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GPhC: Provisionally registered pharmacists ‘may operate’ as RPs

GPhC: Provisionally registered pharmacists must take the registration exam "at the first opportunity"
GPhC: Provisionally registered pharmacists must take the registration exam "at the first opportunity"

Pre-regs who meet the criteria to provisionally join the General Pharmaceutical Council (GPhC) register “may operate as responsible pharmacists”, the regulator has said.

  • Pre-regs who pass certain criteria to provisionally join the register can operate as the responsible pharmacist, although they must practise under the guidance of a senior pharmacist
  • They will not be able to locum or work as superintendents or chief pharmacists
  • To remain on the register, provisionally registered pharmacists must sit the registration exam, which will be held online as soon as is possible

Provisionally registered pharmacists will not be allowed to work as locums, superintendent pharmacists or chief pharmacists, the GPhC said in a policy paper it published yesterday (May 21).

The policy sets out the criteria for provisionally registering this year’s pre-registration pharmacist trainees. Pre-reg trainees can apply to join the GPhC register from July 2020 until July next year, with the first cohort provisionally joining the register from August 2020.

In order to remain on the register, provisionally registered pharmacists must sit and pass the registration assessment “at the first opportunity if they are fit to do so”.

They will have to take the registration exam – which is “expected to be held online” – “as soon as is practicable”, the regulator said. However, they will be given a minimum of two-months’ notice to prepare for the assessment, it added.

The GPhC said last month (March 27) that it had decided to allow trainees who meet “certain criteria” to provisionally join the GPhC register. The regulator announced in March its decision to postpone the 2020 registration exams due to COVID-19.

Criteria for registration

The GPhC said it is “considering how to manage the cost of the process fairly and proportionately” and will inform the pre-regs “about the fees for this application”.

To provisionally join the register, they must meet some criteria, such as having “successfully completed 52 weeks pre-registration training in 2020” and not having previously failed the GPhC registration exam.

Trainees must also self-declare that “they are fit to practise as a pharmacist” and must get a “final declaration” from their tutor to confirm they have met all 76 performance standards and that they are not subject to current fitness-to-practise proceedings.

Employers will be responsible for carrying out a risk assessment before the provisionally registered pharmacists begin work. The regulator said it will share some standards for employers defining how these pharmacists will be allowed to operate.

“Provisionally registered persons must practise only under the guidance and direction of a senior pharmacist,” the GPhC said in its policy.

A “set of principles”

Commenting on the provisional registration policy, GPhC CEO Duncan Rudkin said that the GPhC’s decision has been “guided by a set of principles, including maintaining standards for entry to the register to protect patient safety and quality of care, and the importance of maintaining the workforce pipeline so that pharmacy can continue to serve the needs of patients”.

“We will continue to engage with stakeholders as we put this policy into practice, both to help inform our thinking on any particular points where we need to clarify the policy further,” he added.

Royal Pharmaceutical Society director for education Gail Fleming said the organisation welcomes the “clarity about what provisional registration looks like”. The RPS will support provisional registrants with “a range of products and services including mentoring, online revision courses and mock exams”, she added.

What do you make of the GPhC policy?

Shahan Mir, Community pharmacist

There needs to be transparency for the general public and they should be aware that the medicines will be supplied by a PRP. There should be an annotation to the RP notice on display clearly highlighting this with a link/signpost with an explanation and reasoning for patients. It will be much better if patients are informed beforehand as opposed to after an event.

Soon-To-Be Ex-Pharmacist, Superintendent Pharmacist

I am so sick to death of dentists telling people to go to pharmacies when their fillings have come out!!! WE CAN'T GET TEMPORARY FILLINGS SO STOP SENDING PEOPLE!!!!! Just another example of fobbing off onto pharmacy when another 'healthcare professional' hasn't got the balls to face patients.

Nothing to do with this article at all but I just wanted to get that off my chest......

NQ Pharmacist , Primary Care Nurse

DUCAN YOU MORON!! Not even a pharmacist head of GPHC what do you expect!!

Soon-To-Be Ex-Pharmacist, Superintendent Pharmacist

Is there anyone assessing the competence of these 'trainee RPs' before they are let loose? How will the supervision by a senior pharmacist work? Will they have to second check the checking? It all sounds very vague and just an extention of the pre-reg period until they can get the exam sorted. As others have said, aren't exams more or less naturally socially distanced anyway? I remember from my 'o'levels (I'm THAT old) that all the desks were definitely 2 metres apart to stop cheating. There is no issue with hundreds of people from different households moving around in a supermarket for hours so why should a few tens of students not moving around, in an exam hall be a problem? I do get the feeling that a lot of people are being deliberately awkward with a lot of situations where the risk is actually minimal - I assume the students and invigilators all go shopping?

The one person I do agree with is that teachers union person who has been slagged off to the hills for her comments about snotty little kids wiping their noses on you - totally true, a significant risk and she should be free to say the truth.

A England, Manager

I am reading utter nonsense here. Professional standards and clinical knowhow and the evidence that they have been met should not be traded in the current circumstances- there is no need. I have already seen my share of pharmacists, that I would not even give palce on a Pharmacy Assistant course, let alone a Pharmacy Degree. It seems no one has thought about how to continue and undertake the Pre-reg exam! GPhC is a pathetic joke of a Professional Body (evidence - current proposition). There will be no harm done by delaying the Pre-reg exam for 2-4 months. Hundereds of locations should be used where a small number (up to about 100) can sit 2m apart and complete the exam...there are plenty of empty places, plenty of professional people who have nothing to do at the moment and can invigilate exams!!


C A, Community pharmacist

"Eligible Pre-regs must practise under the guidance of a senior pharmacist"

Am I missing something - if they are under the guidance of a senior pharmacist, would the more senior pharmacist not be better signing in as RP?

