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30 May 2019

We often hear that the way pharmacy services are delivered will change significantly over the next five to ten years - but the pace of change was really brought home to me when I looked through the information about our proposed guidance on prescribing. Since 2016, the number of independent prescribers on our register has gone up by over 4,000 - which is more than double.

Although this is just a number, behind it are many pharmacy professionals taking on different job roles, working in multidisciplinary teams, in a greater variety of settings, and using new technology.

We want to make sure that we understand these changes and are able to respond to them - focusing more on proactively anticipating and responding to issues, and tailoring our responses to get results in the best and quickest way. To do this, we have begun work on a longer-term, ten-year vision and strategy.

As a first step, we need to understand more about how pharmacy professionals work now. To do this, we have commissioned Enventure, an independent research company to ask you to complete a survey about your role as a pharmacy professional as it is today.

This is the first time we have gathered data about the roles and responsibilities of pharmacists and pharmacy technicians since 2013, and we’re interested to see what has changed, and what hasn’t – we’re keen to share the results with you.

We want to get the most out of the information you give us, so we will also be sharing the same anonymised data we receive with other organisations who are responsible for workforce planning in all three countries of Great Britain.

I hope you’ll look out for an email survey invite in the coming weeks.  Your information will help us understand what pharmacy looks like now, and provide a sound basis for our future strategy.

21 March 2019

As an organisation, we are committed to promoting equality, valuing diversity and being inclusive in all of our work.

And this commitment is not just to make sure that we are meeting our duties under the Equality Act 2010. It is because we strongly believe that every action we take, every decision we make, should be fair and inclusive to everyone, and we should make sure we are eliminating discrimination in every area of our work.

Our clear aim is to build equality, diversity and inclusion into everything we do. For this to be effective we need to be continuously challenging ourselves to look at our processes and to evaluate the information about how they are working.

One key area of our work is the fitness to practice (FtP) process. Although a very small proportion of pharmacists and pharmacy technicians are ever involved in the fitness to practise process, it can have a significant impact on them. It’s important to do everything that we can to make sure that the process is robust and fair for all involved, starting with how and why concerns are raised with us.

We have previously looked at our data and shared high-level reports on fitness to practise and equality and diversity. These show some trends that we need to do more to understand, including that Black, Asian and minority ethnic (BAME) pharmacists are more likely to have fitness to practise concerns raised about them than White pharmacists.

We already use a variety of mechanisms to assure good decision making, including eliminating discrimination from decisions.  This includes unconscious bias training for decision-makers and using decision-making guidance at each stage of the process for both our investigative staff and independent panels. We also quality assure our decisions, both during the investigation and after the final decision.

This coming year we are planning to review and update our strategic approach to equality, diversity and inclusion, looking across all our regulatory work (not only Fitness to Practise) to see what further opportunities there are to use regulation actively to promote this agenda, as well as continuing to eliminate any scope for discriminatory decision-making. We expect this review to include building our understanding of what the data are telling us and to look at practical measures such as the role of inspection in promoting equality and eliminating discrimination in pharmacy services, as well as considering the possibility of extending anonymised decision-making within the GPhC.

We will share the results of this work and keep you posted, as well as asking for your help and engagement.

17 January 2019

You will have seen that last week, the Prime Minister launched the NHS Long Term Plan in England. This document, put together by NHS England and NHS Improvement following a consultation with the sector, provides a vision for the NHS in England over the coming decade. It emphasises clear role for pharmacy professionals as part of NHS multi-disciplinary teams. The Scottish and Welsh Governments have also previously underlined the importance of strengthening the role of the pharmacy team through their national strategies, including ‘Achieving excellence in pharmaceutical care’, and ‘A healthier Wales’ respectively.

