PDA respond to the GPhC’s consultation on initial education and training standards for pharmacists

The GPhC (General Pharmaceutical Council) consulted from 9 January 2019 to 3 April 2019 on changes to the initial education and training standards for pharmacists. The PDA have expressed concerns about the GPhC proposals in its consultation response.

Tue 9th April 2019 The PDA

Broadly speaking, we would like to see the format of pharmacists’ training aligned with that of other healthcare professionals, with structured professional career frameworks for pharmacists in the different sectors of practice, underpinned by standardised pre and post registration training pathways.

However, we found the GPhC’s proposals to be severely lacking in detail. The considerable adjustments to education and training proposed within this consultation would have a significant impact on the future of the profession.

Our main recommendation was that the GPhC should not make any changes as a result of this consultation. It should consider the responses to this consultation and put forward a more detailed consultation at a later date to allow better informed responses.

Other recommendations to the GPhC included:

  • Revisions to the learning outcomes and the selection and admissions process
  • The need to include an indicative syllabus
  • Retain important regulatory requirements that underpin patient safety, such as the requirement for the pre-reg tutor to have worked as a registered pharmacist for at least three years in the UK in the sector of practice in which they plan to work as a tutor
  • Ensure the standards do not allow pharmacy technicians to act as “supervisors” to pharmacists, to avoid diminishing the quality of pharmacists’ education and training
  • The terms “designated learning in practice supervisor” and “supervisor” have different meanings in these proposals, and this could be misleading or confusing. The GPhC should only have one person acting as a tutor (or “designated learning in practice supervisor”) to a pre-reg and that person alone should be considered to be the pre-reg tutor / supervisor
  • Specify which standards and criteria would apply to the university and which would apply to the employing organisation, and enforce them robustly
  • Make it clear that pharmacy students will have employed status with accompanying employment rights during their pre-reg training period
  • Clarify funding arrangements so that pharmacy students don’t have to pay for five years of tuition fees and do not lose a year of earning potential as a pre-reg, and ensure that employers and universities are appropriately reimbursed for the work they undertake
  • If the UK healthcare system needs more pharmacists, that should be achieved by making the profession more attractive to work in. It is not the GPhC’s role to “widen opportunity of access to university and healthcare professions”. The GPhC must not passively accept or actively promote a reduction in standards of entry in to university; this would lead to the diminution of professional standards and reduced patient safety.
  • The GPhC should set minimum academic entry requirements to be attained of specific grades at A-Level as a minimum (or equivalents according to the National Qualifications Framework). This should be evidence-based, considering the standards that need to be maintained in the profession, and enforced rigorously. We highlighted that in 2016/17, 25 out of 33 universities required ABB or better but 39% of new intake students were accepted on to courses having not attained the required A-level/Highers Grades.
  • Progress assessment meetings must still require sign-off by the pre-reg tutor, who must be a pharmacist. The GPhC must not allow non-pharmacists to conduct these meetings. The current proposals state that the meetings may be conducted by “delegates”.


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The Pharmacists' