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.