The guidance includes answers to common issues that pharmacy undergraduates experience when applying for pre-registration place, what to do if they feel a potential employer is pressurising them into accepting an offer and what to do if they accept an offer but wish to reject it at a later date.

BPSA Graduate Officer, Lauren Rose said:

“Students have been contacting the BPSA with concerns that they are often left unsure whether to accept offers from the community sector early on in the year when hospital applications are dealt with several months later. In addition some students are made to feel under pressure to accept offers within a specified time frame when they may have other potential interview dates lined up. Students feel the pre-registration year is an important year in terms of their training and feel it is important for them to ensure they are working within the right training place that they are most passionate about.”

Ryan Hamilton, BPSA Honorary Life member and past president of the association said:

“Students have felt under pressure to accept training offers for a number of years and since the demerger of the regulatory functions from the RPSGB students have reported such pressure with repeated frequency. The guidance published today will allow students to understand not just their rights, but also their responsibilities, when it comes to accepting and rejecting offers. The guidance aims to help students make an informed decision and go about this in a professional manner.”

Rob Darracott, Chief Executive of Pharmacy Voice said:

“We’re pleased to have worked alongside the BPSA and the NHS in producing this useful guidance for both students and employers.  Everyone in pharmacy can remember the feeling they had when applying for their placement, we hope this guidance will help to alleviate any concerns students have and to help them to make informed decisions as well as giving information on where to turn for more information.”  

Amanda Kemp, Chair of the NHS -Pre-registration Trainee Pharmacist Specialist Group said:

“The NHS Regional Pre-registration Training Leads welcome this guidance which helps provide clarity and support to students and will also benefit employers by enabling students to make an informed choice in a professional and timely manner.  If a student is unsure about whether to accept an offer or wait to see if they get another offer, it is important that they talk to the employers about their position.  Employers in all sectors understand that this can be a difficult choice to make and can help clarify the recruitment process and possible options.  The guidance also signposts students to other sources of help and advice, such as the BPSA Graduate Officer.”

This guidance should be read in conjunction with the Best Practice Guidelines for the recruitment of pre-registration trainee pharmacists in the NHS (England & Wales) Guidelines on accepting and rejecting offers for NHS pre-registration training positions and the information on employment offers and contracts provided by community pharmacy employers. 

The guidance can be downloaded by clicking here. 

“If the Government wants to relieve the immense pressure on hospital A&E departments, it needs to realise that the NHS is more than doctors and nurses.  As many as 1.5 million visits to A&E could more appropriately be handled at a community pharmacy.  People turn up to A&E with sprains, minor burns, eye infections and all manner of other complaints that a pharmacist can sort out conveniently.  The NHS can do a lot more to signpost to this support and to make the patient experience consistent wherever care is accessed in a community pharmacy.

“NHS 111 is significantly under-referring to self care and community pharmacy support. There is a lack of ‘pharmacy endpoints’ in the algorithms used by NHS111 call handlers. This means that calls that would have been referred to community pharmacy by NHS Direct under the old system may now be referred unnecessarily to GPs or out of hours (OOH) services or emergency care.”

In its formal written submission to the Health Select Committee, Pharmacy Voice made the following additional points:

• A national minor ailment scheme, where pharmacists can supply, when appropriate, certain medicines to treat immediately a range of common conditions could help to reduce demand on GPs and OOH services.
• Pharmacists are highly trained health care professionals able to advise people on treatment for a wide range of common conditions. They know when to refer to GPs, out of hours (OOH) services or emergency care
• Community pharmacies are located where people live and work.  They are typically open for longer hours than GP surgeries. There has been a trend in recent years for pharmacies to open for longer hours.  According to our estimates, pharmacies in England now provide the public with immediate access to a registered health professional – a pharmacist – without an appointment for more than 100,000 extra hours a week than in 2005.  
• The locality approach to NHS111 means that engagement with pharmacy on the ground is hugely variable.  In a survey conducted by Pharmacy Voice across England between February and April 2013, with locality responses representing 80% of the country, we found that in fewer than half of all the localities had there been even initial contact between the NHS111 organisation and the local pharmacy committee. 

