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Questions from pre-registration pharmacists and tutors

My current training

Applying to register provisionally

Working as a provisionally-registered pharmacist

Sitting the registration assessment

 

My current training arrangements

Should I continue to follow the GPhC pre-reg scheme requirements, that are detailed in the manual, during the pandemic?

In the current situation, we appreciate that you are under significant pressure to deliver pharmacy services. This means that you may not be able to keep training in a work environment which meets the pre-registration scheme requirements, and that you will be asked to do work which does not form part of your training plan.

We will take a flexible and proportionate approach to the scheme requirements during this period. Safeguarding patient care and your own health are key priorities. You should follow government guidelines on taking precautions against COVID-19.

We would also highlight the recent joint guidance on pre-registration training issued by Health Education England, Heath Education and Improvement Wales, and NHS Education Scotland which may help tutors to support trainees during this time.
 

Does my tutor still have to complete my progress reviews?

Yes, progress reviews are still required, but we understand that both you and your tutor are under significant pressure at this time and you may not be able to complete these appraisals at the time you planned to.

If you complete these appraisals later than planned, it will not automatically affect your eligibility to sit the assessment.
 

What is the guidance around 40-day absence now?

You will not be ineligible to sit the registration assessment, or to register simply because you have taken more than 40 days of absence due to the pandemic.

If you need to take temporary leave, either to self-isolate or because of illness, you should speak to your employer or your tutor, and arrange your absence in the normal way. You do not need to let us know.

If you need to be absent for a longer period of time, your tutor should assess where you should pick up your training.
 

I am still employed by the same employer but have been deployed to work in different places. Do I have to complete a change of training details form?

You may be asked to work in different locations or departments, sometimes at short notice, during the pandemic.

It’s important that you receive the right support and supervision, wherever you are working - and that your employer follows the recent joint guidance on pre-registration training.

You do not need to let us know about changes in your location unless you move to a different site for more than ten weeks, or if the change is permanent- that is, that you are not going to return to your previous training site.

You should only work in another pharmacy location which:

  • is part of the organisation or company which employs you as a pre-registration trainee
  • is directly linked to your training site
  • you have been redeployed to by your training organisation

If you are changing sites for more than ten weeks, or permanently, you should consider where you are in your training and if you need to bank the time you have already completed. You can find out more about banking your training in section 2.22 and 2.23 of the pre-registration manual.
 

I am on a multi sector training programme and I have not been able to move to a different sector as planned. How does this affect my training?

We understand that supporting the delivery of pharmacy services during the pandemic means that you may not be able to keep to your original training plan.

If you can’t move to a different location as planned, you should work with your tutor to decide how you can progress your training in your current placement.
 

Can I work in a pharmacy being supervised by one of my relatives if this is more aligned to current government socialisation guidelines?

If you are asked by your employer to work in a pharmacy which is supervised by a relative and which is part of the same organisation, you can do so. During this time, although your relative is supervising your work, they should not assess your training progress or be responsible for delivering any part of your training plan. They can’t be your tutor, and this can’t be a permanent move.

Unless your employer asks you to, you should not work in another pharmacy which is not part of the organisation or company which employs you as a pre-registration trainee, or is not directly linked to your training site, except as a volunteer or support staff.
 

Is it ok if I am not able to work with my tutor(s) for 28 hours a week over four days, or need to be supervised by a pharmacist who has been registered with less than three years?

Yes. You may be asked to work with and be supervised by different members of staff other than your designated tutor(s), sometimes at short notice, during the pandemic.

It’s important that you receive the right support when you are working, and that your employer follows the recent joint guidance on pre-registration training.

You do not need to let us know if you are not able to be supervised by your tutor(s) for up to ten weeks. This will not affect your eligibility to sit the assessment or to meet the registration requirements.
 

If I need to self-isolate, feel that my work environment poses too much risk or I need to take a break for my own wellbeing, can my employers make me come to work?

You should follow government guidelines on taking precautions against COVID-19, and talk to your tutor and your employer to manage your concerns.

You may also find it helpful to contact other organisations such as Pharmacist Support - the profession’s independent charity - who offer free and confidential support covering wellbeing. You can access a range of information and resources on their website. To speak with a member of their support team directly, call 0808 168 2233 or email info@pharmacistsupport.org
 

Will a new trainee be able to start at my site with my tutor, if I am still working there?

We are currently considering the arrangements for trainees due to start the 2020/21 pre-registration scheme.

We will take into account the fact that the 2020 assessment sittings have been postponed, and that your training may not be completed on time. We aim to make sure that any impact on current trainees is minimised.
 

Can I work from home?

If you want to work from home, you should talk to your employer. Their policy should follow government advice.

