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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

16 August 2017

Person-centred care sits at the heart of our standards for pharmacy professionals, and should sit at the heart of pharmacy practice. When we talk about ‘person-centred care’, it is inevitable that our first thoughts focus on the person receiving care. But we know that person-centred care can also make an enormous difference to the carers and loved ones supporting them.

I recently read a moving account from the Very Reverend Martyn Percy, Dean of Christ Church in Oxford, about how interactions with his local pharmacists affected him as he cared for, and subsequently lost, a loved one battling cancer. It’s a poignant and eloquent reflection on how person-centred care from a pharmacy professional affected him in his grief.

Some of you will know that in December 2016 we lost Emma’s brother to cancer.  Chaz was 49, and had been living with Emma and myself for several months, as he could no longer live independently.  We were ably, exceptionally and kindly supported by staff here in the House, and in the last week of his life by Sobell House.  Indeed, I particularly want to pay tribute to the care and support from all the staff of the House during this time:  it was exceptional, tender and kind.

In between my brother-in-law coming to live with us and his end, part of my fortnightly routine had been to take him to the doctors, and also do the weekly run to the pharmacy for the morphine and other drugs.  We would walk up to Beaumont Street for the regular appointments, and call in to Boswell’s pharmacy department on the way home.  So after Chaz had passed away, I returned to the pharmacy with a card and some chocolates and a large quantity of un-used drugs that could have sold very well on the black market.  (I jest, I hasten to add).  The gifts for the pharmacy staff were a simple ‘thank you’ to Anna and Alison, the two pharmacists who had worked so hard on the dosette boxes of medication, and patiently measured out each day’s drugs:  fiddly, mundane work that requires concentration and precision.  But they had always done it with such cheerfulness, and on the days I had sometimes taken Chaz with me, they were always so good to him too.

So I plonked my shopping bag of drugs on the countertop of the pharmacy, conveyed our thanks for all they had done, and handed over the chocolates.  We chatted for a while, and I was about to take my leave when they said ‘wait there please – don’t move’.  And then they came out from behind the counter, and warmly embraced me – a hold of deep knowing, acknowledgement and consoling.   So there the three of us embraced in the middle of Boswell’s pharmacy.  We probably made quite a sight; a most unusual trinity.

(Reproduced with the kind permission of the Very Reverend Martyn Percy from ‘Untamed Gospel’, Canterbury Press)

Mr Percy’s reflections are obviously not unique. Every day in Great Britain there are undoubtedly scores of similar examples of pharmacy professionals who not only dispense medicines and advice, but do so with empathy and compassion for both the patients and their carers and loved ones.

And just as patients benefit from the support of their team of carers and loved ones involved in their well-being, the delivery of safe and effective care is enabled and supported by all members of the pharmacy team – including unregistered pharmacy staff. We don’t regulate these individuals, but it is within our remit to ensure that the entire pharmacy team works effectively as an essential part of providing good-quality care.

We recently launched a consultation on new guidance for pharmacy owners to provide greater clarity on this; specifically, the roles and responsibilities when it comes to the pharmacy team. Informed by feedback we received, including in our online workshops on quality in pharmacy, we are proposing to strengthen and assure the regulatory framework for unregistered staff.

In the past, individual pharmacists have been responsible for training staff, including unregistered staff. In the draft guidance, we set out that pharmacy owners will be accountable for ensuring that all staff working in the pharmacy are competent and empowered to provide safe and effective care to people using their services.

The draft guidance also emphasises the importance of staff in managerial or leadership positions, who may or may not be a registered pharmacy professional, understanding that pharmacy professionals must prioritise patient safety over organisational goals.

We know from our online workshop that many of you have strong views on ensuring a safe and effective pharmacy team, so I would encourage you to take our consultation survey and let us know what you think.

I also encourage you to share Martyn Percy’s story with your colleagues – registered and unregistered - and reflect on the patients and the carers you encounter every day who also benefit from the person-centred care you provide.

22 June 2017

There are about five weeks left in our consultation on revalidation, and we have been encouraged by the feedback we are hearing so far both through the consultation survey and in our engagement events.