Revising the standards of initial education and training for pharmacists

The role of pharmacists continues to evolve at pace in response to changes in the sector and in pharmacy practice. Every day we see the vital role that pharmacies play in delivering care and in helping people to maintain and improve their health and wellbeing. As it is for other healthcare professionals, the pharmacist’s role is a flexible one and varies between settings and sectors. Whatever the circumstances, pharmacists are experts in medicines. The role’s flexibility means that pharmacists can work in registered pharmacies; in primary, secondary and tertiary care; in nonhealthcare settings; or in combinations of these.

Importantly therefore, initial education and training also needs to evolve to reflect these changes so that pharmacists are equipped with the skills they need to develop new services. The standards of initial education and training we set for pharmacists are vital in making sure that pharmacists are appropriately prepared to deliver pharmacy services and improve them. The initial education and training of pharmacists must give them the necessary knowledge, attitudes and behaviours to successfully take on their roles and provide safe and effective care for the people using their services.

On 9 January, we launched a landmark consultation to modernise the initial education and training of pharmacists. Our proposals seek to give pharmacists the knowledge, attitudes and behaviours they will need to be prepared for future practice.

We recognise that our proposals may present a number of challenges for course providers, employers, commissioners and students, and may involve some difficult decisions. But we also believe it is the right time for us all to think innovatively about how education and training needs to change so that the pharmacists of the future are fully equipped for the roles they will need to play.

15 November 2018

Pharmacists and pharmacy technicians are often the last health professionals that patients will see before they take their medicines. 

As such, the conversations that patients and the public have with pharmacy professionals during these interactions help patients make informed decisions so they can manage their treatment and care in the best way for them.

In order to safely and effectively undertake the role, it is fundamental that professionals keep up to date with the right skills, knowledge and behaviours required of them. This also means ensuring that the right procedures are in place and are followed. 

In this issue we look at the safe and effective supply of medicines in practice. In our ‘focus on’ article we have outlined a case study around the drug sodium valproate. As you know the consequences of dispensing this drug without following the set procedures could be serious, so please do take a look and re-familiarise yourself with the requirements when dispensing.

We know many of you are currently playing a critical role in making sure people are receiving the flu vaccine. In this issue, we are also encouraging all of you to protect yourself, your patients, your colleagues and family by making sure you also get the flu vaccine. By protecting yourself, you reduce the risk of spreading flu to patients and your family and of disruption to your services.
 

27 September 2018

In 2016 I told you about my New Year’s resolution to start using social media. Half the world now has a social media account in some form, and we know it has advantages. It can be an extremely useful way to speak directly to people you would never otherwise have access to, learning and listening, discussing and developing new ideas.

We have also seen some very positive benefits for patients through social media. The #HelloMyNameIs campaign for example, launched by Dr Kate Granger MBE as she fought and sadly lost a battle with cancer, asks all health professionals to introduce themselves by name before speaking with those in their care. This simple campaign has been taken up widely across the NHS and beyond, winning awards for its compassion and effectiveness for patients. 
Unfortunately, as I said in my 2016 post, despite the many and varying positives of social media, there are some decidedly unsocial trends flourishing. It seems online forums are used too often to bully, ridicule or embarrass, rather than inform and enlighten. Perhaps because we can upload our thoughts at the touch of a few buttons, we do so unthinkingly, without fully considering the consequences. It can give a megaphone to words that should only be said in private, if at all.

For me personally, social media was not something I wanted to continue with after my first dalliance. However, we do use social media regularly and positively at the GPhC. For instance, we tweet from our Council meetings to keep you updated, respond to questions and queries and provide links to our latest consultations and events through our social media channels.