Rob Darracott, Chief Executive of Pharmacy Voice said:

“Nearly two million people come to pharmacies each day, to benefit from safe supply of medicines, health improvement interventions, support for self care and treatment for long term conditions.  Pharmacies make a massive and underreported contribution to the health of the nation.  This small study has to be seen in that context.

“People trust that community pharmacies will offer appropriate advice at the point of supply of medicines.  It is disappointing that Which? has identified incidents where this hasn’t happened, but encouraging that in the two scenarios tested by Which? once before (in 2008), improvement was noted.

"It’s important to recognise that Which? looked only at one part of the pharmacy service – the advice given at the point of supply of certain over the counter medicines. There is growing evidence about the benefits of the pharmacy service in the round, which comprises a range of NHS and public health services as well as the supply of medicines.  

“The sample size of this study is not enough to make any meaningful comparisons between pharmacy groups, or types. Audits of interventions made at community pharmacies in 2012 show that all types of pharmacy - independents, supermarkets and pharmacy chains - routinely intervene to reduce risk and improve outcomes for their patients.

“Pharmacy is a uniquely accessible health service, and this has to be matched by the quality of interactions with customers. New operating frameworks in community pharmacy, and the use of nationally recognised qualifications for pharmacy support staff, are showing considerable promise to improve the overall quality of service and patient satisfaction. Naturally, pharmacy organizations will wish to reflect on the Which? report and together look at what more can be done to ensure consistently high quality in community pharmacy.”

Rob Darracott, Chief Executive of Pharmacy Voice said:

“If the proposals go ahead, Information Commissioner staff would have the power to enter the pharmacy and check data handling procedures without warning. This is unnecessary. The one part of the dispensing and reimbursement process where there is a risk of loss of information is outside the control of pharmacy staff and systems.”

Pharmacy Voice makes the following points in the submission:

• Community pharmacy is a heavily regulated profession and pharmacists and their staff are subject to the same rules of confidentiality as the rest of the health service and subject to information governance requirements. All pharmacy staff have a confidentiality clause in their contracts and pharmacists and registered technicians, regulated by the General Pharmaceutical Council (GPhC), are also bound to confidentiality by their code of ethics. Pharmacy premises are inspected not only by the NHS but also bythe pharmacy regulator the General Pharmaceutical Council.
• Community pharmacies are subject to inspection by the NHS to ensure they are meeting the requirements of the pharmacy contractual framework.  Information governance and confidentiality fall within the Clinical Governance elements of the contractual framework and processes and procedures are inspected and evidence is sought to demonstrate compliance.
• The one part of the dispensing / reimbursement process where there is a risk of loss of information is outside the control of the pharmacy staff. Pharmacy owners do everything within their power to ensure that the transfer of the prescriptions is secure, but there have been instances where bundles of prescriptions have been mislaid. The Electronic Prescription Service Release 2 allows for the electronic transmission of this information; however the service has not been widely implemented by GPs. A solution would be for pharmacies to electronically invoice the NHSBSA based on the dispensing data held on their own system. We would appreciate any support that the Information Commissioner (IC) could provide in obtaining a rapid solution to the method of payment avoiding the need to send prescriptions to the NHSBSA.
• For micro, small and medium sized business to have to designate a data protection officer and be subject to audit is yet another bureaucratic burden, at time when government is trying to support and encourage business and through the Cutting Red Tape challenge reduce the burden on businesses.  The cost of this would ultimately be borne by the Government through the regulatory burden element of the reimbursement package for community pharmacy.
• The Government recognises the value of the sector in ensuring the safe supply of medicines, helping to meet the medicines optimisation and public health agendas and helping to reduce the load on other, more expensive parts, of the NHS. To further burden a sector that needs to be released from unnecessary bureaucracy, to devote more time to patient care, runs counter to the direction of Government travel.
• A proportionate response would be for the Information Commissioner’s Office to analyse the areas covered by existing inspections by the NHS and GPhC. The IC should then seek to negotiate a Memorandum of Understanding with the GPhC so the pharmacy regulator can provide any further assurances in relation to data protection through their pharmacy inspection programme.

