Response to GPhC Consultation on Guidance to ensure a safe and effective pharmacy team. Contact Helga Mangion National Pharmacy Association Mallinson House 38-42 St Peter s Street St Albans Herts AL1 3NP 01727 858687 ext 3376 Email h.mangion@npa.co.uk NPA response to the GPhC consultation on guidance to ensure a safe and effective pharmacy team Page 1
National Pharmacy Association (NPA) response to the GPhC Consultation on Guidance to ensure a safe and effective pharmacy team. The National Pharmacy Association. The NPA is the body which represents the vast majority of independent community pharmacy owners in the UK. We count amongst our members independent regional chains through to singlehanded independent pharmacies. This spread of members, our UK-wide geographical coverage, and our remit for NHS and non-nhs affairs means that we are uniquely representative of the independent community pharmacy sector. In addition to being a representative voice, we provide members with a range of professional services such as GPhC accredited training courses for support staff, to help members maintain and improve the health of the communities they serve. We welcome the opportunity to respond and provide comments to the GPhC consultation on guidance to ensure a safe and effective pharmacy team. Feedback and views to this consultation were sought and received from the membership through a variety of media. It was discussed internally at a number of board committees, and also through a member feedback mechanism through the NPA website. Feedback was also received verbally, and by direct e-mail communication. It is hoped that the relevant weighting be applied to our response, to reflect the NPA membership concerns and thoughts. The consultation response would also include views from the NPA training provider perspective. General remarks The NPA is in agreement with the GPhC rationale that regulation should continue to adapt and respond to the pharmacy changes evolved around patient needs. In response to the proposal that the Pharmacy Owner ought to be accountable for, making sure unregistered pharmacy staff are competent for their roles, the NPA seeks further clarification as to the process of how the GPhC would hold non-pharmacists owners accountable to this, given that the GPhC jurisdiction only covers pharmacists and pharmacy technicians. Term support staff It is in the consultation document that the GPhC views the term support staff as outdated. It is not clear from the succeeding text as to what the preferred term would be, however the reader is led to understand that the term has been replaced with unregistered pharmacy staff. NPA response to the GPhC consultation on guidance to ensure a safe and effective pharmacy team Page 2
The NPA suggests that the term support staff is still relevant. In the community pharmacy, the responsible pharmacist is responsible and accountable for the running of the day to day pharmacy; other staff are employed in support of the pharmacist. GPhC proposal of non approval of individual training programmes The NPA does not support the proposal of the GPhC of no longer approving individual training programmes and qualifications for unregistered pharmacy staff. The roles of the unregistered pharmacy staff are becoming increasingly vital in the changing role of pharmacy. This proposal, the NPA feels, would bring about the emergence of a number of courses aimed at non-registered pharmacy staff without any assurance that they would match the regulatory standards or are fit for purpose for the very important patient facing roles in the pharmacy. The responsible pharmacist needs to be confident in the ability of the staff who are often the first point of contact with patients and the public, to undertake their role. In a community pharmacy, pharmacy teams include, but are not exclusively Medicines Counter Assistants, Delivery Drivers, Registered Pharmacy Technicians and Pharmacists: 1. Medicines Counter Assistants as part of the triage pathway of when a patient seeks to purchase an Over the Counter medication from the pharmacy 2. Technicians in the assemble and the preparation of medication 3. Delivery Drivers in the Delivery of medication 4. Pharmacists in the public health role of community pharmacies. Most members of the community pharmacy teams are also involved in the provision of some pharmaceutical services under the direct supervision of the responsible pharmacist. Currently, NPA members avail of the GPhC accredited training courses for these roles and are assured of their validity and relevance to the role soon to be undertaken by the pharmacy support staff. From a training provider s perspective, the NPA welcomes the opportunity for its courses to be accredited by the regulator: 1. It confirms the regulatory standards of the course NPA response to the GPhC consultation on guidance to ensure a safe and effective pharmacy team Page 3
2. Opens an informal communication channel between the training provider and the regulator. Through this the training provider would be able to implement new guidance or suggestions by the regulator with immediate promptness The guidance: Broadly, the NPA welcomes guidance from the pharmacy regulator. In regards to this proposed guidance to ensure a safe and effective pharmacy team, which would then enable pharmacy owners and pharmacists to use their judgement in how to best meet those outcomes for their pharmacy, the NPA suggests that further clarification with specific practical information, is provided, in order to illustrate good examples of how this guidance could be interpreted. This will provide assurance through the GPhC regulation of registered pharmacies. Under the proposals set out in this consultation, the assurance provided and then received is subjective and may be open to a number of interpretations. This in turn could lead to a variation of standards across the sector and may lead to adverse patient safety implications. Variation of standards across the sector would also impact on the pharmaceutical services available through a community pharmacy. Currently, when a pharmaceutical service is due to be commissioned, commissioners set out service level agreements, with the assumption that a specific named role has undertaken the minimum accredited training required. In the absence of this accreditation and the clear guiding principles, a community pharmacist and their teams would need to undergo further unnecessary and in some cases costly training in order to confirm their eligibility. This could then be further complicated by the fact that unregistered pharmacy staff work in a range of other settings, including hospitals and GP surgeries, settings which have their own regulatory premises standards. The NPA suggests that standards are produced in addition to the guidance which would support the pharmacy owner regardless of whether they happen to be pharmacists or non-pharmacists in order to outline competencies for their non-registered pharmacy staff. CONSULTATION QUESTIONS: 1. Do you agree with the proposed approach? The NPA membership belief is that when the Pharmacy Owner is also the Superintendent Pharmacist, there is a common level of understanding of legal obligations in assessing the competency of all members of the pharmacy team. In cases when the owner is not a pharmacist, there may be a spectrum of understanding around the legal obligations, concerned with assessing the competencies of unregistered pharmacy roles. NPA response to the GPhC consultation on guidance to ensure a safe and effective pharmacy team Page 4