We know that many of you are also using social media in both your personal and professional lives. We would encourage everyone to look again at the guidance we published on Demonstrating professionalism online in 2016,  which offers practical advice to help you use social media successfully and to continue to meet the standards we set:

Do:

  • act professionally
  • treat people with respect
  • maintain confidentiality and privacy at all times
  • maintain proper professional boundaries
  • think before you post, privacy settings do not mean that something will remain private and a statement that these are your own views means little in practice

Don’t:

  • bully, harass or intimidate
  • unlawfully discriminate
  • post inappropriate comments
  • share information about patients or their care
  • get drawn into negative, unconstructive discussions

We thought it may also be useful to have the perspective of someone working in the health world who themselves uses social media successfully within their role.  And so in this edition’s ‘focus on’ article, we asked Shaun Lintern, the Patient Safety Correspondent at the Health Service Journal and a regular user of social media, to give his advice on how to get the best of social media, and steer away from that less inclusive side. 
In this edition we are also outlining some important information about revalidation - so do take a look, and we are highlighting an exciting opportunity for three registrants to become members of our Council. We know it’s so easy to think this type of position isn’t for you, but believe me when I say that you should genuinely consider it. To help you decide, two of our current Council members have outlined what they think of the role and their experiences so far. We want to hear from both pharmacy technicians and pharmacists across Great Britain, so if you are looking for a new challenge and have the skills and experiences outlined on our website, we look forward to seeing your application. 
 

19 July 2018

New ways of delivering health care, using advances in technology, have the potential to improve accessibility and convenience for patients. But they can also carry particular risks which need to be successfully managed.

We are seeing a growing number of providers offering online primary care services, including online pharmacy services, using a range of different online technologies and offering a range of different services.

We have always said that we encourage responsible innovation that may benefit patients, but are also clear about our responsibility to protect people who want to use pharmacy services. This means understanding potential risks and taking action to help make sure these risks are mitigated as far as possible.

Why are more safeguards needed?

Regulating healthcare services on the internet is complex, with different organisations and agencies responsible for different parts of the service. We have been working closely with other regulators in Great Britain involved in regulating online prescribing services to help make sure patients receive safe and effective care at each stage, from when they first visit an online primary care service to when they receive their medicines from a pharmacy.

But we are aware of situations where patients have been put at risk because of the inappropriate prescribing, sale and supply of medicines on the internet. This includes through concerns raised with us and through our work with other regulators.

As an example, the CQC’s recent report, The state of care in independent online primary care services, sets out their findings from their first full programme of inspections of primary health care provided online.  This highlights significant concerns around patient safety, including around safeguarding and inappropriate prescribing.

We have become increasingly concerned about the way some primary care services appear to undermine the important safeguards that are in place to protect patients from accessing medicines that are not clinically appropriate for them. It sometimes appears to be too easy for people to obtain prescription-only medicines; someone can obtain a prescription-only medicine with just a few clicks on the screen, answering a short online questionnaire and submitting some credit card details. But medicines are not ordinary items of commerce and must not be treated as such.

We therefore want to play our part in strengthening the safeguards in place for patients and the public trying to obtain medicines online through the guidance we set for pharmacy owners and through our inspections of online pharmacy services.

In 2015, we published guidance which sets out what is expected of pharmacy owners who provide pharmacy services at a distance, including on the internet. We think that the time is right to update this and are proposing to strengthen the guidance.

We want to hear people’s views on these proposals, to make sure we have addressed all the key issues in this rapidly changing area. I’ve set out the key points below, and how you can help shape the final guidance.

What are we proposing?

We plan to include the following points in our updated guidance:

  1. Transparency and patient choice
    We are proposing to set out what information the pharmacy should give people about the online primary care services being offered, and who is providing them, so people can make an informed decision about where to obtain medicines and other services.
  2. Making sure medicines are clinically appropriate for patients
    We are seeking views about whether it is appropriate for pharmacy websites to allow patients to choose a prescription-only medicine, and its quantity, before having a consultation with a prescriber. We want to know the potential benefits and risks of patients being able to do this.
  3. Further safeguards for certain categories of prescription only medicines
    We are proposing that certain categories of medicines, including antimicrobials (antibiotics) and opiates/ sedatives, may not be suitable to be prescribed and supplied online unless further action is taken to make sure that they are clinically appropriate for the patient, such as contacting the patient’s GP. We would make clear that it is not appropriate for pharmacy owners to work with prescribing services unless they are assured that the safeguards we’ve identified are in place.
  4. Regulatory oversight
    It is not appropriate for pharmacy owners to work with online prescribing providers who may try to deliberately bypass the regulatory oversight which aims to ensure patient safety throughout the healthcare system. We raise concerns in the paper about potential additional risks to patients if pharmacy owners decide to work with prescribers or prescribing services operating outside the UK. We plan to make it clear that if a pharmacy owner decides to work with prescribers or prescribing services operating lawfully outside the UK, we expect the pharmacy owner to manage the additional risks this creates.

