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GPhC: Guidance on meds supply in RP’s absence won’t ‘survive’ pandemic

Exclusive
GPhC to review statements issued during the pandemic “when the time is right”

GPhC guidance tolerating the supply of dispensed items in an emergency when the responsible pharmacist is away will not “survive” the pandemic, CEO Duncan Rudkin has told C+D.

Under current law, dispensed and checked prescriptions cannot be given to patients if the responsible pharmacist is away and alternative pharmacist cover is not available.

However, in March last year, the General Pharmaceutical Council (GPhC) issued a joint statement with the Pharmaceutical Society of Northern Ireland (PSNI), stating that the regulators would support pharmacy professionals who depart from the law in emergency circumstances linked to the COVID-19 pandemic when this is in “the patients’ best interest”.

The GPhC and PSNI used the example of if the responsible pharmacist must suddenly leave to self-isolate and no pharmacist cover can be found.

On such occasions, the regulators would “expect there to be access to a pharmacist by phone or video link to provide direction for the remaining staff in the pharmacy”, they said. 

The regulators said at the time that “this approach should only be adopted for a short-time period, where other options have been exhausted”. They agreed that “considering the potential effects of the current pandemic, it would be in the patient’s best interest for medicines already dispensed to be supplied from the pharmacy rather than not supplied at all”.

Guidance issued “in context” of pandemic

In an exclusive interview with C+D yesterday (June 1), Mr Rudkin said that he does not think the guidance referred to above will “survive” the pandemic.

“It was issued in the context of the pandemic [at a] particularly sudden and very significant increase in pressure on pharmacy… and [it] should not be taken as an indicator of the direction of travel,” he added.

The GPhC will begin a review of all pandemic-related statements “when the time is right”, Mr Rudkin said. It will remove some announcements “where appropriate”, to differentiate between “what remains GPhC policy going forward” and “time-bound” statements.

“Good” that supervision talks are “owned by profession”

Asked about the resumed talks on supervision in pharmacy, Mr Rudkin said that it is “good that this debate is being owned by the profession, rather than being driven by government or the regulator”.

He welcomes the profession’s decision to look at these issues “afresh”, following changes to pharmacy practice and the “expectations that the health service has of pharmacy and of the pharmacy professions”.

Last month, C+D revealed that three employer bodies had formed a cross-sector group to “refresh” discussions around changes to supervision in pharmacy.

Another aspect of pharmacy supervision that is subject to change is the “legal framework around the role of the responsible pharmacist and the superintendent”, Mr Rudkin said.

“I think that will proceed [at] the earliest opportunity and of course, that will be an important piece of the jigsaw when it comes to an up to date, very transparent and accountable set of governance arrangements that we need to have in pharmacy practice,” he added.

In 2018, the Department of Health and Social Care (DH) launched a consultation as part of which it sought to clarify the roles of responsible pharmacists and superintendent pharmacists. One of the questions asked whether the pharmacy regulators could make exceptions to the rule dictating that responsible pharmacists can only supervise one pharmacy “at one time”.

A spokesperson told C+D today (June 2) that the DH is committed to publishing its response to the consultation and it will lay it out in Parliament with the draft legislation as soon as possible.

11 Comments
Question: 
What do you make of this announcement?

Interleukin -2, Community pharmacist

What is naive is the notion that you ll retain your shifts as a locum and not risk ftp exposure after one episode of exercising your "super hero powers" eg shutting the pharmacy due to dangerously low staffing levels. What if a methadone patient purchasing heroine and ODs because you were shut to give out their dose.

M. Rx(n), Student

And what if that same scenario plays out anyway because you kept going despite the desperate situation?

Remember the Elizabeth Lee(?) saga?

YOUR PROFESSIONAL JUDGEMENT should be exercised on a case by case basis! It's not a blanket call --- there are several shades between extremes.

And even if the scenario you described played out, IF you can justify your decision, then IT IS A FAILURE OF THE SYSTEM and not your action itself that is at fault!

Fear of consequences should not deter making the RIGHT or BOLD calls when there's clear grounds to take a RESPONSIBLE course of action in the interests of YOUR PATIENTS - the same way you can refuse to sell codeine to a patient whom you clearly suspect to be abusing it.

Keeping your shifts to keep working in horrid and dangerous settings itself, in a sane world, would raise ftp questions.

Interleukin -2, Community pharmacist

Reading Dale and Appleby is one thing, 15 years of locuming and facing all kinds of scenarios is quite another. You are right sir, you definetly are . But I suspect that if poll locums, more than 99% will tell you that you NEVER ever get a complaint for selling co-codamol or solpadeine, but rather you ll get loads of complaints to head office for refusing sales...no dear me ..sorry for being rude..cos when the complaint comes through, the co-codamol is hardly ever mentioned. The ultimate outcome because naturally no ones cares about your side of the story is to not book that locum anymore. You see as it turns out, the real life interpretation of all those lofty ideals we were taught in Pharm school is more nuanced than black and white. Only with experience my friend

M. Rx(n), Student

Your assumptions are incorrect.

