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.

15 June 2016

Many of you will have read recent articles in the Guardian and pharmacy media about pressures experienced by pharmacy professionals working in community pharmacies.

We recognise that pharmacy professionals working in a wide variety of roles and settings will experience significant challenges in trying to provide high quality care to patients and the public while dealing with limited resources or other pressures.

Indeed, we never seem to hear of healthcare professionals working in fully optimal circumstances without resource constraints of one kind or another. Some of the challenges facing professionals in NHS organisations, including financial pressures and targets, were recently highlighted again in the latest Nuffield Trust’s Health Leaders Survey, published last week, which warned of poor morale among staff and looming shortages in key areas within the NHS in England.

Pharmacy professionals working in community pharmacy face different pressures as the businesses in which they work seek to generate income and manage their costs. This reality highlights one of the reasons why society looks to professionals to act professionally, counting on them to put patients’ interests above the interests of others (including professionals themselves and their employers). This can be very hard and easy answers are thin on the ground. If these situations were easy we wouldn’t need professionals to handle them.

It’s also true that a range of other people have a part to play. Employing organisations have a responsibility to provide a working environment in which professionals can behave professionally. This requirement is clearly set out in our Standards for registered pharmacies. We as the regulator have a responsibility to set standards for pharmacy professionals and registered pharmacies that promote safe and effective care for patients and the public. And we use our inspection powers to assess how well pharmacy owners are achieving the standards for registered pharmacies. A great deal of the information which informs these assessments comes from responsible pharmacists themselves, and other individual team members. And there are roles for other key organisations and groups too, including educators and professional bodies in providing support to help make sure professionals (including superintendents and responsible pharmacists) are both competent and confident to challenge management where needed, and to raise concerns where their challenge is not heard or acted upon.

We have recently reviewed the survey results shared with us by the Pharmacists’ Defence Association, which had asked its members about pressures they face in the workplace. The survey and accompanying anonymous case studies highlight a number of issues which we and others need to understand better. A wide range of views and comments have also followed, which we also need to get to the bottom of. This is why we are arranging a seminar in October, to be chaired by Professor Nairn Wilson, a distinguished professional leader from outside pharmacy. We want to create an opportunity for all of us – regulators, the NHS, companies, professionals and representative bodies to consider these complex and challenging issues in depth, to inform the work we have to do individually and collectively. Read more on professionalism under pressure.

14 April 2016

Last week we launched one of the most important consultations we’ve ever undertaken, on new standards for pharmacy professionals.    

You may be asking ‘why we are changing the standards?’ What will these changes mean in practice for pharmacists and pharmacy technicians?  What changes in the sector prompted or informed the new standards?   

At first glance the new standards may suggest that not much has changed. But they do represent a departure from those currently governing pharmacy professionals. We’re proposing to reduce the number of standards from 57 to nine, underpinned by guidance and examples of the kinds of behaviours that describe them. 

And in focusing on comparing the existing standards with those proposed to replace them, it’s important that we don’t lose sight of a number of more profound changes in what the standards themselves represent.   An enhanced focus on person centred care; a greater emphasis on professional responsibility and accountability, and last but not least, highlighting the importance of leadership and teamwork.

Against the backdrop of a sector that is changing and maturing, we have written these standards to be flexible and applicable to pharmacy professionals wherever they work. Rather than an exhaustive list of dos and don’ts, we are providing you a framework, with guidance and support, which relies on your knowledge, skills and professionalism to determine the best way to do your job. The draft standards reflect the attitudes and behaviours that you and the public told us were important. They also reflect a call for greater accountability to yourself, to your peers and to your patients.

Amidst all this change, however, there also is continuity. This consultation on standards reflects our ongoing commitment to promoting a culture of professionalism and to improving outcomes for patients and the public. My hope is that this consultation will provide the impetus for you to start a conversation with your peers and other health professionals about your practice and how to work effectively together; and also to consider how you can provide person-centred care. 

And, of course, we also want to hear from you.

Read more about the standards, take the consultation survey and let us know if we have got it right – not just for today, but for tomorrow.

11 February 2016

Photo of chief executive Duncan Rudkin

In this issue, chief executive Duncan Rudkin looks at the significant changes ahead in 2016

We are only six weeks into 2016 and already it has become clear that this will be another year of significant change in pharmacy – genuinely justifying the cliché ‘challenge and opportunity’, perhaps. And I’m conscious that for many of you, especially those of you who work in community pharmacy in England, 2016 may have started off with a great deal of concern and uncertainty about the future. Before Christmas the Department of Health published a number of proposed changes to the pharmacy contract and pharmacy services in England, but it was the proposed reduction in the total funding commitment which has inevitably been the focus of a lot of debate.