We have received nearly 1,000 completed consultation surveys, and met with more than 500 pharmacy professionals and members of the public, and it’s clear that there is keen interest in revalidation. That’s a good thing.

But it also seems that some of you are still unsure about what the proposal means for you and how it will affect your practice, which may be causing some trepidation. Such trepidation is almost inevitable when faced with significant change, but we want to do what we can, both during the consultation and beyond, to answer people’s questions and hopefully allay any fears.

Some of the feedback we’ve been hearing has to do with process: “Who is the right person to be my peer and how do I find them?”, or “I don’t work with patients so does this mean I cannot revalidate?”, or “What does this mean for me when I next renew my registration?”. Some of you are thinking about the kind of revalidation required of other health professionals and are asking “How is this comparable with the expectations of doctors, nurses and midwives?”.

I want to take a moment therefore, to (hopefully) demystify our proposal and signpost some of the resources that may help you understand what we’re trying to do in introducing revalidation and, more importantly, how it could benefit you as a professional.

This proposal and the introduction of revalidation represent a significant change in how we relate to you as a regulator, so we need to hear from pharmacists and pharmacy technicians through the consultation survey. Equally important, however, we want your informed feedback to make sure that what we are proposing actually works in practice.

We start from a basic premise: that in order to maintain the standards of practice, it is important for you to be aware of changes in the profession that could impact the care you provide. This goes beyond knowledge and skills, and encompasses the expectations the public and other healthcare professionals may place on you.

You are probably aware that we have already done a great deal of work on this. Over the past three years, we’ve spoken with your colleagues and peers, other members of the profession, and the public about what they expect from pharmacy professionals in terms of the care they provide and, importantly, how to ensure and assure that their knowledge and skills remain up-to-date.

What we heard is that exhaustive record keeping and ‘tick-box’ exercises no longer fit the bill; and that, perhaps, we needed to look at different ways to record activities (and different kinds of activities) in order to show real improvement and provide meaningful reassurance to the public.

The revalidation proposal outlines a scheme that encourages more reflection on your practice and, importantly, on how you are embedding the standards for pharmacy professionals in your work. Among the changes we are proposing: reducing the number of CPD records we require you to submit from nine to four; asking you to conduct and record a peer discussion with a colleague or someone who understands your work; and asking that you write a reflective account detailing how you are meeting one or more of the standards for pharmacy professionals. We are also proposing that, rather than ‘calling’ records periodically for review, we would require them to be submitted annually; but randomly select a small sample (about 2.5 per cent) for review.

Our consultation document explains in detail how we developed the revalidation proposals. The accompanying FAQ answers most questions we have encountered since we started this work three years ago. If you haven’t already done so, I would encourage you to have a thorough read of these documents before completing the consultation survey.

We have also scheduled a webinar for 27 June, which will provide an overview of the consultation and give you another opportunity to weigh in with your views and questions. The webinar will be hosted by Hugh Simpson, our Director of Strategy, and Osama Ammar, who has led this work since we started it three years ago. You can sign up for the webinar here.

Finally, today we are launching a video with testimonials from two of the volunteers from our pilot that ran in 2016. These pharmacy professionals provide a first-person perspective on peer discussions, reflective accounts and, in general, the impact these activities had on their practise.

We appreciate that change can be unsettling but we hope that, through working closely with all those affected, we can make this a positive change for everyone. The changes facing our profession, in the roles of pharmacists and pharmacy technicians; and in the expectations the public has for them, are well underway. It’s important, therefore, that we adapt to this new landscape by changing how we regulate; and that you, as professionals, begin to consider new ways for assuring that the trust the public places in you remains steadfast and underpinned by evidence.

27 April 2017

One of our core responsibilities as a regulator is to ensure that people using pharmacy services remain confident in those services and the professionals who provide them.

I want to talk about two significant steps we are taking to advance this commitment, and to support and promote professionalism.

This week, we have launched a 12-week consultation on revalidation for pharmacy professionals. And on 12 May, our new standards for pharmacy professionals will come into effect.