You can find the full details of our proposals in our discussion paper. Please read it and then let us know your views by responding to our survey.

17 May 2018

A vital component for delivering professional, safe and effective care is the environment in which health professionals operate. Strengthening the regulation of the places in which they work is therefore a critical part of assuring and improving care.

I want to talk about some of the work we are undertaking to strengthen our regulation of registered pharmacies. This includes a new major consultation, and new guidance for pharmacy owners on ensuring a safe and effective pharmacy team.

Developing our approach

Today (17 May 2018) we launched a major consultation on how we are planning to develop our approach to regulating registered pharmacies. This includes publishing inspection reports for the first time. These proposals, if taken forward, would significantly change how we regulate pharmacies., We want to hear from you about our proposed approach to make sure we are getting it right.  We also want to know what you think the impact will be for pharmacy owners, the pharmacy team and, most importantly, the people using pharmacy services.

Over the last five years we have made significant strides in how we regulate registered pharmacies. The independent evaluation we commissioned and the feedback we have received suggest our approach is working well.  Since we introduced the new approach to inspections in 2013, we have inspected around 13,000 registered pharmacies across Great Britain and expect to have inspected every registered pharmacy in Great Britain by the summer.  And we have found that the vast majority of pharmacies (85%) were meeting all of the standards we set.

It is now time to reflect upon and improve our current approach. As a regulator we want to move to a more flexible and agile way of working, so that we can more effectively respond to the changing needs of patients and the public and to changes in pharmacy.  We will also soon have new legal powers, including powers to publish inspection reports.

We aim to strengthen the assurance we provide to the public that pharmacies are meeting standards and will help to drive continuous improvement in the quality of pharmacy services and care. As part of this, our new approach will increasingly use information and intelligence, using our data and insight to effectively target our resources where they can have the most impact.

You can read about our proposals in this Regulate article

And then please don’t miss your opportunity to respond to the consultation and help to shape the final proposals- you can respond here to our online survey 

New guidance for pharmacy owners

You may recall we consulted last year on new guidance for pharmacy owners. This outlines what they are expected to do to make sure everyone in the pharmacy team can provide safe and effective services to patients and the public.

We received a lot of very helpful feedback through the consultation, which our Council has discussed in detail at its recent meetings.

In the consultation, we had proposed some changes to the regulatory framework for unregistered members of the pharmacy team.  After carefully considering the feedback, we have decided further work is needed in this area before we make any final decisions. This will be taken forward as part of our ongoing programme of reviewing the standards of education and training for the pharmacy team.

Another key theme in the feedback related to staffing in registered pharmacies, and in response we have added a new section in the guidance about what pharmacy owners should do to make sure there are enough staff, suitably qualified and skilled, to provide pharmacy services safely and effectively.

At our May Council meeting last week, our Council agreed that we can shortly publish this new guidance, once a few final changes are made.  Please look out for this guidance, which we expect to publish next month, and consider what it means for you in your role and for those you work with.

15 February 2018

The legal framework governing the UK’s health professions regulatory bodies needs reform. That is the clear message we gave to the Department of Health and Social Care recently, in our response to their consultation about reforming the regulation of health professionals. 

The government’s consultation provides the opportunity to identify how regulation needs to change so it works as well as possible for patients and the public, and effectively supports the professionalism of all health professionals. And we hope this consultation will lead to positive reforms.