The full response to the consultation can be read by clicking here. 

Rob Darracott, Chief Executive of Pharmacy Voice said:

“If it ain’t broke, don’t fix it. Community pharmacy owners currently indemnify all members of staff including self-employed locums.  The system works well, pharmacy owners and staff know that indemnity arrangements are in place and in the in event of an untoward  incident happening which could result in patient harm then any resulting claim will be dealt with promptly and the claimant will receive due recompense.”

Pharmacy Voice makes the following points in the submission:

• We understand the need for regulated healthcare professionals to have adequate indemnity insurance.  However community pharmacy differs from other independent contractors to the NHS or self employed healthcare professionals, in that the supply of medicines and other pharmaceutical services to the public, at a primary care level, can only take place in a registered pharmacy (and a pharmacy within a larger store will have a designated footprint registered as the pharmacy).  Registered pharmacies are regulated by the GPhC, and therefore must, by regulation (Pharmacy Order 2010), have adequate indemnity insurance in place.
• We agree with the proposal to permit healthcare professional regulatory bodies to remove a healthcare professional from their register, withdraw their license to practise, or take fitness to practise action against them, in the event of there being an inadequate indemnity arrangement in place. However given that owner or employed pharmacists are indemnified through the registered pharmacy in which they work by their owner / employer there could be a situation where the GPhC won’t register a pharmacist until they have insurance, but an employer won’t offer employment to a prospective pharmacist until they are registered with GPhC.  Currently the GPhC updates its register twice a month, and we would not want to see employers or pharmacists disadvantaged by delays in registration or confirmation of registration processes.  Such delays could result in clinical services not being available to patients through bureaucratic impediment.
• Any changes to set individual professional indemnity as a requirement of registration to the system for community pharmacy are likely to unnecessarily increase costs and complexity and be an added burden for the regulator, pharmacy owners and registrants alike.  The outcome of such a change would have no impact other than to increase costs and bureaucratic burden, in checking that regulated pharmacy professionals are suitably indemnified, by community pharmacy owners would ultimately be borne by the Government; through the regulatory burden element of the reimbursement package for community pharmacy.
• Not all pharmacists work in patient facing roles. If it is the public and patients that the Draft Order is seeking to protect through improved professional indemnity arrangements, we fail to see why a pharmacist who is not providing clinical advice and clinical services to the public should be expected to hold personal professional indemnity as a condition of registration, when they have no need of such indemnity. We would expect GPhC registrants to use their professional judgement when deciding if they need indemnity insurance.

The consultation can be read by clicking here. 

“The most pressing issue for pharmacy is to get clarity on what will and what won’t be required to be implemented at pharmacy level.  As it stands, the European Commission says that pharmacy level scanning will be necessary, but the MHRA has said it disagrees.  How can pharmacies prepare for what’s coming in such circumstances?  The Commission and the MHRA need to thrash this out and come to an agreed position before and not after the Delegated Acts are laid in 2014. There is a serious lack of engagement between the UK and the European Commission on this matter.”

The information pack, published by the Department of Health, gives the legislative background, outlines the minimum information that must be in PNAs and outlines matters to consider when making assessments.

Rob Darracott, Chief Executive of Pharmacy Voice said:

“It’s important that local authorities understand the difference between a good and bad PNA. While good PNAs can help to align pharmaceutical services with other local provision across health and social care, and maximise benefits from pharmacy services, a poor PNA risks legal challenge and represents a considerable opportunity loss.”

The guidance can be downloaded by visiting www.gov.uk.

Earlier in the year, the Pharmaceutical Services Negotiating Committee, Pharmacy Voice and the Royal Pharmaceutical Society produced a PNA guide for local authorities which was distributed to the chairs of HWBs and local authority chief executives, as well as NHS pharmacy advisers locally. The resource can be downloaded by clicking here. 

Care Bill

“Pharmacy Voice welcomes the proposal to integrate health and social care and the emphasis on prioritising people’s wellbeing and reducing people’s dependency on formal care services.