Both of these programmes of work represent years of research, testing, evaluation and direct collaboration with  pharmacy professionals, members of the public, the pharmacy sector, and other stakeholders. Both are grounded in timeless principles around serving the public, lifelong learning and professional accountability. And both embody our duty to ensure that these timeless principles remain at the core of pharmacy practice – now and in the future – by considering what we can do differently to support and enable you to meet the challenges within healthcare and the expectations of the public.

Standards for pharmacy professionals

On 12 May the new standards for pharmacy professionals will come into effect. All pharmacists and pharmacy technicians will have to meet the new standards from this date.

The new standards have a different look and feel—they’re less prescriptive, having been reduced from 57 to nine, with examples under each one to illustrate how they might apply in practice. The standards rely less on detailed guidance and more on your knowledge, skills and expertise as a health professional.

Our consultation on the standards was one of the largest we have ever held. We heard from more than 2,700 registrants, stakeholders, professional bodies and members of the public who told us what they felt was important in delivering high-quality, person-centred care.

There is a greater emphasis on person-centred care and prioritising the needs of patients. There is an updated and clear articulation of our expectations around leadership, and how they apply to the entire pharmacy team (not just those with management responsibilities). And building on a long-held commitment to openness, there is a focus on candour and acknowledging mistakes; as well as greater accountability to yourself and your patients.

Beyond a list of ‘dos and don’ts’, the new standards also have more flexibility in supporting and enabling professionalism, but they are only as effective as their application and how well they are embedded in every day practice.  They can inform professional decision-making and can serve as a springboard to get professionals to discuss professionalism with their colleagues. They can be used as a yardstick against which to reflect on your own practice, as well as how your teams are measuring up. These standards will also be the benchmark against which you will be asked to provide evidence in relation to revalidation.

The standards underscore the importance of individual responsibility for pharmacy professionals, but it is important that employers recognise that they, too, have a responsibility to enable and support the registrants working for them by providing an environment where professionalism can flourish.

Employers should ensure that they and their entire pharmacy team are familiar with the new standards and discuss how to better support them in this regard.  They should reflect on how their existing policies and procedures may support – or undermine – a pharmacist or pharmacy technician’s ability to comply with the standards and demonstrate professionalism.

Others also have a stake in the standards.  We expect that professional bodies will take the opportunity to reflect on how they can support their members and supporters in understanding, applying and embedding them.  Those involved in education and training will look to align their curricula with the standards so their students and trainees can reflect on what they will mean in practice.  And we will encourage patient groups and other stakeholders to help us spread the word about the new standards and what people using pharmacy services can and should expect from pharmacy professionals.

Revalidation for pharmacy professionals

After more than three years of work, including two online workshops that generated more than 3,700 responses and ideas, and a pilot project with more than 1,300 volunteers, we have launched our consultation on revalidation for pharmacy professionals.

Although the consultation revolves largely around process – reducing the number of records, changing the timing of submission of those records and changing the review process – it represents an essential shift in our approach to the way you will be asked to demonstrate how you are keeping your knowledge and skills up-to-date.  

What we are proposing reflects what people – both pharmacy professionals and people using their services – have told us they want and expect from a new framework.

We are asking you to go beyond just recording activities and outputs, which many feel has become rote, toward activities that will draw out not only what you have done to increase your knowledge and skills, but also ask, ‘so what’? What has been the impact on your practice? How has it has improved the care you have been able to provide? What are the outcomes for people using the services you provide?

We are proposing to modify and simplify our requirements for CPD to create space for two new activities – peer discussion and a reflective account. The evidence we have collected from our own efforts and from reviewing the revalidation schemes of other health professions suggests that these two activities are especially potent in improving the quality of care you provide to your patients and in your own professional confidence and satisfaction.

Engagement with other colleagues through peer discussion to obtain feedback, reflect on practice and share new ideas is crucial if we are jointly to meet the expectations of the people using pharmacy services. Likewise, taking the time to think about the standards, and articulating, through a reflective account, how you are meeting them in your practice, helps demonstrate how the essentials of safe and effective practice remain at the core of how you work.