Having a temporary period of working from home will not directly affect your eligibility to sit the assessment or to register where all other criteria are met.
 

Can I do my training online or remotely?

Please discuss this with your training provider and tutor - there may be parts of your training that can be done online, for example a first aid course.


 Applying to register provisionally 

How do I join the provisional register?

You will need to apply to join the provisional register through your my GPhC account. You must complete your training before you can join the provisional register.

Your tutor will need to complete a final progress report, and sign you off as satisfactory before you can complete an application for provisional registration. If you are successful, we will confirm to you the date on which you will join the register.

Important: do not practise as a pharmacist until your name appears on the online provisional register. Practising as a pharmacist while not on the register is breaking the law and you can be prosecuted.
 

What is the earliest date I can start working as a provisionally-registered pharmacist?

The first date a trainee could plan to be entered onto the provisional register and able to start work will be 1 August 2020.

From this date, we will add successful applicants to the provisional register on the first and fifteenth of each month. We aim to register people as soon as possible after they apply.
 

What documents do I need to apply for provisional registration?

You will to provide 

a)    A recent photo of you. The photo should be of your head shoulders, showing you facing straight to the camera, against a plain background.

b)    A scanned copy or photo of one of:

  • the details page of your passport (including your photo)
  • your EEA identity card
  • your UK or EU driving licence (you can use your provisional licence)

These documents need to be valid at the time of your application, but you do not need to get any copies of documents certified by a solicitor. We will ask your tutor to confirm your identity using the documents you provide.
 

Do I have to pay a fee to become registered provisionally?

You will not have to pay a fee to become provisionally registered. But you will need to pay to sit the registration assessment, and to apply to join the register, as usual.

We anticipate that the vast majority of people will be provisionally-registered for a short period as we expect to hold the registration assessment at the end of this year or early next year, so we don’t consider it appropriate for them to pay a full year of fees.
 

What are the criteria for provisional registration?

We have published our policy on criteria for provisional registration.

We will make sure all trainees get the information they need to consider applying for provisional registration in good time.
 

What are the timeframes for applying for the provisional register? 

Those who are eligible for provisional registration will  be able to apply in July, to join the register provisionally from 1 August 2020.

We will notify all trainees who may be eligible to join the register in good time before applications open. 
 

Can I join the register provisionally if I’m not currently in training?

If you are not currently in training this does not automatically mean that you are not able to apply for provisional registration, if you meet all of the criteria. This includes completing your training in 2020, and receiving a final declaration from your tutor that you have completed your training and that they believe you are safe to be registered provisionally. 

If you meet the criteria and are considering taking a break before registering provisionally, we recommend that you talk to your tutor.
 

I completed my pre-registration training before 2020 but was planning to sit the registration assessment for the first time in June; can I provisionally register?

In the policy, we have said that you must have successfully completed 52 weeks pre-registration training in 2020. This is for a number of reasons, including our new requirement for enhanced tutor sign-off after trainees have completed 52 weeks of training.  We do appreciate that this presents real challenges for you. We are still looking at this complex issue and developing our detailed approach.  We will also consider each case on an individual basis.  We would therefore ask you to email us on info@pharmacyregulation.org with the details of your individual situation.  We will then consider your case and get back to you as soon as we can.
 

Can I join the register provisionally if I have previously been unsuccessful at the registration assessment?

If you have previously sat the registration assessment and been unsuccessful, you will not meet the criteria to be eligible to apply for provisional registration. You will need to wait until the next registration assessment sitting, and apply for full registration as usual once you have passed the registration assessment.

We understand that anyone who has failed the registration assessment previously will be disappointed at not being eligible to apply for provisional registration. We are sorry for that, and the disruption this may cause. We recognise the significant efforts people will have made to enhance their learning through further study and working as dispensers, for example.

In setting the eligibility criteria for provisional registration, we considered very carefully how we could protect patient safety and quality of care, while also reasonably facilitating pre-registration trainees to join the register to maintain the workforce. We also need to make sure that those joining the register on a provisional basis have up-to-date knowledge of pharmacy. 

We decided to exclude from the provisional registration scheme those who have previously had the opportunity to demonstrate that they meet the standard, by sitting the registration assessment, and have unfortunately failed to do so. This is because a failure to pass the assessment provides clear and objective evidence that an individual has not yet demonstrated that they have met the required standard to be registered as a pharmacist.

We believe that those who are finishing their pre-registration year now and who have not yet had the opportunity to take the assessment due to the pandemic are in a different position.  We think it is right that they are able to register provisionally provided a number of requirements are met, including an enhanced tutor sign-off which involves seeking the views of another registrant or other healthcare professional confirming they have seen no evidence that the person will fail to meet the standards for pharmacy professionals.

