Pharmacy bodies have said that any changes to the roles of responsible pharmacists (RPs), superintendent pharmacists (SPs) and chief pharmacists (CPs) must improve patient safety and survive future challenges, rather than being a response solely to current pressures.
This came following the approval of The Pharmacy (Responsible Pharmacists, Superintendent Pharmacists etc.) Order 2022 by the Privy Council, which is expected to come into force in December.
What is remote supervision?
A responsible pharmacist (RP) is required to be in charge of a pharmacy premises when medicines are being sold or supplied, or being assembled, prepared or dispensed with a view to sale or supply.
The Department of Health and Social Care (DHSC) first proposed remote supervision in 2006, which would allow pharmacies to dispense medicines without a pharmacist being physically present to supervise if a contractor is listed as the responsible pharmacist for multiple sites.
A DHSC memo leaked in 2017 suggested that the rebalancing committee, which reviews pharmacy legislation and regulation, supported the sale and supply of pharmacy and Prescription Only (PO) medicines by pharmacy technicians.
What changes will come into effect in December?
Under the 2022 orders, the power to consider proposals around the roles of RPs, SPs and CPs, including regarding workforce challenges, the operation of multiple sites and remote supervision, will be transferred to the GPhC and the PSNI as of December 2022.
It will empower the regulatory bodies to make an exception to the general rule that an RP can only be in charge of one pharmacy at a time, rather than this power lying with government ministerial legislators.
In doing so, regulators would be required to ‘consider minimising the costs on business’, a stipulation which some respondents to the 2018 consultation described as ‘inappropriate’, calling for regulators to be required to consider patient safety instead.
Respondents to the 2018 consultation also raised concerns that if a RP was not required to be present in a pharmacy or if pharmacy staff could be remotely supervised, patient safety might be put at risk; pharmacists could be unfairly exposed to criminal and civil prosecution and regulatory sanctions, and that pharmacies would lose their ‘unique selling point’ of always enabling access to a pharmacist.
Some respondents also commented that the pharmacy regulators were not trusted to use this power effectively.
But the government’s response to the consultation stressed that the legislation focused on the transfer of powers from ministerial teams to regulatory bodies, rather than the issue of remote supervision itself.
It stated that ‘the power to permit an exception to the general rule that an RP must hold the role for only one registered pharmacy at a time already exists in legislation’ and that ‘the proposal was to move this exception-making power from ministers to the pharmacy regulators, in keeping with the general principle of rebalancing.’
It added that ‘the consultation did not raise proposals in relation to remote supervision’ but added that ‘supervision will be the subject of further consideration in the context of the work to make better use of the rich skill mix in pharmacy teams.’
Could we see remote supervision in the future?
Duncan Rudkin, chief executive of the GPhC, said that the GPhC is ‘committed to listening carefully to all views expressed and considering what approach would best support safe and effective pharmacy care’, via a series of stakeholder engagements and full public consultations.
Pharmacy bodies have said that any changes must take into account a long-term view and prioritise patient safety, rather than solely responding to current pressures.
Speaking to The Pharmacist, Dr Leyla Hannbeck, chief executive of the Association for Independent Multiple Pharmacies (AIMp) argued that current supervision rules are ‘hopelessly dated and clearly unfit for purpose in the current age’.
She added: ‘There have been numerous instances in the past where pharmacy has considered regulatory changes against a background of current pressures without keeping a very clear mind about future unintended outcomes. AIMp are acutely aware of the damage being caused by the current workforce challenges; but we want to make sure that any changes made now are well considered and will survive future challenges.’
She said that AIMp had established a Task and Finish group made up of its members, who Dr Hannbeck said were ‘close to the coal face’ on this issue, with ‘mostly family-owned business’ that ‘are actively managed and worked in by them on a daily basis’.
Paul Bennett, RPS chief executive, stressed that ‘the regulatory standards set by GPhC must continue to maintain or improve patient safety and recognise the expanding role of pharmacists in all care settings.’
He added that: ‘Patients must continue to benefit from direct access to advice from a pharmacist. The increasing clinical role and service provision we are seeing from community pharmacies must continue to grow at pace, including enabling patients to have better access to pharmacist independent prescribers within their communities.’
The RPS said that it was not able to yet comment on what it might feed into the GPhC consultation, as the terms of the consultation had not yet been released and its response would be informed by RPS Boards and members.
The GPhC said that there will be extensive engagement with stakeholders across the pharmacy sector as well the wider health sector, governments and patients and members of the public.
It said that it would be able to give more information regarding the timescales and subject of the consultation when work begins in December.
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