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Freedom to speak up – the impact of NHS England whistleblowing guidance on community pharmacy

22 June 2017

We know that health professionals being open and honest when things go wrong is one of the best ways to protect patients. A culture of openness in the NHS, and across healthcare in general, is critical to improving safety and ensuring there is less emphasis on blame and more focus on speaking up and learning.

As part of this work NHS England published Freedom to speak up in Primary Care - Guidance to primary care providers on supporting whistleblowing in the NHS, on 1 November 2016.

The guidance is for all providers of NHS primary care services in England, including community pharmacies. It details the principles and actions to apply in primary care to support the raising of concerns by staff about the delivery of primary care services to patients and the management of the concern raised.

What this means for pharmacy

Pharmacy professionals and pharmacy owners will be aware of the importance of raising concerns, and ensuring the right culture exists to raise concerns, as set out in our guidance. Our standards for pharmacy professionals also set out, under standard 8, that pharmacy professionals must speak up when they have concerns or when things go wrong. Our standards for registered pharmacies include a provision to ensure staff are empowered to provide feedback and raise concerns about meeting these standards and other aspects of pharmacy services.

Pharmacy contractors will already have whistleblowing policies in place as part of their compliance with the terms of the Community Pharmacy Contractual Framework. Building on this the NHS England guidance expects contractors to review and update their whistleblowing policies and procedures by September 2017.

A central part of NHS England’s requirements is for every primary care provider to identify a named individual as a ‘Freedom to Speak Up Guardian’ who can ensure that policies are in place and that staff know who to contact if they have a concern.

The policy states:

Each NHS primary care provider should name an individual who is independent of the line management chain and is not the direct employer as the Freedom to Speak Up Guardian, who can ensure that policies are in place and that staff know who to contact if they have a concern.

A key question is who to appoint as the Freedom to Speak Up Guardian. Examples from NHS England include a member of the local clinical commissioning group or a professional network. These are likely to bring a degree of professionalism and independence. NHS England’s guidance notes that there are a range of way to appoint a Freedom to Speak Up Guardian, including:

  • an arrangement with another local primary care provider, or with the local hospital trust Freedom to Speak Up Guardian
  • an assigned staff role within a larger provider federation/network
  • a nominated member of the local Clinical Commissioning Group (CCG), the Local Professional Network (LPN), or the Local Pharmaceutical Committee (LPC)
  • NHS England Responsible Officers

Whoever is appointed, it is important that staff have faith in their confidentiality and independence. NHS England will work with CCGs, LPNs and Local Representative Committees to support local nominations.

What to think about

The GPhC supports this important element that continues the work to make raising concerns and speaking up a normal part of working life, and this should in particular improve how those who raise concerns are treated. As well as ensuring staff know how to and where to raise concerns, staff should feel entirely confident that their concerns will be listened to and acted upon as necessary and, most significantly, that they will not experience any detriment for having raised their concerns.

Pharmacy contractors in England should take this opportunity to:

  • review local policies and procedures to ensure they align with the new policy and guidance
  • identify an appropriate Freedom to Speak Up Guardian
  • discuss any changes to policy and procedures with staff

Further information

Further information on speaking up about concerns is available from:

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