CONCLUSION
Wood [38] has raised an even more fundamental
issue, pointing out that most undergraduate medical “The central mission of medical education is to improve the
curricula today are outcome-based [40] and incorpo- quality of health care delivered by doctors… [with] pa-
rate small-group learning with fewer lectures in the tients as the recipients of our skills… what doctors do, and
delivery of instruction. The challenge posed by Wood how and when they do it, depends on the quality of medical
is in her statement: “Teaching and learning in communi- education. We need to get it right” [43].
cation skills and the psychosocial domains can be achieved PBL is essentially a strategic learning system which
in many ways, and working in small groups—coupled represents a major shift in the educational paradigm
with timely and constructive feedback—may be just as from the traditional teacher-directed (teacher-centered)
effective as problem-based learning” [38]. The question instruction to student-centered (learner-centered) learn-
is, then, do we still need to adopt and implement ing, a paradigm considered more appropriate for the

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M.C.E. Gwee

educational preparation of students in the 21st cen- I am also grateful for the generous support provided
tury. Implementation of PBL can be a tremendously by KMU. I would like to express my deep apprecia-
daunting task: not only will it require a clear under- tion to all my fellow speakers, tutors and all KMU
standing of the strengths and limitations of PBL, but faculty and students for the fellowship and commu-
also a significant change in the mindsets of students nity spirit with which we all enjoyed our learning
and teachers [7,17,44]. Implementation of PBL is together.
likely to cause some difficulties, including discomfort
and agitation to both teachers and students, especially
in the early phase of its implementation, and in those REFERENCES
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