“Community pharmacists see patients frequently and get to know them so are often the first to notice if someone’s health is better or worse than usual. By integrating community pharmacy into the health and social care team their informal monitoring can help delay care needs from developing. The system should not only intervene at crisis point.”

Deregulation Bill

“The aim to reduce the burden of excessive regulation on businesses is welcome. Healthcare providers including community pharmacists and their staff  have a duty to provide care to the highest possible standard however the standards and guidance by which they are governed must be fit for purpose and not so onerous that they reduce the time staff have for delivering care.  Unlike other healthcare regulators the General Pharmaceutical Council also regulates and inspects pharmacy premises. NHS bodies and other regulators must work with GPhC to avoid overlap in regulation and inspection which would adversely affect patient care.”

National insurance contributions Bill

“Small pharmacy businesses make an important contribution to health and social care so naturally we welcome any measures that would allow them to invest more in patient care. The reduction of National Insurance Contributions (NICs) bills will reduce the costs of employment and will support small businesses aspiring to grow and expand.”

The guidance, produced by the Royal Pharmaceutical Society (RPS) and endorsed by NHS England, the Royal College of Nursing (RCN), The Royal College of General Practitioners, The Association of the British Pharmaceutical Industry (ABPI) and the Academy of Medical Royal Colleges (AoMRCs) sets out four principles of medicine optimisation that could revolutionise medicine use and outcomes:

• Aim to understand the patient’s experience
• Evidence based choice of medicines
• Ensure medicines use is as safe as possible
• Make medicines optimisation part of routine practice

 Rob Darracott, Chief Executive of Pharmacy Voice said:

“We welcome the work carried out by the RPS.  The signatures of the NHS Medical Director and the Chief Nurse on the foreword to this document should dispel any lingering doubt that improving patients’ use of medicines is not going to be at the centre of health care over the next few years.  We put medicines optimisation alongside safe supply and keeping people well as the future purpose of community pharmacy in our Prospectus last year and the initial blocks in place.  The New Medicines Service and targeted MURs should be the basis on which to build medicines optimisation programmes that contribute routinely to improved patient outcomes and provide the pharmacists’ contribution to managing long term conditions.  We may not have made the philosophical leap in every pharmacy that medicines optimisation is what we are going to be focusing on in the future, but it is crystal clear that we should.”

The guidance can be downloaded by clicking here. 

Rob Darracott, Chief Executive of Pharmacy Voice said:

“The judicious use of PGDs supports patient choice and access to self care, without compromising quality or safety or undermining the traditional route of initiation and supply. There have been many benefits to date, for example, the supply of emergency hormonal contraception through pharmacies under PGD arrangements has helped prevent many unplanned pregnancies.  Furthermore, community pharmacy NHS flu vaccination services reach people that a GP led service often doesn’t, mainly those in the under 65 at risk groups who may find it difficult to attend a GP clinic.”

Pharmacy Voice makes the following points in the submission:

• The best PGDs will include the ability of a pharmacist to directly refer patients, for example, to a sexual health clinic or an out of hours service.
• PGDs are used to improve patient access to necessary healthcare. This includes choice of provider as well as location.
• Some patients will choose to be vaccinated against flu even though they are not in an NHS at risk category. They may choose a pharmacy offering a private PGD as their provider. If this prevents them becoming infected then demand for NHS services may be reduced.
• The judicious use of PGDs can reduce GPs workload, to enable them to have more time to treat those with more complex needs.
• Judicious supply of antibiotics via PGD can improve the health of the patient and reduce risk to the local population. For example, after chlamydia screening, the provision of an appropriate antibiotic following a positive screen via a PGD would be completely justified.
• Opportunities for community pharmacists to become independent prescribers have been limited. Most community pharmacists practising as independent prescribers are working on a sessional basis in GP surgeries and are funded by the GP practice. This does not offer the opportunities for pharmacists or the improvement to patient access to services which was originally envisaged, although the potential for service redesign to utilise the potential of independent prescriber status has not been fully explored.
• Use of an existing PGD will not only save the commissioner time and money but will be simpler and safer for pharmacy owners who have pharmacists in several CCGs or  local authorities all with different PGDs for the provision of the same medicine.

The full consultation can be read here.