The NPA seeks further clarification as to the process of how the GPhC would hold non-pharmacists accountable for this, given that the GPhC jurisdiction only covers pharmacists and pharmacy technicians. 2. Does the proposed guidance adequately cover the key areas to ensure a safe and effective team? Should the GPhC carry on with its role of accrediting courses for non-registered staff, then the NPA suggests that the guidance is adequate but would require a few detailed comments in some parts. However, should the GPhC cease its role in the accreditation of courses then the NPA suggests that the guidance proposed adds very little value to the current standards and the guidance proposed would then need to be further developed. The following are comments to this consultation from a member and training provider perspective. Governance: The NPA agrees with the headlines as outlined in the Governance element of the guidance, as most pharmacies will be covered through legislation such as the Data Protection Act, and Health & Safety Act. The NPA however, suggests further clarification on one point. Staff numbers and roles are appropriate for the services provided and are systematically reviewed in line with changing services and workloads. Currently, there is no minimum staff requirement and the NPA asks what measure could and would be used that could determine what the correct staff numbers and roles are in a particular pharmacy. Also, the pharmacy owner or superintendent could create new roles in response to patient need and/or new commissioned pharmaceutical services. In the absence of further clarification and guidance, this is all subjective and open to interpretation through the regulation process of registered pharmacies. Education and training requirements: The NPA agrees with the headlines outlined under education and training requirements, and suggests further clarification on some points: NPA response to the GPhC consultation on guidance to ensure a safe and effective pharmacy team Page 5
...they assess the competence of staff when they start in their role and make an informed judgement on what further knowledge or training they may need. This should include considering the member s previous education and training, qualifications held, and work experience as well as monitoring their performance. In the absence of accredited training courses, standards and competencies, a subjective judgement would be drawn. Robust standards would need to be outlined for further clarification for the standardisation of the pharmacy offer across the community pharmacy sector. Unregistered pharmacy staff who need further education and training to meet the required competency level for their role are enrolled on an appropriate training programme within three months of starting in their role. In the absence of further clarification and accreditation of courses by the GPhC, it would be difficult to define an appropriate training programme. Furthermore, some pharmacy owners and responsible pharmacists would only enrol a new member of staff onto a course once they have completed their induction successfully. In most cases the induction period would be for three months, meaning that the student would then be enrolled onto the course after a minimum of four months after starting their new role. The NPA suggests that the pharmacy owner in collaboration with the pharmacist (in instances of being a non-pharmacist), make the timely decision (to include extenuating circumstances) as to when the unregistered pharmacy staff be enrolled on an appropriate training programme. The needs of their patients and local communities are identified and staff are trained accordingly. Currently, there is a pharmaceutical needs assessment that is used locally to identify the service needs of their patients and local communities, however currently there is no tool available where staff training needs are also able to be identified. The NPA suggests that guidance for such a tool should be made available in addition to this principle in the guidance. NPA response to the GPhC consultation on guidance to ensure a safe and effective pharmacy team Page 6
Knowledge, skills and development: The NPA is in agreement with the level of guidance as outlined under this principle, however suggests that further guidance be published in order for pharmacy owners, regardless of whether they are GPhC registrants or not, to be able to fully meet the suggested principles. For example in The knowledge, skills and development of staff within their teams is appropriate for the services provided by the pharmacy. & Essential elements of training are identified for each role within the team and these are proactively reviewed and reassessed, in response to changing needs and circumstances. A mapping tool be provided, in addition to further guidance, as to what the pharmacy owner would be reviewing and assessing against. The principle: They have considered whether they can make protected time available for training. Has been considered in a number of previous GPhC workforce consultations. Evidence suggests protected study time is of benefit to both the student and the pharmacy team and ultimately the patient for a number of reasons. Given that this principle would be incorporated into a guidance document, the NPA suggests that further examples of what good protected (training) time looks like be defined for consideration by the Pharmacy Owner and Superintendent Pharmacist. Maintaining a person-centred environment: The principles outlined under this definition appear to be aligned to the Healthy Living Champion as part of the Health Living Pharmacy campaign. The NPA suggests more robust principles to allow for mapping by the Pharmacy Owners and Superintendent Pharmacist in order to be able to meet this particular principle. Management and leadership roles: The NPA is in agreement with the principles outlined under this definition, particularly when it relates to non pharmacist owners. The NPA however, would ask as to how these principles would be NPA response to the GPhC consultation on guidance to ensure a safe and effective pharmacy team Page 7