We are working hard to develop an online registration assessment and to schedule this as soon as possible in a way that is fair for all candidates. We are committed to ensuring that any delay in sitting the assessment will be as short as possible.
 

Do I have to join the provisional register if I am eligible?

You do not have to join the provisional register, even if you meet the eligibility criteria. You may not want to join it at all, or you may want to take a break and submit an application later in the year.
We recommend that you talk to your tutor about your next steps and seek support if you are unsure what to do.
 

How do I move from provisional registration to registration as a pharmacist?

Everyone who is provisionally registered must sit the registration assessment at the first opportunity if they are fit to do so, and must pass the assessment to remain on the register.
 

How long can I be provisionally registered?

Once you are provisionally registered, you can remain on the register until 1 July 2021 at the latest. At this point any one on the register on a provisional basis will be removed and you will not be able to practise as a pharmacist.

If you want to renew your registration, you must meet the criteria for registration, including passing the registration assessment. 
 

Will I get more information about the self-declaration?

Yes.  We will provide more information about making the self-declaration in the information on how to apply for registration.  Registration will open in July so you will be asked to make your self-declaration then.
 

I’m a tutor.  How do I get the views of other registrants to inform the final declaration?  Who can give these views?

We will provide you with further guidance on making your final declaration about your trainee(s) in advance, so you have time to seek views from the named second registrant or other health professional. We will explain in the guidance how to do this.

You may want to begin thinking about who you may ask to give views, and check with them if they are happy to do so. The second registrant or other healthcare professional must have either:

  • overseen the trainee’s training as a Superintendent Pharmacist, or Chief Pharmacist
  • been involved in the quality assurance of their training as a member of an education and training organisation, or
  • worked with the trainee as a member of the pharmacy or hospital team,  and confirmed they have not seen any behaviours or practice which would prevent the individual meeting the standards for pharmacy professionals.  
     

I have seen that trainees in other healthcare professions have been able to register earlier than normal and start working straight away. Why can’t pre-registration pharmacists do the same?

Our main responsibility is to make sure that patients and the public receive safe and effective care. It’s important that pharmacy professionals on our register have the right skills and knowledge to deliver this.

The way pharmacy education is organised means that pharmacy students and trainees gain almost all their practical experience during their pre-registration year. This is in contrast to medicine and nursing, for example, where those in training complete a series of placements, in between periods of academic study. It is easier to rearrange the timing of these placements, as has happened with medical foundation training. This is not a practical option for pharmacy education and training.

The Nursing and Midwifery Council has recently made the decision not to add final year nursing students to their temporary register, and so nursing students need to finish their education and training before they are eligible to register.

One of the aims of our proposals on provisional registration is that pharmacy pre-registration trainees are able to progress in their education and training, and are not unfairly disadvantaged in comparison to those who have qualified in previous years.
 

Why is it safe to be registering trainees at all before they’ve passed the registration assessment?

The criteria for provisional registration will help to make sure that only pre-registration trainees who have demonstrated they have the necessary skills, knowledge and competence to be able to work safely, with structured support and guidance, will be able to register on a provisional basis. 

This includes introducing an enhanced tutor sign-off and a final declaration from their tutor confirming the trainee has met all 76 performance standards, and that they are not subject to current fitness to practise proceedings.  

The declaration must include a statement from the tutor that they believe the trainee is safe to be registered provisionally and that the trainee has demonstrated behaviours which indicate they could meet the standards for pharmacy professionals once registered, including using their professional judgement and speaking up when they have concerns or when things go wrong (standards 5 and 8 of the standards for pharmacy professionals). 


Working as a provisionally-registered pharmacist

I have accepted the offer of a job, which is dependent on me passing the registration assessment and joining the register in August. How does the situation affect my job offer?

We have published our policy on provisional registration which sets out the criteria a trainee must meet to join the register provisionally. 

If you join the register provisionally, you will be able to work as a pharmacist if you are:

•    employed directly by the organisation or business in which you are working
•    working under the guidance and direction of a senior pharmacist

You will not be able to work as a locum, or as a chief or superintendent pharmacist while you are provisionally registered, but you will able to be a Responsible Pharmacist.

Your employer will also need to meet certain conditions set out in the policy.

We recommend that you read the provisional registration policy and talk to your employer about your job offer.
 

I don’t have a job offer for when I finish training. Will I be able to work as a pharmacist if I join the provisional register?

If you are successful in your application to join the provisional register, you will be able to work as a pharmacist, so long as you are:

•    employed directly by the organisation or business in which you are working
•    working under the guidance and direction of a senior pharmacist

You will not be able to work as a locum, or as a chief or superintendent pharmacist while you are provisionally registered, but you will be able to be a Responsible Pharmacist.

Your employer will also need to meet certain conditions set out in the policy.
 

Why can’t I be a locum?

After considering this issue very carefully, we decided that all provisionally registered pharmacists have to be employed directly by the organisation or business in which they are working. That is the only way we can make sure that you have the structured support you need to practise safely, and to assure patient safety.  

We will be requiring employers to carry out a risk assessment before you can start work and for you to work under the guidance and direction of a senior pharmacist throughout your time on the provisional register. This would not be possible if you are working as a locum where you are likely to be working in different locations and for different employers.

We understand this may cause you significant challenges if you are planning to work as a locum. We are sorry for that but we have to make sure provisionally-registered pharmacists have the support they need and patients are protected, by putting these requirements in place.  
 

Once I am provisionally-registered, do I have to work in the organisation or business where I did my pre-registration training?

No, you can work in another organisation or business as long as the criteria and requirements set out in the policy are met.
 

Can I work as a provisionally-registered pharmacist in a GP practice, within a primary care network, or another setting?

We understand there may be a number of people who want to take up roles in these settings and we will clarify the position shortly. 
 

Does ‘working under the guidance and direction of a senior pharmacist’ mean I have to work in the same location as them?

No, it does not mean you would have to work in the same location as the senior pharmacist, but they need to work for the same organisation or business, and must be available to to provide guidance and direction to you, for example by phone.
 

Why do I still need to do the registration assessment when I’ll have been working as a pharmacist for several months already?

It’s important to emphasise that you will only be joining the register on a provisional basis, until July 2021 at the latest.  You will need to sit and pass the registration assessment if you want to register as a pharmacist beyond July 2021. The registration assessment is still a vital part of assessing that you are able to practise as a pharmacist without the structured support and other requirements outlined in the policy.
 

What happens if I fail the registration assessment while I am provisionally registered?

If you fail the registration assessment while provisionally registered, you will be removed from the register and you will not be able to practise as a provisionally registered pharmacist. You will be able to apply to join the register once you have passed the registration assessment.
 


Sitting the registration assessment

When will the next registration assessment be?

We understand that many trainees would want the registration assessment to take place as early as possible.

We are currently carrying out a procurement exercise to identify a provider to deliver an online assessment in late 2020 to early 2021.

We will keep you updated on our progress and will give trainees and provisional registrants a minimum of two months’ notice of the date for the assessment.
 

Will the format of the registration assessment change and how?

We are carefully considering if and how the format of the registration assessment may need to change when being held online. We will provide further details on this once we have completed the procurement exercise and agreed the format.
 

Why can’t you tell me exactly when the exam will be?

We are planning to deliver the assessment online – including the ability for individuals to take the assessment at home - and have held preliminary 
discussions with organisations and institutions which have recent experience of this type of assessment.   

Given the high stakes nature of the assessment, it is essential that conditions are met about its security, the technological capacity, the ability of candidates to prepare and access the assessment and any amendment of the format of the questions in the assessment.  

This is the first time we have held an assessment online and we need to find a company that can provide the platform to help us do this.

We will now take forward a procurement exercise to ensure the requirements are specified clearly and can be delivered.  We are committed to making this happen as quickly as possible but cannot confirm an exact date until the procurement exercise has been completed.  We will give everyone at least two months’ notice of when it will be to give candidates a fair opportunity to prepare.
 

Why do I still need to do the registration assessment when I’ll have been working as a pharmacist for several months already?

It’s important to emphasise that you will only be joining the register on a provisional basis, until July 2021 at the latest.  You will need to sit and pass the registration assessment if you want to register as a pharmacist beyond July 2021. The registration assessment is still a vital part of assessing that you are able to practise as a pharmacist without the structured support and other requirements outlined in the policy.
 

I will exceed the eight-year time limit in November 2020. If I am unable to work, chose to take a break from training, or am unable to sit the registration assessment for the second or third time in 2020, will the GPhC criteria for registration be extended to accommodate this?

We will take in to account the situation of trainees who were due to sit the registration assessment in 2020, and the issue of the time limit to meet the registration criteria.

We will provide more information when we have an agreed plan to hold the registration assessment.
 

My visa is due to expire before I will be able to sit the registration assessment. What should I do?

You should raise this with your employer and the healthcare education organisation in your country:

  • HEE in England
  • HEIW in Wales 
  • NES in Scotland

The Home Office has announced that frontline workers with visas due to expire before 1 October 2020 will receive an automatic one-year extension.

The RPS and BPSA has confirmed with the Department of Health and Social Care that this extension will apply to provisionally registered pharmacists who are in employment which fulfils the requirements for a tier 2 visa. They are continuing discussions in relation to international trainees without employment in the period between the end of pre-registration training and the registration assessment. Please see the RPS website for more information.