With both of these initiatives, we hope to reduce the sense of professional isolation that many pharmacy professionals have reported to us. We all need peers. We all need feedback. We all need to reflect. Engagement and reflection on your practice, and how you’re doing and what you can do better are essential components of the professionalism that every pharmacy professional should embrace.

Supporting professionalism

Introducing the new standards, and our proposals for revalidation for pharmacy professionals, represents two important milestones as we work to support and improve the delivery of safe, effective care and uphold trust in pharmacy. The evidence-based approach underpinning these important initiatives also reflects our approach to regulation, and I believe will enable us to support professionalism in a way that is effective and efficient and, ultimately, will lead to improved outcomes for people using pharmacy services.

But our work – and yours – isn’t over.   Now is the time for you to consider the new standards; what they mean to you and your colleagues and the services and care you provide. We will soon roll out a programme of activities and resources – including a new app – to help you engage with the standards and embed them in your practice.  We hope you will take advantage of these resources to help you understand and apply the new standards with confidence.

We would also encourage you to respond to our revalidation consultation. The participation of registrants and others as we have developed our proposals has been invaluable, but we still need to hear from you and others who will be directly impacted by the plan to find out if we’ve got it right.

Read more about the standards for pharmacy professionals coming into effect

Read more about the revalidation consultation

23 February 2017

What does quality mean to you? If asked, most of us could come up with a definition of ‘quality’.But quality can mean different things to different people and articulating the methods by which quality is achieved and maintained is not easy.

We see assuring and encouraging quality improvement in pharmacy as an essential part of our role. In our observation one of the things that the profession and the sector might find it useful to work on is developing a more consistent shared understanding of what quality in pharmacy practice means.

We wanted to start a new conversation with pharmacy about three broad elements of quality: safety, effectiveness, and patient experience. The three elements of quality have been talked about in the NHS for many years, and we wanted to understand more about what they mean to people working in pharmacy.

There are growing expectations on everyone working within health and care, including pharmacy, to deliver better-quality outcomes to patients and the public. Governments across Great Britain have made it clear that if the NHS and the wider health and care sector are to meet the challenges we face – such as an aging population, growing costs of healthcare and public health challenges – pharmacy will have to operate differently.

Operating differently is in part about the types of services that pharmacy delivers. It is also about the pharmacy workforce – particularly, as we have heard over the last year, a workforce that feels that professionalism is under pressure. But most important, we believe that it is about an increased focus on quality.

We want to build a greater, shared understanding of what enables quality in pharmacy, and what gets in the way. We have a part to play, as the regulator, in providing assurance to patients and the public about the quality of services they receive and encouraging improvement in quality in pharmacy. Pharmacy organisations and leadership bodies have a role; so too do educators and employers within and outside the NHS. And pharmacy professionals can make the biggest contribution in improving the quality of the services they provide.

In January, we launched an online workshop and asked pharmacy professionals and other stakeholders how they define quality in pharmacy practice.  

By having this conversation, we wanted to broaden our understanding of people’s views of quality, and hear examples of how quality is being delivered in practice. We also wanted to understand better the difficulties that pharmacy professionals may face in providing good quality services, and the steps that they are taking to overcome these challenges.

Over three weeks, more than 1,000 people participated in the workshop, representing the broad range of pharmacy sectors and areas of practice. They contributed more than 5,000 ideas, comments and votes – three quarters of which were positive, and solution focused.

The conversation was wide ranging, with interesting reflections on the subject of quality, and how people are addressing challenges to quality in their practice. The discussion fell into three key areas: delivering good patient experience, delivering effective services, and delivering safe services.  Here’s a bit of what we heard:

  • On patient experience, discussion unsurprisingly focused on communicating effectively with people using pharmacy services, but there was also significant discussion around the idea of continuous improvement. Respondents identified a wide range of tools and approaches for gathering patient feedback, and discussed the benefits and challenges of involving people in decisions about their care.
  • On effectiveness, the issue of leadership in pharmacy came to the fore, with some discussion focusing on the responsibility of leaders to ensure that pharmacies are resourced to meet the demands they face. There was also some discussion about the skills of the pharmacy team, and some practical examples shared about how these can be best used.
  • On safety, there was discussion about the importance of using and following standard operating procedures, but also some honest reflection on the challenges of doing that in practice, and the need to not ‘design out’ professional judgement and decision-making. (A hugely important point closely aligned with the GPhC’s own emphasis on the public benefits of professionalism compared to, say, process.) Participants also talked about raising concerns – how best to go about doing it, and some of the barriers to dealing with problems in practice.