In our response, we made the case that we need to change the way we regulate to improve protection and assurance for patients and the public, and better support the professionalism of all health professionals.

 Health and social care has changed considerably to meet the changing needs of the population, and it will continue to change. Regulation must change too to match that.

Changing the legal framework

Regulation is most effective at ensuring safe and effective care when it has a wide range of flexible regulatory tools that can be used to provide assurance and help to promote improvement.  We are seeking changes to our legal framework, which governs how we work, to improve our ability to regulate effectively, and to give us the flexibility we need to be able to respond effectively to external changes. 

In return we need to be held to account. We would gladly, and indeed should, provide more assurances to the Parliaments and Assemblies across Great Britain to whom we are accountable, to ensure there are checks and balances over our decisions and actions.

We are conscious that this consultation has taken place at a time when there are many other demands on government and on the parliamentary time needed to legislate for the changes proposed, and so none of us yet know what will happen following this consultation. More importantly, we also appreciate that the consultation has taken place at a time when everyone in pharmacy, and in healthcare generally, is exceptionally busy caring for their patients in a rapidly changing and uncertain environment.

Number of regulators

What hit the headlines in relation to this consultation was the proposal that there should be fewer regulators, and that some of the existing regulators should be merged. We think it is right that this debate is had, and we have an open mind about this issue.

The number and configuration of regulators is of course ultimately a decision for governments. In our response we argue that the contextual understanding of professions, where and how they work must not be lost. We all need to probe the evidence base for changing the number of regulators and explore whether any particular proposals would lead to better outcomes for patients and the public, which is the important thing.

Supporting professionalism

We welcome the clear focus within the consultation on supporting professionalism. We have long said that regulation is more than enshrining and enforcing minimum standards. Our focus should be on promoting and supporting professionalism because it enhances patient safety and quality of care.

As part of that, we need to make sure that the environments in which health professionals work enable them to meet professional standards. This consultation focuses on reforms to regulation of health professionals, but in our response we say there should also be a debate about our powers to regulate registered pharmacies. As the regulator of both pharmacy professionals and registered pharmacies, we believe the environments in which health professionals work are critical to the context for delivering professional, safe and effective care. Strengthening the regulation of both the professionals and the places in which they work is therefore a critical part of assuring and improving care.

Having a debate about this is particularly important at a time when there is increasing focus on how the environments in which health professionals are working could affect patient safety. Both in pharmacy, and in other areas of healthcare, professionals are raising concerns that the environments in which they are working are affecting their ability to provide safe and effective care.

Most recently, the case of Dr Bawa-Garba has raised a number of concerns among health professionals. These include concerns about how their regulator, and the courts, may respond when they make errors when working in often very challenging environments.

This is a difficult and tragic case and we will be considering any implications with others. We will actively engage with the rapid review commissioned by the Secretary of State and led by Professor Norman Williams, and carefully consider all of the outcomes of that review.

I would encourage you to read the statement we’ve issued in response to the issues raised in this case. And I would strongly urge you to continue to report errors and take part in processes to learn from errors. It is undoubtedly difficult to speak up when things go wrong, but it is vital for patient safety that errors are reported and discussed.

And I want to make clear that this responsibility lies with all of us. As the regulator, we will work hard to promote a culture of openness, honesty and learning across pharmacy, and we will be urging everyone who employs pharmacy professionals to do the same.

13 December 2017

It is rare to see agreement across all of the political parties, particularly in the current climate, but that is exactly what we saw when the Dispensing Errors (Registered Pharmacies) Order was debated in the House of Commons and House of Lords recently.

It was passed unanimously by MPs, and it was recognised in both Houses that this important change should make a real difference to patient safety, by encouraging reporting of and learning from dispensing errors that occur in registered pharmacies. The parliamentarians speaking in the debates highlighted their confidence that, in response to this change, pharmacy professionals would be more likely to report and learn from dispensing errors in registered pharmacies.