I appreciate that is an emotive issue which affects people’s livelihoods. And you may be asking what the GPhC’s position is on the government proposals. Let me emphasise that the GPhC operates independently of governments and of the pharmacy professions and of contractors, and is not involved in making decisions about funding pharmacy. We are here to work on behalf of patients and the public and to protect, promote and maintain their health, safety and wellbeing; our role is not to advocate for the profession, for pharmacy owners or for government.

It is our responsibility, however, to listen to governments across Great Britain, to the NHS and other employers, to registrants and above all to patients and others who use pharmacy services, to be aware of how pharmacy may change in the future. We need to understand these changes so we can ensure that the standards we set are fit not just for today, but for the future. And so we will be holding major consultations in the next 12-18 months on standards for pharmacy professionals, for registered pharmacies and for the education and training of the pharmacy team to ensure that these standards are achievable and appropriate. We will need your input into these consultations to help us understand how you think pharmacy professional practice will and should change (whether or not you see these as the same thing!).

Efficiency and effectiveness

We continue to focus on ensuring we are using registrants’ fees efficiently and effectively. Last week our council approved our budget for 2016/17 and decided to maintain registrants’ fees at the current level for October 2016-17.  We are reducing our operating costs for 2016/17 so we don’t have to raise fees, despite continuing growth in the volume of cases we are having to deal with. It is our intention to achieve greater efficiencies on top of what we’ve already achieved over the past financial year, while continuing to achieve our ambitious aims.

Reserving judgement

It is very important that the pharmacists and pharmacy technicians that we regulate have confidence in us as their regulator and so we carefully consider all feedback and comments from registrants about our work. Recently, some registrants have raised concerns in the media about the actions we have taken so far in a high-profile case involving an internet pharmacy.

My team and I understand the frustration some registrants may feel when they think we should be taking immediate action in a particular case involving an individual pharmacy professional or pharmacy business. While our process may take longer than many would like, our duty is to thoroughly investigate and consider all available evidence before taking action. We aim to provide updates whenever possible, however, it would be inappropriate—and unfair—to discuss ongoing cases; doing so could prejudice any future hearings and the outcome of the case.   It is right that registrants let us know when they think we have not taken the right action. But we are not in the business of arbitrary judgement or trial by comment columns.

New powers for regulating registered pharmacies

Finally, I’d like to add that I’m delighted that the UK and Scottish Parliaments are now considering new legislation which will give us important powers to improve the way in which we regulate registered pharmacies. The order will allow us to publish reports from our inspections and take proportionate enforcement action against pharmacies where necessary. Once this legislation has gone through, we will seek your views later this year on changes to our approach to regulating registered pharmacies.

2 December 2015

Earlier this month we brought together leaders from across pharmacy, students and patients and asked them a question; how do we produce the pharmacy team of the future that will meet the needs of patients and the public? 

We were provided with a multitude of answers but one theme that emerged strongly was that of change - that change is coming and that change is necessary.

On many levels change is already happening. Pharmacy professionals are already taking on greater roles in providing person-centred clinical care and in medicines optimisation. The way care is provided continues to change in order to meet growing demand from an ageing population at a time of limited resources, with care moving out of hospital and into community settings. Relationships between patients and health professionals are also changing, with patients becoming partners in their own care and expecting to make decisions jointly with the health professionals working with them.

It’s important that our standards for education and training reflect all of these changes and prepare tomorrow’s pharmacy team for new roles and new challenges. There was widespread agreement from delegates at the conference that the core skills of professionalism, communication skills and multi-professional working need to be included in the standards for all members of the pharmacy team. And many of those attending told us that the pharmacy team need more interaction with patients in clinical settings and more inter-professional learning during their education and training.

We are mindful that we must not simply build our standards around a core of today’s knowledge. Instead we need to equip the pharmacy team of the future with the abilities to acquire knowledge and skills throughout their working lives – knowledge which most of us are not even able to visualise at this point in time. Education and training needs to be an ongoing process beyond qualification; there needs to be a clear pathway for future education and training.

The responses we received to our recent discussion paper Tomorrow’s pharmacy team also highlighted that there are still gaps in knowledge about the roles, skills and abilities within the team. This needs to be addressed if we are to achieve a truly integrated approach to pharmacy education and training and to pharmacy practice. And as part of that approach we also need to consider how the pharmacy team as a whole becomes better integrated within the wider healthcare team, with the patient always being at the centre.

These are all issues which will be reflected in our future standards for education and training of the pharmacy team. We plan to continue to engage, question and challenge all those with an involvement in pharmacy education and training to make sure that the standards we end up with are robust now and in the future. And we will challenge ourselves and others to make sure that we move this forward with pace. Change is needed now to make sure tomorrow’s pharmacy team have the skills and abilities to meet future health challenges and the needs of their patients. We all need to make this change happen.