We also heard promising ideas and examples of what is working in practice to enable quality in pharmacy. 

The positive response and practical feedback to our first workshop has been very encouraging. We are now looking forward to our next workshop starting next month, when we’ll delve more deeply into the issues raised. We want to hear from those who have already participated and others too, to discuss their experiences of quality in pharmacy, what enables quality and, critically, what barriers there are.     

We will be reflecting back what we have heard from each workshop in more detail- watch out for updates on our website and social media platforms. Later this year, we will also be sharing our findings with members of the public, to get their take on quality in pharmacy. We will use this to continue to build a shared understanding of what the priorities should be to support quality in pharmacy, and how all of us can help to improve people’s experiences of using pharmacy services.

For as John Ruskin said:  Quality is never an accident; it is always the result of intelligent effort.   

19 December 2016

In the last Regulate, I wrote that part of our role as a regulator is to start sometimes tough conversations as a way to explore, understand and address complex issues. By extension, this also means that we should be willing to challenge our own thinking and even initiate major change if it leads to better patient care.

This is consistent with our recently released strategic plan which lays out ambitious goals for us over next three years, including providing ongoing assurance to patients and the public about the quality of care and advice they will receive; and holding ourselves accountable for working with you to uphold and promote professionalism and playing our part in supporting improvement in the quality of pharmacy practice.

It is in this context that we have just launched a consultation that proposes significant change to an area that has seen its share of controversy in recent years – religion, personal values and beliefs in pharmacy practice. It is not an issue that we approached lightly, but we believe it is an important issue to address.

We are proposing a significant change to the expectations of pharmacy professionals regarding their religion, personal values and beliefs and their ability or willingness to provide services to patients. This is a major shift that places the onus on the pharmacy professional to ensure that patient needs and care are not compromised by religion, personal values and beliefs and, moreover, that patient needs and care should always come first.

Our current standards and guidance state that pharmacy professionals can refer patients and the public to other providers if their religion, personal values or beliefs prevent them from providing care.

And in the consultation we held earlier this year on the standards for pharmacy professionals, we proposed that we would continue with this approach.

Most respondents to the consultation survey agreed with the approach we proposed. However, most of the people or organisations who commented in this section thought that pharmacy professionals should not be able to refuse services based on their religion, personal values or beliefs, as it would contradict the principle of person-centred care. This view was also expressed by pharmacy users in focus groups we held across Great Britain.

The debate around this topic has in the past been framed around a few familiar issues, such as a religious objection to providing certain services, such as emergency hormonal contraception.   But, as we learned during our consultation, it is much more complicated and broader than we and others may have thought.   In fact, it was our engagement with members of the public that highlighted the complexity of this issue and helped us to see what this approach looks like from the point of view of those receiving care.

We heard about a transgender individual who was refused hormone therapy and told—in front of other customers - to get their medicines elsewhere. We heard about individuals seeking prescribed treatment for substance misuse who felt demeaned and judged for it by the pharmacy professional supplying their medicine.

And not imposing religion, personal values and beliefs also has implications beyond the provision of services, for example if a pharmacy professional did not act to safeguard a girl who they believed to be at risk of female genital mutilation because their personal values or beliefs condoned the practice.

After detailed discussion of the implications of our proposals, and a review of the relevant human rights and equality law, it became clear to us that the examples we gave in the standards relating to personal values and beliefs and the supporting guidance needed more work to encompass these and other circumstances pharmacy professionals may be faced with, and that it was appropriate to consult on this topic. 

We feel the proposals better reflect our policy of person-centred care.

We are now proposing that the standards and guidance emphasise that pharmacy professionals should not knowingly put themselves in a position where a person is unable to receive the care or advice they need.