able to be applied in terms of accountability and make non-pharmacist owners accountable to this, given that the GPhC jurisdiction only covers pharmacists and pharmacy technicians. 3. Is there anything else not covered in the guidance that you would find useful? Please give details. In the instance of the GPhC following through with the proposal of non-accreditation of training course, the NPA would suggest that this would lead to a diverse range of assessment methods used in the sector. This could lead to a variable standard of quality due to a lack of regulatory oversight and a number of questions raised. -Where would the oversight and governance of the training provider sit? -Who will determine as to whether the current sampling techniques being undertaken for quality assurance are effective enough? Further guidance would be required to ensure consistency throughout. The NPA is also concerned in instances when the awarding bodies for these courses are no longer providing the service due to commercial factors. Training requirements. 4. Do you agree with the minimum level of competence for unregistered pharmacy staff who are involved in dispensing and supplying medicines? No. The NPA suggests that every member of the pharmacy team should be competent to undertake their specific role and is not in agreement with the GPhC proposal that unregistered pharmacy staff must have the knowledge and skills of the relevant units of nationally recognised level 2 qualifications or training towards it. For a course to comply with the nationally recognised level 2 qualification, additional costs would be incurred which would in turn be transferred to pharmacy owners. The NPA asks as to the necessity and relevance of this. Currently, the NPA has four GPhC accredited courses which are equivalent to Level 2, and are deemed by the regulator to meet the minimum standards required to undertake the various support roles. Furthermore, there appears to be a lack of definition of a nationally recognised level 2. In addition, should this particular training course not have undergone the GPhC accreditation, but be accredited by another educational body, having the pharmacy regulator involved would provide an increased assurance and confidence of its application and relevance to the pharmacy sector. NPA response to the GPhC consultation on guidance to ensure a safe and effective pharmacy team Page 8
5. Do you agree with our proposed approach? No. The NPA is in agreement with the GPhC proposal that all unregistered staff who need further education and training be enrolled on an appropriate training programme, however, would suggest that within three months of starting their role would be a challenging timescale. A new member of staff would need to undergo a specific company induction period which is normally three months. Pharmacy owners and NPA members would prefer to invest in new courses for staff, safe in the understanding that the individual is fully inducted into the company and role with firm foundations. The NPA also suggests that this be only started following completion of a structured and robust induction. The NPA is concerned however, that in the absence of accredited courses, there is no longer the assurance of the standards of the course. 6. What impact do you think the proposals will have on pharmacy owners? In instances that the pharmacy owner is a pharmacist, there would be no impact, as this would be aligned to the current policy. However, if it is a non-pharmacist owner, than it would be of high impact. 7. What impact do you think the proposals will have on pharmacy professionals? These proposals will have a mostly negative impact on pharmacists, due to the lack of clarity leading to a raft of training courses available to choose from, without any guidance, relevance or standardisation to the pharmacy profession and pharmacy services. These proposals will also have a partly positive impact on pharmacists, if this proposal leads to a partnership approach between the pharmacy owner and pharmacist. However, these proposals may also lead to a distant relationship between the two, in which case it would not be entirely positive. 8. What impact do you think the proposals will have on unregistered pharmacy staff? Mostly negative. These proposals would lead to a variance in training which could lead to very specific training of relevant units but not overall training for that role. For example, in the training for dispensing of products, it may have robust training on the technical elements, but not as much relating to communication skills and building relationships. Currently unregistered staff are able to move onto their career pathway across different pharmacy sectors in the knowledge and assurance that all training packages are accredited and standardised. This will no longer be the case as a result of these proposals. NPA response to the GPhC consultation on guidance to ensure a safe and effective pharmacy team Page 9
9. What impact do you think the proposals will have on people using pharmacy services? Negative impact., Due to the lack of standardisation in training packages. This in turn would lead to variance in service delivery. 10. Do you have any other comments? It is difficult to gauge the full impact that these proposals will have on pharmacy owners, pharmacists and pharmacy technicians and unregistered pharmacy staff, as there is still a need for further clarification on a number of points. 11. Do you think the proposals might have an impact on certain individuals or groups who share any of the protected characteristics? These proposals will have an impact on students with special learning requirements or students requiring reasonable adjustments. Currently, the NPA follows a standard operating procedure that uses the GPhC accredited courses as the standard to determine how the reasonable adjustments are to be set out. In the absence of training courses no longer being accredited, variance could be introduced. NPA response to the GPhC consultation on guidance to ensure a safe and effective pharmacy team Page 10