As an organisation, we have advocated for this change for a number of years, and are delighted that the long-awaited legislation to introduce a defence for inadvertent dispensing errors that take place in registered pharmacies has now been approved by Parliament. This change in legislation will remove a barrier to improved reporting and learning from errors and will therefore be beneficial for patient safety. It is also the right thing to do, in fairness to pharmacists and pharmacy technicians, who do so much to  maintain and improve patient safety.

The legislation is now expected to come into effect next year, once the final legislative process is complete. We know it has been a very long wait to get to this point, and we recognise the importance of this change for all pharmacists and pharmacy technicians.

And this includes those working in settings other than registered pharmacies. We understand the government will consult next year on removing the threat of criminal sanctions for dispensing errors made by pharmacists and pharmacy technicians working in settings other than registered pharmacies- and we will continue to urge for this to move forward at the earliest possible opportunity.

While we wait for the law to change, we think there is an opportunity for all of us to focus our attention on what more we can do to learn from errors, to reduce the probability of them happening, and to improve the care people receive.

We know that, thanks to the significant efforts of pharmacists and pharmacy technicians across Great Britain every day, the number of dispensing errors is very small when considered against the number of items dispensed each year.  As Don Berwick, the leading authority on patient safety, said recently in an interview with the PJ; ‘Pharmacy dispensing is safe compared with other areas of healthcare’. 

But we know there is more we can all do to reduce the number of dispensing errors even further, and to make sure that when they happen, we’re all doing everything we can to prevent them happening again. 

We know there are already a number of local and national initiatives across England, Scotland and Wales to reporting and learning, which are making a difference. These include the Community Pharmacy Patient Safety Group, which is driving reporting culture and practice across community pharmacy in England, and sharing learning from patient safety incidents through its networks. In Scotland, the Quality Improvement in Pharmacy Practice Collaborative has brought together key organisations including HIS, RPS, NES , CPS, NHS Boards and the Alliance to help embed continuous quality improvement in pharmacy services and share learning across Scotland. And in Wales, the Error Reporting Task and Finish Group has been working to improve error reporting and promote an open culture within pharmacy, by simplifying and raising awareness of the reporting system, and working with employers and stakeholders to promote reporting and share learning. 

But there’s more we can all do- including the GPhC. We all have to live up to the expectations expressed in the parliamentary debates that this change in the law will make a real difference in reporting and learning.

For our part, we will be considering how we can better use and share the information we receive about dispensing errors to support learning, reduce risks and improve patient outcomes.

And we would encourage each of you to reflect on how to live up to the expectations of openness and honesty set out in the standards for pharmacy professionals whenever errors occur.

We recognise that the possibility of action by the regulator can also deter people from reporting errors- and so I want to emphasise again that single dispensing errors would not in our view constitute a fitness to practise concern, unless there were aggravating factors. 

One of our inspectors, Colette, sums up our approach in the ‘focus on’ article about dispensing errors; “my main concerns when investigating a dispensing error are firstly to try to find out how the error may have happened, and secondly to understand what learning points or preventative actions have been taken (or are needed) to avoid a similar event happening again.”

I know that it is never easy to admit a mistake, but to err is human, and we, like you, want to learn from each error, for the benefit of patients and the public.

19 October 2017

We have just published the report on our consultation on revalidation. Over 1850 written responses were submitted, and more than 2400 individuals participated in over 40 separate events across Great Britain. The quality and quantity of feedback and engagement gives us confidence that revalidation for pharmacy is on the right track. 

Revalidation will be an important tool to uphold the public’s confidence that you as pharmacy professionals are maintaining, and continuing to improve, standards of practice.  It is also a demonstration of your commitment to professionalism, assured by a regulatory approach which is flexible and able to address the needs of a changing pharmacy and healthcare environment.  

When our consultation on introducing revalidation was launched earlier this year, it was inevitably met with some uncertainty from the pharmacy sector.  How will the GPhC’s interpretation of revalidation compare with revalidation for other health professions?  What does revalidation mean for CPD in the future?  