The draft guidance explains that the most appropriate action depends on the individual needs and circumstances of the person seeking a pharmacy service, and that in some cases a referral to another service provider might not be the right option, or enough, to ensure that person-centred care is not compromised.

We understand the importance of a pharmacy professional’s religion, personal values or beliefs, but we want to make sure people can access the advice, care and services they need from a pharmacy, when they need them.

In line with our new standards for pharmacy professionals, the guidance relies on the professional judgement of pharmacy professionals.   It is not meant to force pharmacy professionals to do anything against their conscience; rather our hope is that it will encourage them to think about, and take responsibility for, ensuring that their religion, personal values and beliefs do not compromise patient care.

We recognise the proposals represent a significant change, which is why we are holding this consultation.

As with the standards consultation, we are casting a wide net for feedback.  We want to hear from pharmacy professionals, and we also want to hear from employers since, they will have a role to ensure they maintain an environment that supports person-centred care.  We want to hear from professional bodies, who will have a role in supporting professionals.  We also want to hear from religious groups, secular groups, groups representing vulnerable people or those under difficult or challenging personal circumstances – those on the receiving end of pharmacy services and whose insight will be instructive for us and the profession.

Our view is the debate and discussion about this is as important as the consultation itself so we want to know if we’ve got it right but, equally important, we want to know if you think we’ve got it wrong and why.

This is a complex and difficult area for all of us; but we should not shy away from challenging discussions; instead we need to use these discussions to identify a consensus on how we can best support pharmacy professionals to help make sure they can put the care of their patients first.

31 October 2016

Regulation takes many forms. Sometimes the most useful intervention we can make as a regulator is to bring people together to start the challenging conversations that are needed about complex issues. Through these conversations we can begin to build a greater understanding of the issues and to identify actions that need to be taken and who should take them.

This October, we started two such conversations.

Understanding issues relating to ethnicity and academic performance

As a follow-up to the preliminary findings of research conducted by OPM on Black-African candidate performance in the registration assessment, we brought together key stakeholders, including academics, pharmacy professionals, pharmacy students, and representatives of professional bodies, to discuss the broader issues surrounding disproportionality in the academic performance of BME students and ways to address this.

Our keynote speaker, Professor Uduak Archibong, who heads the Institute for Diversity and Inclusion for the University of Bradford, welcomed our event for beginning a critical conversation about an issue that needed to be addressed, and called for leaders to work together to achieve success for everybody.

Through the workshop discussions, it was clear that this is an issue that resists an easy diagnosis or, suffice it to say, a simple solution.  The take-home message, however, was that a broad-based and multi-pronged approach and some targeted interventions could begin to help improve the experiences and performance of all students – not just those from BME communities.  Among the interventions discussed were engaging students early on to build confidence and competence in communication and promoting structural inclusiveness and diversity at the institutional level.

Based on the robust discussions during and after the event, and feedback we have received, most attendees saw it as an important first step in helping BME and other candidates live up to their potential.  We hope it provides the catalyst to leaders across pharmacy to consider what they can each do to help ensure pharmacy education and training is as open and fair to all as possible. We will use our regulatory levers to help promote and achieve this, including the standards we set and our accreditation of courses.  We will be consulting on new standards for education and training in the next year and you can expect to hear more about how equality will be embedded in the new standards then.

Professionalism under pressure

In mid-October we held a seminar to bring people together, from inside and outside pharmacy, to discuss the pressures that some pharmacy professionals are reporting in the workplace and to consider what role different organisations and individuals can play to address the issues raised.

What came through very clearly from the discussions at the event is that individuals and organisations across and beyond pharmacy have a role to play in developing a culture that supports professionalism and prioritises the quality of care for patients over profit.

As I said in my closing remarks at the event, individual health professionals and teams will always carry a big responsibility for ensuring that their actions are directed towards the best interests and well-being of the people they are serving, and not to the commercial or organisational interests of their employers. This is a core aspect of professionalism, however challenging the context you are working in.

But this in no way means that health professionals alone should bear the burden of balancing workplace pressures against their own judgement and the good of the patient.

