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Inside Under the microscope: renewals 06 Interview: Duncan Rudkin 14 FtP determinations and learning 22
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Contents
Welcome from the chair A message from the chief executive and registrar Pharmacists update Pharmacy technician update Renewal Standards News in brief Letters Customer service Three countries Interview with registrar Continuing Professional Development Education and training GPhC Fitness to practice legacy cases Fitness to practice determinations 2 3 4 5 6 8 9 10 12 13 14 16 18 20 21 22
This rst issue focuses on the importance of renewing your registration; being on the register is an important safeguard on which safe and eective regulation depends. There are also articles on continuing professional development (CPD) and tness to practise (FtP), reminding us that the declarations you sign at the point of registration or renewal are not merely boxes to tick they are fundamental to your day-to-day working lives and to our assurances to the public about your tness to practise, which your continuing registration represents. Regula+e forms part of a wider dialogue between the GPhC and registrants: what are we doing well? What can we do better and what do you want to see more of? Or less? Feedback to us is always important. Let us know what you think. The public places a lot of trust in you and so do we. We hope you enjoy reading Regula+e and we look forward to hearing from you.
Regula+e is the registrant bulletin of the General Pharmaceutical Council. It is sent to all registrants (at the time of posting) and pre-registration trainees. At times we may approach external organisations or individuals to submit an article or opinion on a topical issue. All articles and letters commissioned, written or submitted are subject to editorial control and may not be printed in full or with reference back to source. If you would like to contact the editor or submit a letter or comment to Regula+e please contact us at: regulate@pharmacyregulation.org The Editor, Regula+e General Pharmaceutical Council 129 Lambeth Road | London | SE1 7BT General Pharmaceutical Council 2011
Much of what we have done over the 12 months since we became operational has been about putting in place the essential building blocks to underpin more ecient and eective regulation which is not code for more regulation. We carried out a major communications drive to ensure that all those with the option of applying for pharmacy technician registration had the information they needed before the start of compulsory registration. We are now working through the muchlarger than expected nal wave of applications which this campaign brought in. When it comes to tness to practise, we are clearing the legacy cases we inherited from the RPSGB and we are learning lessons. We have put solid foundations in place, including a new customer contact centre. And we will provide you with greater value as time goes on.
And so to Regula+e. We know that its not enough for us to be accessible through email and phone. We have an obligation to reach out too and this will be one of a number of additional ways we will do so. This regular publication is not about promoting our existence and work it will focus on regulatory information you need to know. Regula+e is your publication. We want to encourage your feedback on areas and topics that you would like to see covered in future issues, and to contribute and share your learning with other pharmacy professionals by writing to our letters page.
Pharmacist update
with regulatory information, and our dedicated customer contact centre means we can answer your questions quickly and eectively. As we are a new regulator, we have introduced some concrete changes. These include a rolling register with a xed period of registration whether you work as a registrant in community pharmacies, hospitals, the pharmaceutical industry or other areas such as primary care trusts, universities or pharmacy organisations, rolling registration is a new concept. The new renewals system requires that you register two months prior to your renewal date, which will be a year from your initial registration or your existing renewal date if you have been on the register prior to September 2010. See Duncans interview, p14 A time for renewal, p6
satised our registration requirements and are subject to national standards. Patients can therefore expect the same high standards of conduct, ethics and performance and accountability as they do from pharmacists. We gave applicants a two-year window to voluntarily register with us based on experience and a preexisting qualication, known as grandparenting. In addition to these grandparenting arrangements, in June we also slightly modied the process for pre-registration trainee pharmacy technicians to allow them to apply for registration four weeks before the end of training. We did this in response to feedback from the profession. This requirement for compulsory registration meant we received around
20,500 applicants before this summers deadline. While that has created a challenge in terms of processing applications, it is a happy problem to have. We are still processing some of these and this may take a few more months. Pharmacy technicians play a key role in the way that the pharmacy profession interacts with and serves the public. Like the renewal process itself, putting pharmacy technicians on the register is a way of saying to patients and the public, we are competent, t to practise and highly trained. It announces that you are working to agreed codes of conduct and ethics, your training is up to date and rigorous, and patient safety is your number one concern.
If you were previously registered with the RPSGB but do not apply for registration by 26 September 2012, despite your experience and qualications, you may need to complete additional education and training. Please note that, if you applied after 1 July 2011, you will not be able to work until you are registered. If you applied under the transitional arrangements, you can continue practising until your registration application has been processed. Those who have recently qualied and who applied under the new arrangements (but have only worked as a pre-registration trainee pharmacy technician) have had their applications prioritised as they cannot work until
they have a registration number. It is also important to note that you must apply for registration within ve calendar years of starting on a recognised course or within two years of completing the last recognised course, whichever is sooner. A pharmacist who employs or manages a member of sta to undertake the roles and responsibilities of a pharmacy technician, but who is unregistered, may be liable to tness to practise proceedings and possible removal from the register.
Renewal
You will have seen a great deal about renewals recently. We make no apology for that. The rst rolling renewal process has started and we want to help you understand and use this process to secure your registration. The key fact to remember is that you need to complete your renewal at least two months before the date of your previous renewal. If you registered after 27 September 2010, this will be the anniversary of when you joined the register. If you were on the register prior to 27 September 2010 and transferred from the RPSGB, your renewal date will remain the same. But you will also have to comply with the minimum two month deadline. This is an important development in pharmacy registration, says GPhC chief executive, Duncan Rudkin. For the rst time, renewals will be in line with initial registration, making it clear for people and businesses to know when they are due to renew and for what period.
The changes aect everybody. Owners and superintendents will receive reminders on a monthly basis, which means you could be sent a number of reminders over the course of the year but although you will have to renew registrations throughout the year, you will only need to make one declaration to cover all registered premises for the next year. Renewals are a simple enough process you are sent a renewal notice and must renew online using myGPhC or by an automated telephone service (unless you are an owner of premises, in which case you need to ll in the renewal form and return it by post). While it might be tempting to think that renewal is simply about paying a fee, it is more fundamental than that. Renewal is the foundation on which patient safety sits. Renewals include completing your tness to practise declarations and your renewal declaration conrming that you adhere to our standards and that you have done, and will continue to keep up to date with your CPD, explains Terry Orford, head of customer services. Renewal is not just about paying.
Renewal
The CPD and FtP declarations that registrants are required to make are not simply box-ticking exercises. They are the chance for you to restate your professionalism. We are also encouraging everyone to provide their email address, if they havent already done so, and registrants are asked to check their details on myGPhC. Above all, please read the information we send out. You would be surprised how many registrants dont read it and either miss their deadline or do not renew properly, says Terry. Those who do not renew in time will be removed from the register this means that they will not be able to practise until they make an application for restoration. Its straightforward enough to renew but we have had to remove some registrants because they didnt meet their deadlines, warns Terry. There are no excuses. And the restoration fee for those who have been removed is considerably more expensive than renewing correctly in the rst place.
Standards
A key element in our standards work is that although they are outcomes focused, we want them to be meaningful to registrants: we therefore look to make clear how they apply in everyday practice. A key area of work going forward will be identifying how we can build on the standards and any supplementary guidance we publish. Although our core standards are designed to be applicable to all areas of practice, there may be some areas where additional guidance or information is necessary to underpin them. To date, we have guidance covering a range of areas, from the provision of pharmacy services aected by religious moral beliefs, to responses to complaints and concerns. We know there are more areas to cover and as part of our ongoing eorts we expect to be consulting and engaging on four more guidance documents in the near future so we can nd out how best to ensure these clarify complex issues for you in your practice. These are: Patient condentiality: the guidance will explain your duty, what we advise in relation to protecting condential information, and advice about disclosure of information. Obtaining consent: we explain what consent is, the types of consent there are and how to obtain it. The guidance also provides information about capacity to make decisions and the dierence between children and adults. Professional boundaries: gives guidance to pharmacy professionals on the importance of maintaining proper professional boundaries and explains your responsibilities. Raising concerns: looks at the importance of voicing concerns and the steps a pharmacy professional should take. This also includes guidance for employers.
The rst four documents expand on standards within conduct, ethics and performance. We know there may be more than one way to meet our standards and you may adopt alternative methods to do this. We expect you to exercise your professional judgment in your day-to-day practice to safeguard the care of patients. We continue to work closely with professional organisations such as the RPS and the National Pharmacy Association to ensure that when we publish standards, other bodies who may wish to provide support and advice to their membership are in a position to do so. We also want your feedback: standards must be relevant to the times and we are looking for areas where new legislation and evolving practice mean we need to tweak or update what we say, or where more support for registrants is required.
News in brief
Raising concerns
We welcome the House of Commons Health Select Committee July report which highlighted the need for health professionals to raise concerns about their own practise or that of other professionals. We are committed to ensuring that registrants understand the importance of this in relation to safe and appropriate care of patients and the public. Our own standards require registrants to commit to this, through standards 6.9 (self-reporting) and 7.11 (raising concerns not just about fellow registrants but about wider healthcare professionals).
Letters
Every issue will feature your letters. In this first issue we have published a number of enquires we have received through our customer contact centre, rather than directly to Regula+e.
Dear editor, I wish to renew my registration for another year. But I wish to set up a direct debit and when I ring the number on your renewal letter there is no option for this!! How I do that? Also, are there extra fees? Zacharias P
Dear editor, I have just received my registration renewal notice by post and was just wondering why the fees need to be paid so far in advance? I am also concerned that if I am paying three months in advance, will this mean that I am eectively registering early and as such losing out on three months of next years registration? As a single mother with a mortgage Im sure you can understand every penny counts in my household, which is why I would like some further clarication before I set up a new direct debit! Thank you in advance for your time, Monica B
In order to set up a direct debit with us you will need to complete a direct debit form which can be found on our website. It is important that you submit this before attempting to renew your registration. Usually it will take 48 hours from receipt of your direct debit form before our systems are updated. If you try to make your renewals before the direct debit has been processed by us, the automated system will insist that you provide either credit or debit card details. Unfortunately there is a charge to use your credit card. There are two options on the form for those wishing to pay by direct debit there is the option to pay a single lump sum of 267 as per your renewal letter, or in quarterly instalments of 66.75. The charge for using the direct debit service is an extra 15 (if you pay in quarterly instalments this will be taken with your rst payment) to cover the extra administration costs involved with providing the direct debit service.
The renewals process is based upon the regulations specied in our Registration Rules 2010, which state that all registrants must renew a minimum of two months prior to their expiry date. As this is set in legislation, there is no exibility with these timelines. The additional month is designed to give registrants enough lead in time to make their declarations, and also to ensure that they have sucient funds in place to make their renewal. You can be assured that your renewal fee covers you for the full 12 months from the expiry date stated on your letter, regardless of how early it is paid.
Letters
Dear editor, Thank you for informing me that my application for registration as a pharmacy technician will not be processed, I understand that it was unfortunate that my application was not received in time to be processed. I have looked at the link which you set out in the letter, but unfortunately I dont understand which further courses I must undertake before my application can be processed again. Therefore I would be extremely grateful if you could inform me of what qualication I should attain. Yours faithfully Hailey S
Edexcel BTEC National Certicate in Pharmacy Services (qualication code 500/1138/8) City & Guilds Level 3 Certicate in Pharmacy Services (qualication code 100/5845/X) SQA National Certicate in Pharmacy Services (qualication code G753 04) plus successful completion of additional SQA modules Building Blocks Chemistry and Local Investigations Buttercups Training level 3 underpinning knowledge programme National Pharmacy Association level 3 underpinning knowledge programme and meet the qualifying period of work experience You need to provide evidence of having completed a minimum of two years relevant work-based experience in the UK under the supervision, direction or guidance of a pharmacist to whom you have been directly accountable for not less than 14 hours per week. (Please see section 7 of the GPhC criteria for initial registration as a pharmacy technician). During these two years, you must have completed at least 1260 hours of work experience (excluding sickness absence, maternity leave and holidays) and at least 315 hours of work experience in each year.
Following the end of the grandparenting arrangements on 30 June 2011, in order to apply for registration as a pharmacy technician you must hold one of the following approved competency-based qualications: Pharmacy Services NVQ level 3 (City & Guilds qualication code 100/2201/6) Pharmacy Services NVQ level 3 (Edexcel qualication code 100/2615/0) Pharmacy Services SVQ level 3 (Scottish Qualications Authority qualication code G75923) and One of the following approved knowledge based qualications
All letters are subject to editorial control and may be reproduced in summary without reference back to source. If we receive a letter that the editor feels needs a response or is clearly an issue of learning for the wider profession we may respond in this letters section. Not all letters received will be published and we will not publish letters that are personally critical of individuals in opinion or comment.
Customer service
The centres aim is to provide an eective and ecient telephone service and to ensure our advice and guidance is up to date, accurate and complete. Sometimes its necessary for us to speak to colleagues about particular enquiries and then call you back. However, we have noticed that the volume of engagement with the contact centre depends on whats happening in the academic cycle. Were adding to our knowledge database all the time, David goes on. We get a host of enquiries around getting hold of training material or paying fees, then as we go towards exams there are a lot of queries around getting to exams, and results, resits and so on. Other spikes in calls have come in the areas you would expect, such as around the July deadline for the registration of pharmacy technicians. From the beginning of May to the end of June we were getting 450-500 calls a day, recalls David. And 600 calls a day towards the end. CPD also throws up a raft of issues for the contact centre. Many of these are practical things, such as logins or passwords or what information registrants have to send in, explains David. The contact centre sta are customer service specialists, not pharmacists, which means they will not give advice on pharmacy queries (an area instead handled by our standards adivsory team). David explains: We should be able to handle at least 80 per cent of calls without passing them on. In reality, we are exceeding this gure, with over 90 per cent of calls answered by the contact centre. While it is important that registrants receive a prompt, timely response to their phone queries, the contact centre does more than this: through the careful management of calls, it has an important role to play in the process of regulation itself in that it can take pressure o other teams in dealing with enquiries.
It can also identify trends that may help in improving our systems and processes, or identifying areas of potential risk and concern within pharmacy. In the majority of cases, visiting our website is still the best way to get the information you need quickly and simply. We use the data collected by the contact centre to develop generic frequently asked questions (FAQs) which you can nd on the website. These FAQs can help to answer enquiries without you having to contact us directly. The FAQs are reviewed regularly to ensure they remain accurate and current.
Three countries
In our responsibility for regulating pharmacy across Great Britain, devolution is an important reality and there are particular challenges for an organisation like ours to ensure we regulate in a way which reects this reality. Firstly, registrants should nd that our standards and any guidance we publish is consistent, and keeps pace with, changes in local legislation and certainly in the delivery of local health services. Our standards also need to reect the realities of dierent legislation in the three countries, for example, in relation to protection of vulnerable groups where the responsibilities of pharmacy professionals and employers may be dierent across Great Britain. We also have a responsibility to consider the impact on regulation of any changes in the delivery of pharmacy services, such as, through changes to the pharmacy contract. Another critical issue is for us to reect our commitment to engagement across Great Britain of all our key interest groups, including patients and the public, as well as members of the pharmacy professions and their employers, in the development of our standards and policies. We recognise that holding one major consultation event in London will not suce. We are committed to ensuring all registrants will have an opportunity to meet with us to discuss our work and the development of our standards, no matter where you live in Great Britain. Finally, and perhaps, the most important implication of devolution, is that to contribute to maintaining patient safety, we must understand the health regulatory and law enforcement agencies across England, Scotland and Wales and ensure we are sharing information appropriately to uphold standards, avoid regulatory duplication or burden, and to protect patients.
New director for Scotland The GPhC is delighted that Lynsey Cleland has been appointed as director for Scotland. Lynsey registered as a pharmacist in 2000 and worked as a community pharmacist before becoming a pharmacist adviser and then head of professional ethics at the RPSGB. From September 2008, she was the northern regional lead inspector, scheduling and delivering an inspection and monitoring programme for a portfolio of registered pharmacies in Scotland. In her new role, Lynseys focus will be ensuring the way in which we regulate in Scotland reects the local context, as well as leading all our engagement work in Scotland including pharmacy professions, patients and the public, Scottish parliamentarians and government ocials.
Director for Wales We are currently recruiting a director for Wales. For further details visit our website.
Interview
As the rst chief executive and registrar of the GPhC Duncan has led the organisation through establishment and its rst full year of operations.
How do you think registrants perceive the GPhC? Do you think youve made a good rst impression?
The reality is for many registrants they will have very little direct contact with the regulator outside of renewal notices. Part of the purpose of Regula+e is to ensure that we keep all registrants up to date with issues that aect them and to enable us to have a more interactive relationship with them. Fitness to practise is only a small part of our role and we need to encourage greater involvement of the profession in shaping policies, from education to new standards and guidance. I think weve made a good start, but registrants will naturally say that the proof of the pudding will be in the eating!
What would you see as the biggest successes of the GPhCs rst year of operation?
Undoubtedly the approach to, and implementation of, our just disposal of legacy cases has been successful. Introducing a whole new registration system has been very challenging but the rst major renewals peak in January appeared to go well with over 98% renewing. However, the most notable change to pharmacy regulation this year has probably been the introduction of compulsory registration of pharmacy technicians.
You have received a lot more applications than predicted. Has that created any problems?
Independent estimates had suggested about 14,500 technicians might register. Once we have processed all the applications, over 20,000 technicians will be on the register. This is a testament to all those pharmacy technicians who wish to contribute to pharmacy as part of a regulated profession with all the requirements and opportunities that brings.
Interview
Have you encountered any problems that you didnt know existed when you started up?
Of course, but it would have been a surprise if things hadnt cropped up: the size of the caseload has been a big challenge, which it is in all the health professions, by the way. However, we have to be focused on the future, not worrying about what happened in the past.
How do you think pharmacy is going to change, and will divergence in practice across Great Britain have an impact?
I am still learning about pharmacy but its already clear to me that there will be changes, including big changes in the role of pharmacists and pharmacy technicians. Our core approach, for example, in standards development is that we need to ensure what we do in regulation is not just t for today or tomorrow, but is proofed against future changes. This applies equally to how we react to the divergent health structures across Great Britain and how we work with colleagues in Northern Ireland. Regulation must be appropriate to the local context and we must ensure that we understand how pharmacy is delivered locally and how we can avoid regulatory duplication and overlap with regulatory bodies based in Scotland and Wales.
Where does the GPhC most need to make progress in the next 12 months?
Weve done much to establish ourselves and ensure a smooth transfer from the RPSGB, but if anything the next year is likely to be busier than the rst. We will be taking forward how we intend to regulate pharmacy premises, which will involve widespread engagement with the profession, and we will be producing a range of regulatory guidance to underpin our standards in areas such as seeking consent and condentiality. A key priority in operational terms will be to complete our work on legacy FtP cases and ensure we are dealing appropriately with cases opened since September of last year. And looking at the eectiveness and eciency of all our operations.
CPD is not a tick-box exercise: it plays a key role in enabling registrants to reect on and apply their learning, and helps to bring into focus everything you learn as you go about your work as a pharmacy professional. We have a statutory duty to ensure registrants practise safely and eectively, and the CPD framework and rules that came into force in July, help to formalise how this is done. It is a legal requirement that you undertake and record CPD: in order to maintain your registration as a pharmacy professional, you are required to demonstrate that your practice is current. The framework explains how to do this, as well as how much CPD is required, how it has to be recorded and what happens when a registrants records are called. One of the changes we have introduced is that not only will you have to declare on your renewal that you intend to complete your CPD in the coming year, but also that you have completed it in the previous year. Crucially, it is not only a question of participating in continuing education the CPD framework is there to explain what we see as an ongoing process of reection, planning, action and evaluation. For example, at least three out of the nine required CPD entries for each full year of your registration must start at reection, and we will check that a registrant has applied at least 50 per cent of our assessable criteria for good recording practice.
If a registrant fails to respond to a request from us to submit their CPD record for review by the deadline given, we may now remove them from the register. Well use this new power only as a nal resort, but it shows the importance we place on CPD as a means of assuring continuing tness to practise. Its best to avoid this by recording CPD regularly, suggests head of education and quality assurance, Damian Day. And our online system is the best way of doing this. For some pharmacy technicians this is all new, of course, as is being a professional registrant group. But perhaps the clearest way of looking at it this is not at the CPD standards themselves, which have altered, it is the way we explain what you have to do which is new, plus the fact that it is now a legal requirement to record this in an approved format. Previously this was a nice to have rather than a necessity, explains Damian. Now, if registrants dont appear to have met the standards then we will ask for extra information or we may ask them to participate in some more learning in a particular area. For example, we may ask a registrant to undertake more CPD activities by a specied date and to make a record of this learning in their record. CPD makes you better able to do your job as a pharmacy professional and the framework is there to ensure registrants are up to date, says Damian. It also provides a cost eective way for the regulator to check this: the CPD framework is not designed to be intrusive records are normally only called every ve years, which means the burden on you is reasonably light. Conscientious professionals are committed to CPD for their own positive reasons having a regulatory framework simply provides an important assurance of something that should be (and in most cases is) happening anyway.
CPD standards are not changed by factors such as part-time employment or working in a non-pharmacy role. We will be exible if someones circumstances change but its always best to let us know of changes in advance, Damian goes on. Changes may include taking a short career break, or being unable to do CPD for a period because you are ill. Finally, we recognise that registrants CPD needs are likely to be very dierent: a community pharmacist or pharmacy technicians CPD record, for example,
might contain entries about clinical issues, public health issues and prescription and over-the-counter medicines. However, a pharmacy managers record could reect managing, coaching or training skills that are being developed, while an industrial pharmacist may have more on regulatory requirements or new technology. We just want to make sure that you are accessing the learning that will help you develop and keep your patients safe.
CPD enables you to update, maintain and develop your capabilities by: Helping you identify your individual learning needs Recognising the learning that occurs in the workplace, whether formally or informally Acknowledging that everyone learns in dierent ways and that you will have your own preferred methods Avoiding the need to complete a xed number of hours of CPD or to stick to a formal learning structure
Anything which helps you to improve as a pharmacy professional such as: Learning knowledge and skills on conferences and courses Practice-based learning including feedback from patients and audits Analysis and review of critical incidents Self-directed learning including reading, writing or undertaking research Learning with others e.g. talking to colleagues or going to workshops
Details of the format in which you must record CPD, and the criteria we use to assess whether youve met our requirements, can be found at www.pharmacyregulation.org. We are interested to have your views on how the CPD review has worked and how helpful or otherwise youve found the feedback given on your entries? You can send us your views to info@pharmacyregulation.org marked CPD review. To update your CPD record, go to www.uptodate.org.uk
The prestige and status that professions are held in is based on the knowledge that they have achieved a standard arguably a gold standard qualication. The courses that you take, leading to registration, are part of the bedrock on which we all stand, and it is our duty to make sure that these are of the right standard. The register sits at the heart of all health professional regulation, explains Damian Day, head of education and quality assurance. We have a legal obligation to set the standards for education and training. We have to check that you have the necessary education and training, and we have responsibility to check on standards within universities. This is all key to ensuring those who come onto the register are t to practise. Pharmacists, and now pharmacy technicians, follow these vital pathways into what is an academically demanding profession. The process of renewal is, at its heart, an armation that these GPhC-accredited courses have been of a standard which ensures public condence in professionals and helps to ensure patient safety.
For pharmacists this means a minimum ve years education before qualication, taking in the four-year Master of Pharmacy Degree (MPharm), followed by a years pre-registration training and completion of the registration exam. Spending that year gaining practical experience in a working pharmacy is a crucial element of pre-qualication training. And since July this year, of course, the register has included pharmacy technicians. As a vital part of the team, technicians have two years consecutive work-based experience under the guidance of a pharmacist, as well as completing a competency-based qualication and a knowledge-based one approved by us, either at a college or by distance learning. We also accredit training courses for dispensing assistants and medicine counter assistants. Perhaps it is also useful to be clear about the things that the GPhC doesnt do when it comes to education and training. We dont set fees (in England) or control student numbers, Damian goes on. Undergraduate pharmacy numbers are unrestricted, for example, and we dont have a role in workforce planning.
It looks at three things: Initial education and training of pharmacists and pharmacy technicians Postgraduate pharmacy training Workforce and technology The rst two of these relate to the way in which students are educated: possible changes in England could include wrapping up the current pre-reg year into a ve-year bundle (rather than a four-year course plus one year) that would include both MPharm and pre-reg. The third part of the MPC workstream looks at how things should work as the pharmacy industry changes, such as the increasing move to clinical practice. What happens in England, Scotland and Wales may well be dierent, says Damian. Some or all of what MPC has proposed may be brought out for consultation probably later this year, but we as the regulator, will need to consider any proposed changes to the provision or funding of pharmacy education proposed by the each of the governments in England, Scotland or Wales. Whatever the outcome, the nature of the pharmacy professions work is changing, and education and training will adapt to suit the demands of patients and employers.
As many in the pharmacy sector move towards a more clinical role, courses will change and we will revise our standards to reect the way the profession is working. But the quality of the courses must and will remain constant, helping to ensure that we will have a well-stocked pool of future talent: qualied pharmacists who are trained to deliver good quality care and services. Ultimately, our responsibility is to patients and the public, concludes Damian. Our aim is to ensure through the training and education that we accredit - that everyone who is registered with us has the necessary skills to carry out their work safely.
In other words, we set the standards which should make registrants ready for life in the profession, but how this is delivered is then down to educational institutions and employers. Two of the larger pharmacy multiples, for example, train around half of pre-reg students who make it on to the register. There will be around 2,800 students next year in pre-reg, says Damian. In 2010, 2,505 new trainees entered pharmacist pre-registration training. As regulator we also try to help shape legislation on education and training by oering our thoughts on how proposed changes may aect registrants and patients. As part of this work, we are contributing to the governments current work on Modernising Pharmacy Careers (MPC), for example. This important project has huge implications for the way would-be registrants will train in future.
GPhC
We will regulate by developing and monitoring compliance of our standards and rules providing a practicable, workable framework for pharmacy professionals to deliver services safely. They are intended to be proportionate and useful, helping practitioners to improve quality, not be rule bound and risk constraining safe practice. We believe that our vision of modern regulation can: Allow pharmacy practice to develop and to rise to new challenges and opportunities, while protecting the safety of the patients and the public Enhance the condence of the public and patients by sending out a clear message that patient safety is paramount
Ensure that registered professionals are t to deliver a wide range of services to the public safely Provide a framework for CPD and, in due course, revalidation Provide a framework for setting standards for advanced levels of practice Regulation should not create unnecessary burdens, but be proportionate to the risk it addresses and the benet it brings. It should support and enable the working lives of pharmacists and pharmacy technicians, and open up pathways to a satisfying career, rather than being seen purely as a means of discipline. These are the principles to which we subscribe and by which we are happy to be judged.
14 appointed Set the strategy; and individuals 7 pharmacy holding the organisation professionals and to account 7 lay people We also have several non-statutory committee: Audit and risk committee Remuneration committee Appointments committee Deal with daily operational issues delivering the councils strategy
Committees We have a number of statutory committees: Investigating committee Fitness to practise committee Appeals committee Executive team 5 people including all executive directors
When we took over regulation of pharmacy, there was one glaring problem: there were a signicant number of tness to practise cases that had yet to be concluded, but for which, as the new regulator, we were now responsible. Due to the way data had been collected and put together, it took us some time to nd out the GPhC had inherited 589 ongoing tness to practise (legacy) cases. Its a big responsibility we took on, says Hilary Lloyd, director of regulatory services. Based on the historic throughput of cases it would be taking us around four years just to clear the backlog without receiving any new cases. For the public who made complaints, and for pharmacy professionals who had cases hanging over them, such delays are unacceptable. The Pharmacy Order 2010 gave us the power to deal with each of the legacy cases in a dierent way to normal procedures. That enabled the registrar, delegated by the governing council, to decide whether cases should go to a full tness to practise committee hearing or could be disposed of in a more proportionate manner. This just disposal of cases has been an important element in speeding the process up; although we have ensured that all cases are handled fairly and transparently. This includes proper internal and external auditing processes, and providing proper explanations of our decisions. We took into account a number of factors: how old is the case or/and can we prove a case where the facts are in dispute? There were a number of checks and balances in the process, but we wanted to make sure, too, that we were being fair and proportionate, while maintaining a clear focus on public protection.
The whole process has been useful on several levels. It gave us an insight into the concerns of pharmacists and enabled us to concentrate on proportionate regulation, Hilary. FtP isnt about punishment. Some cases have been dealt with by providing advice or issuing a warning so they wouldnt then have to go to a full hearing. Complaints have been made over a wide range of matters such as previous convictions that havent been disclosed; ethics issues; dispensing errors; unlawful supply of drugs; alcohol misuse; theft and violence. Some cases appear clear-cut, but in many others there are nuances which need to be carefully examined. We ask what gives rise to these problems, Hilary continues. If a dispensing error is a one-o, then our view is that its a mistake. Were interested in whether people learn from mistakes, which is a key part of professionalism, and to what extent there is any question about their current tness to practise. We want to see whether theres anything systemic in registrants practise which is an issue, rather than running every single error into the ground. Above all else, the idea of proportionate regulation underpins the process of protecting patient safety. Our ethos is that the vast majority of registrants are good people but for a variety of reasons a few might lose their way, she concludes. Our focus should be on getting them back into eective practice, even subject to any necessary temporary restrictions. Of course, there are some cases where, in the interests of the public and the reputation of the professions, the only proper outcome is erasure from the register and we need to deal with those as quickly and fairly as possible.
All our fitness to practise hearings are held in public. Following the conclusion of the hearing we will publish the determination outcome on our website. We will also publish all determinations sanctions in Regula+e.
Determinations
Should a tness to practise committee determine that a registrants tness to practise is impaired, the committee may impose a sanction that is proportionate to the conduct that has been found proven. This may include, for example, issuing a warning, placing conditions on the individuals registration, suspension or, in the most serious cases, erasing the individual from the register so that they can no longer practise. Erasure from the register is the most serious sanction. The matters listed below include registrants registration number, date of the hearing and the sanction by the panel. Determination of the facts and additional information about the hearings can be found on our website.
Edens, Jonathan Michael Hindrik, 2061869 Hearing 17/08/2011 Removed from the register for having been convicted of 13 criminal oences that led to the imposition of a two-year sentence of imprisonment. Shah, Syed Naseem Hussain, 2045091 Hearing 23/08/2011 Suspended for 12 months Shah, Syed Naseem Hussain 2045091 Hearing 23/08/2011 Suspended for 12 months for receiving a police caution for false accounting. Parsons, William John 2020046 Hearing 7/09/2011 Suspended for 12 months following conviction for unlawfully advertising prescription only medicines.
Skekoni, Olawale Alade 2021866 Hearing 31/08/2011 and 1/09/2011 Registration suspended for 6 months following the registrant receiving a police caution for theft of medicines from Asda and for unlawful appropriation of Oramorph (a controlled drug) from Boots whilst in their employment and selfmedicating. Altaf, Ammaad 2053200 Hearing 04/09/2011 Condition placed on registration Risbridger, Ruairidh David 2060809 Hearing 18/07/2011 Registration suspended for 12 months for unlawful appropriation of cash from employer and for inappropriate salary claims.
A central aim for us as a regulator is to ensure that we share learning from fitness to practise cases with you as registrants Learning Case One
Short-date medicines
On 14 May 2010 the former regulator, RPSGB, received a complaint alleging that on 31 December 2009 the registrants pharmacy had dispensed short-dated Levothyroxine 50mcg, which expired at the end of March 2010 when the complainant would be out of the United Kingdom on a fourmonth holiday. In numbered boxes, the complainant was dispensed 4 x 28 tablets of Levothyroxine 25mcg and 50mcg (for a 75mcg daily dose). The complainant took the medication in order of the numbers on the boxes. After the end of March 2010, whilst out of the UK, the complainant discovered that the Levothyroxine 50mcg box 4 of 4 had expired. A complaint was subsequently submitted to the regulator upon the complainant returning from their holiday.
In August 2011 this case was submitted to our legacy determination group [our group considering cases received from the RPSGB] for consideration under the just disposal policy. Both the complainant and the registrant were written to requesting their views on potential discontinuation of the case. The groups recommendation to the registrar was for this case to be discontinued with written advice to be sent to the registrant regarding date-checking short-dated drugs. This recommendation was based on the fact the medication was in date when it was dispensed and that the registrant had shown good insight and taken remedial steps upon receipt of the complaint. The registrant had reviewed her date-checking procedures, therefore the prospect of establishing current impairment of the registrants tness to practise was considered unlikely. The registrar agreed with the groups recommendation. The case was therefore discontinued with advice.
Learning Points Make sure that when you dispense medicines you include a check to ensure that the stock is in date Consider the procedures you have in place for dispensing short dated stock If a medicine has a short date consider whether there is the potential that, by the time the patient takes the medicine it will have become out of date and make a judgement about the appropriateness of the supply
Learning Points Social networking sites, such as Facebook and Twitter, are not appropriate forums to discuss patients Pharmacy professionals should not make derogatory comments about individual patients or patient groups as these demonstrate a lack of respect and can cause unnecessary distress, impacting negatively on the profession as a whole
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Contents
Welcome from the chair A message from the chief executive and registrar Pharmacists update Pharmacy technician update Renewal Standards News in brief Letters Customer service Three countries Interview with registrar Continuing Professional Development Education and training GPhC Fitness to practice legacy cases Fitness to practice determinations 2 3 4 5 5 7 8 10 12 13 14 16 18 20 21 22
This rst issue focuses on the importance of renewing your registration; being on the register is an important safeguard on which safe and eective regulation depends. There are also articles on continuing professional development (CPD) and tness to practise (FtP), reminding us that the declarations you sign at the point of registration or renewal are not merely boxes to tick they are fundamental to your day-to-day working lives and to our assurances to the public about your tness to practise, which your continuing registration represents. Regula+e forms part of a wider dialogue between the GPhC and registrants: what are we doing well? What can we do better and what do you want to see more of? Or less? Feedback to us is always important. Let us know what you think. The public places a lot of trust in you and so do we. We hope you enjoy reading Regula+e and we look forward to hearing from you.
Regula+e is the registrant bulletin of the General Pharmaceutical Council. It is sent to all registrants (at the time of posting) and pre-registration trainees. At times we may approach external organisations or individuals to submit an article or opinion on a topical issue. All articles and letters commissioned, written or submitted are subject to editorial control and may not be printed in full or with reference back to source. If you would like to contact the editor or submit a letter or comment to Regula+e please contact us at: regulate@pharmacyregulation.org The Editor, Regula+e General Pharmaceutical Council 129 Lambeth Road | London | SE1 7BT General Pharmaceutical Council 2011
Much of what we have done over the 12 months since we became operational has been about putting in place the essential building blocks to underpin more ecient and eective regulation which is not code for more regulation. We carried out a major communications drive to ensure that all those with the option of applying for pharmacy technician registration had the information they needed before the start of compulsory registration. We are now working through the muchlarger than expected nal wave of applications which this campaign brought in. When it comes to tness to practise, we are clearing the legacy cases we inherited from the RPSGB and we are learning lessons. We have put solid foundations in place, including a new customer contact centre. And we will provide you with greater value as time goes on.
And so to Regula+e. We know that its not enough for us to be accessible through email and phone. We have an obligation to reach out too and this will be one of a number of additional ways we will do so. This regular publication is not about promoting our existence and work it will focus on regulatory information you need to know. Regula+e is your publication. We want to encourage your feedback on areas and topics that you would like to see covered in future issues, and to contribute and share your learning with other pharmacy professionals by writing to our letters page. Duncan Rudkin Chief executive and registrar