Industry Pharmacist, Head/Senior Manager

I'm sure the GMC and BDA will follow suit with their pre-regs...not.

Claude Pereira, Locum pharmacist

I honestly can see major problems with doing an online assessment post making someone RP. For instance a provisional pharmacist is on the register for 12 months, sits the exam and then unfortunately fails it. What does that make the work they have been doing (including pharmaceutical advice to patients) for the preceeding months? Null and void? 

I cant speak for all the pre regs in the country, however for all the pre regs I work with, I've seen them all grow into fully capable Pharmacists. They worked the extra hours and dealt with all the stress Covid-19 brought to all of us. For that, they deserve the exam to be scrapped and put on the register based on the merits they have shown in this time of crisis and preceeding months leading up to it. 

Hanging an exam over their heads for potentially another year is by no means fair


Pharm Druggist, Community pharmacist

I share your sentiment that pre regs have been amazing, showing great resilience and adaptability. I must say however, the ones that i have worked with have said they haven't had time to revise and study to gain the requried clinical knowledge. I was extremely impressed by the maturity of one pre reg, who said they feel nervous practising without an exam, because there is no black and white measure of whether their clinical standard is at an adequate stage. They deserve praise and reward, but scrapping an exam designed to examine a day-1 pharmacist's clinical knowledge is not the correct way to reward this, in my opinion.

Claude Pereira, Locum pharmacist


Thats a very fair comment to make as some our pre regs share the same sentiment, I just feel that this whole situation undermines the exam in its entirety as it is essentially saying you dont have to pass it to work as a Pharmacist. 

There is no easy answer for this at all, as Im sure the GPhC wouldve taken it! Its just that this unprecedented situation has caused this years cohort to experience things I would never of imagined as a pre reg.  On top of that, with the restrictions being imposed to work as a provisional pharmacist, it seems inherently unfair.

I would never advocate someone who is not competent to be put on the register, however surely that is in the hand of the tutor to sign off ensuring they are signing off someone who is competent.



Soon-To-Be Ex-Pharmacist, Superintendent Pharmacist

'it is essentially saying you dont have to pass it to work as a Pharmacist.'

Once upon a time, you didn't.  A trained, experienced pharmacist decided whether or not you were fit to go onto the register and that was, and in my opinion still is, good enough. Being good at doing exams does NOT, and I can't emphasize that enough, automatically make you a good pharmacist. I know of plenty of academically gifted people who would be DREADFUL at being community pharmacists because they have no social skills whatsoever and that is a skill which cannot be examined but can only be acquired through experience, which is what the pre-reg year once was, learning how to relate with co-workers and patients (and the relations with co-workers is a much underestimated skill! I had much fun learning it.....). Now it just seems to be an extention of the degree, mostly bookwork with little practical experience gained.


Pharm Druggist, Community pharmacist

Agree, insane circumstances and really do feel sorry for them!

dave de cat, Community pharmacist

online exam? how is the temptation to cheat going to be addressed?

O J, Community pharmacist

Just an innocent suggestion
Why dont GPhc have an online exam, where by, the pre reg have to sit within their training site and their pre reg tutor can be their invigulator.
Yes, there will be logistical and financial cost attached to it but that's for the upper hierarchy to decide.
Any other suggestions??

C A, Community pharmacist

Being that schools are going back next week, as officially announced by Boris, why not just have the exams in a school gymnasium... like we used to do in the olden days (read, when I was at school)

Benie Locum, Locum pharmacist

Will the tutor be paid for this invigilation?

Benie Locum, Locum pharmacist

Nice. We mustn't interrupt the supply of cheap labour for the multiples. I wonder if the GPhC are concerned as to the possible danger posed to the public by these 'provisional' pharmacists. 

Soon-To-Be Ex-Pharmacist, Superintendent Pharmacist

No, of course they aren't. If there was an interruption to the supply of pharmacists, locum rates might rise to unacceptable levels - they might even get to £20 per hour!! Remember what happened during the 'fallow year'? That was the beginning of the end for decent rates for locums.

Pharm Druggist, Community pharmacist

Normally i'd agree with the skeptism, but in this case I'd give the GPhC the benefit of the doubt, that they don't want to abandon the entire pre-reg cohort. 

One argument to the safety aspect is that there is an entire generation of pharmacists that didn't need to sit an exam, that have practised/are practising. Although we live in different times now and i believe an assessment, pre-qualification,  is needed. It seems the GPhC also realise that this is difficult territory and have opted to pass responsibility onto the tutor to sign off. Depending on the degree of responsibility that the tutor has post sign off, and the strength of candidate, I can imagine some tutors will be hesistant to sign off weaker candidates. I believe this is what the GPhC is anticipating and will go some way to providing a filter so the weaker candidates do not qualify. My two cents.


C A, Community pharmacist

With the rapidly reducing government lockdown measures, the GPhC should have plan in place to conduct the exams, just my opinion.

Soon-To-Be Ex-Pharmacist, Superintendent Pharmacist

So, in a nutshell, go back to the tried and trusted way of doing it which worked perfectly well for YEARS until someone decided to stick their two cents in and invent an exam which is un-necessary. I never had to, I'm one of those oldies you referred to, and I and my fellows from the same era are no better nor worse pharmacists than the exam generations.

The tutor took no legal responsibility at all for the actions of the pharmacist post-registration and believe me, had NO hesitation in not signing off weaker candidates. In fact, those who were incapable were weeded out well before it came to the end of the pre-reg year. I should imagine the same would be true of this plan.

Benie Locum, Locum pharmacist

I see your argument. I suppose it will be easier for Rudkin to reprimand and strike off tutors if all responsibilty falls on their shoulders.

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