Organisations, individuals and networks which shape professional culture and provide leadership in these debates have a clear opportunity and challenge to find new ways to support and empower the members of the profession they lead and represent and who may be struggling.

Pharmacy owners must create an organisational and cultural context in which professionalism can flourish and where professionals are empowered in their professional judgement to do right by their patients -ahead of financial considerations.   Corporate boards, too, must ensure they have appropriate governance systems and processes in place to assure that their businesses are meeting the relevant regulatory standards.

And those who commission and negotiate community pharmacy services should also make sure through service and contract design that support for professionalism becomes a part of the system, rather than sending a message that says only volume is valued.

We also have a part to play but what was clear to me through the discussions is that regulation alone cannot provide the answer. One of the things we will continue to do is to take forward these and other important conversations and, in this way, make sure that momentum towards addressing these issues thoroughly and thoughtfully is maintained.

Next month we will be inviting all pharmacy professionals and pharmacy owners to take part in this ongoing conversation, through an online workshop where they can share views and ideas. The online workshop will ask participants what helps pharmacy professionals and owners to provide quality care for patients and the public, and what the barriers may be. Please look out for your invitation to join the online workshop and take part if you can.

Listen to Ducan's closing remarks from the #ProfPressures seminar

17 August 2016

I started using social media as a New Year’s resolution a couple of years ago.  Intrigued by the chance to connect with friends, colleagues and strangers alike in a virtual forum, I found these interactions—ranging from short discussions to long debates—intellectually stimulating and even sometimes entertaining.

My enjoyment has waned of late due, in large part, to decidedly unsocial trends emerging in the larger online world. I still feel that social media is a valuable tool to engage on personal or professional matters. But it seems that, too often, social media is being used to upset, ridicule or embarrass, rather than inform or enlighten. 

In my view, it’s the immediacy that fuels the good and the bad in social media. On the one hand, you can post an idea and have it instantly validated or rejected.   You can generate new ideas from an audience as large as your followers and beyond. 

On the other, this immediacy (and imagined anonymity) also makes it too easy for any of us to behave in ways we wouldn’t dream of doing in person.  To act—or more precisely, react—without thinking.   To say things that are not only unkind and uncivil, but unprofessional.

Social media has become an integral and pervasive part of daily life for many of us.  But it can be a difficult thing to navigate successfully for professionals, who face higher expectations than non-professionals for appropriate behaviour online and off.   What’s allowed and what’s over the line?

Over the years we have been asked to produce guidance for registrants to help them navigate the choppy waters and treacherous channels of social media.  Against this backdrop, last month we released a one-page document outlining additional guidance for using social media. Our aim was to offer common-sense tips to help pharmacy professionals continue to meet our standards, and to make it clear that those standards extend to online forums and social media platforms as well as face-to-face interactions.  

We also wanted to prompt a conversation within the profession about what is considered acceptable behaviour.  And that, we certainly did.

Let me be clear—our aim is not to stifle debate or commentary or drive regulatory actions against registrants.  We welcome and encourage lively, provocative thoughts, discussions, disagreements and debates that do not descend into abuse and rancour. And, I have to think that all of us know the difference between constructive criticism and respectful disagreement, and personal attacks.  If not, think: disagree without being disagreeable and criticise the policy, not the person.

We are not the first regulator to issue guidance on social media.  Other health profession regulators, including the General Medical Council, the General Dental Council and the Nurses and Midwives Council, have all issued detailed guidance on the responsible use of social media. Professional bodies like the RPS and NPA have also issued helpful guidance on using social media effectively, which we signposted in our document as additional resources.

The guidance we have issued does not change our expectations of pharmacy professionals, as set out in our standards. Instead, it offers information and advice which registrants may find helpful in their practice. Our approach to standards and guidance is—as it has always been—grounded in the belief that pharmacy professionals do not need detailed, prescriptive guidance in order to exercise judgement and demonstrate professionalism.  

Like all health professionals, pharmacy professionals must take responsibility for upholding public confidence and maintaining the reputation of the profession online as well as offline.  We recognise that this is not always easy, and as the regulator we see our role as helping you to uphold the trust and confidence patients and the public have in you.