Look, I'm aware of the minefield that Pharmacists have to navigate in the community pharmacy setting - especially those that "Chris Locum" highlight below.  I have personal experience of them!

But, if the excuse is to adopt a "the reality is" attitude in compensation, then there's no future for the sector and all the funding in the world, in the end, won't remedy that rot. 

At some point we have to also take some of the responsibility for the rotten state of the sector. The "corporate bogeyman" had to have had some help from us -- from rent-seeking attitudes to corporate carreerism, we helped make the bed!

All I've been saying is we start acting like PROFESSIONALS in positions of public trust who actually have the LAW on our side in safeguarding the patient's interests! 

Chris Locum, Locum pharmacist

Until the threat of blackballing and insidious (and spurious accusations) threats to pharmacists by corporate management is challenged by the PDA (GPHC is not interested in working conditions and pay disputes), these so-called RP regulations will be nothing more than words.

kate Haddley, Student

I lurked a lot, I’m aware my actual name is on this. I felt I had to comment because....when as an RP is someone away from the Pharmacy? Do pharmacists sometimes use their actual allotted by law breaktime to go for a walk or nip the shop? I am fortunate enough to work for a company that usually gives you more than that 20 minutes. Can I use it? No...even if a pharmacy closes for lunch...do I use it? No, because the workload is such, that I would rather carry on to alliviate the workload for whoever comes after me (I am a relief pharmacist, and pro Reg). I actually think, it should be mandatory for pharmacies to shut for an hour so that staff get a break. It was common wh3n I was younger (to be fair Wednesday afternoon shutdown was). Siesta is common in Spain (it’s not cos of the weather, it’s because we are not robots). Patient safety is paramount, you cannot have patient safety without staff safety. Sorry, what a rant! Told you I’ve been lurking...

M. Rx(n), Student

As the RP, you have the LEGAL authority to do what is needed for the SAFE operation of the Pharmacy.

Save shutting the Pharmacy for a period, you can extend waiting periods to an HOUR, re-direct patients in a hurry elsewhere etc. YOU have the LEGAL discretion.

I know some people who will make some kum-baya suggestion to try and call the area manager/head office for support or some poppycock of the sort. Everyone knows nowt'all will come of it. You might even suffer a performance talk for your efforts. Heck, an area manager I once knew, will wait until 30mins before closing to return your call.

USE your RP powers -- THE LAW & COMON SENSE IS ON YOUR SIDE.

Of course, your education and training did not emphasise this at all.

Axed Locum, Locum pharmacist

"Another aspect of pharmacy supervision that is subject to change is the “legal framework around the role of the responsible pharmacist and the superintendent”, Mr Rudkin said.

“I think that will proceed [at] the earliest opportunity and of course, that will be an important piece of the jigsaw when it comes to an up to date, very transparent and accountable set of governance arrangements that we need to have in pharmacy practice,” he added"

Can we have more detail on the above!!. Is the suprintendent going to be held responsible for the standards, staffing, and resourses at each of the pharmacies they are accountable for?

M. Rx(n), Student

1). The Regulator and the DoH should determine when or when not discussions on Pharmacy Supervision should occur!

2). A superintendent pharmacist should be made legally and professionally liable for ensuring that appropriate resources are directed to the sustainable running of a Pharmacy - something outside of the immediate control of a non-owner RP.

3). The DoH/NHS should make it a priority to ensure that the GOVERNMENT has its own contingency on the ground for deployment in local and national emergencies! E.g. NHS Hubs; to avoid having to needlessly lower drug supply laws to compensate. I mean should methadone supply for instance have to messed around with because the entire system didn't have the foresight to plan for the unforseen? Messing around with supervision laws is not the answer.

Matthew Edwards, Community pharmacist

Point 2 is naive.  The superintendent should not be liable.  As RP you are responsible for the safe running of the premises (see your post above).  If you find that it is not able to operate safely then it is a professional responsibility to stop the premises functioning until sufficient resources/people can be in place.  A superintendent should be informed of such decisions and only then given a reasonable chance to remedy the situation be liable if no change occurs.  However in the first intance the RP has to be liable as the person on the ground with the authority to make decisions.

3.  Pharmacies are privately owned businesses and the government should not have contingency planning in place.  It is part of the pharmacy contract to have a contingency plan in place for all eventualities including closure.  These usually rely on other local businesses to step in as necessary.

M. Rx(n), Student

Re: (2) -- Read it again, very carefully. And bear in mind the RP's remit is only at the point of care. Unless the RP controls the funding to the Pharmacy, I'm not the one being naive here. A superintendent should be representing the interests of the patient and public in the boardroom! If they cannot exert that kind of influence IN A PHARMACY COMPANY then it's a pointless role. And it renders the entire "company-owned" pharmacy gambit a hopeless rabbit-hole.

Re: private businesses -- yes, they should have contingencies in place as part of holdng the contract. I have made that point on a different topic already. But it's no use if a collection of pharmacies come up short and there's no safety net! Imposing a huge fine after the fact is still only after the fact!
I am referring to the government having a means to deploy frontline support when the chips are really down.

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