One pharmacy trade publication described our proposals as a ‘massive shake-up’ in what pharmacy professionals would need to do to demonstrate that their knowledge and skills remained up-to-date, and although I may not use those exact words, I would certainly agree with the sentiment.

Given the scale of the change being proposed, it has been very encouraging to see the level of support and the positive feedback for our proposals expressed during the consultation:

  • A majority of respondents supported our proposals and offered very positive feedback on key elements, including peer discussion and reflective accounts.   
  • They agreed that the proposed new framework was an improvement over the current system—which many viewed as essentially a tick-box exercise. 
  • They agreed that the standards, guidance and new requirements were clear and easy to understand; and that they would ensure that pharmacists and pharmacy technicians are continuing to meet the standards for pharmacy professionals.

Although the feedback we received was positive overall, there were some respondents who raised concerns and queries about the new revalidation process.

While most approved of increased structure and robustness of the proposed system, others commented that the proposal was not robust enough.  It is much to the credit of the profession that some suggested they wanted a tougher, more rigorous approach, but we are conscious of the fact that we need an approach that works well for pharmacy professionals in a range of roles and settings.

There was also clear recognition from most that the addition of peer discussion and the reflective account—key components of the proposed framework—would be beneficial for professional development. 

Some respondents, however, raised concerns about what they saw as a lack of quality assurance regarding the choice of peer, the content and quality of the discussions.  In particular, some respondents were concerned that some members of the professions may find it challenging to find an appropriate person to discuss their professional practice with. A number of respondents felt that it could become a tick box exercise rather than a valuable discussion on professional practice.

As many of our pilot volunteers highlighted, they were already having peer discussions—including with colleagues and through association with professional membership bodies; and they told us that the insights and advice they received helped to improve their practice.  In anticipation of the roll-out of revalidation, in recent weeks, a number of professional bodies have begun to highlight the resources they offer to pharmacists and pharmacy technicians to connect with an appropriate peer to start these conversations.

Another key component, the move to annual submission of records instead of the current requirement for records to be called on a five-yearly basis, also had broad agreement. It was felt that annual submission would help to embed CPD and reflection into day-to-day practice, and would ensure records are completed in a timely manner.

But some respondents commented that submission of all records at the same time as renewal could become burdensome, and a small number of respondents disagreed with the move to annual submission, citing this as being too onerous and out of line with other healthcare professionals who undergo revalidation on three-yearly or five-yearly cycles.

One of the things we are reflecting on is the impression given by some of the feedback that some people feel revalidation is being imposed on them.  What we ultimately want to achieve is that everyone views revalidation as a positive opportunity to reflect on and improve their practice, for the benefit of their patients; so you are driving it, and it’s what you do and bring to revalidation that makes the difference to you and to your patients.

Revalidation is not about the regulator assessing individuals and identifying ‘bad’ performers, and removing them from the register.  It’s about the assurance which you give to your patients, the wider public and your professional colleagues, through your commitment to ongoing professional development and improvement in your practice.

Moreover, the basis of the new model is engagement. The evidence we have developed and evidence from other health professions shows that when professionals are engaged in and reflective of their practice, it can often drive improvement.  

All of the feedback we’ve had is hugely valuable as we work to finalise and introduce our proposals; we are reflecting carefully on everything we heard through the consultation and are considering if any changes need to be made to the approach before submitting our final proposal to our governing council for approval. We’re also planning what further guidance and support we, and other organisations, could provide to support pharmacy professionals with revalidation.

And as we take another important step forward in the development of revalidation, I want to thank those of you who have contributed in some way to our progress to date—perhaps by participating in the pilot or taking part in the consultation.    

I want to invite you all to continue to work with us going forward, and to continue to let us know what you think as we move forward to develop the best possible framework for revalidation of pharmacy professionals.

You can read the full report on our consultation on revalidation on our website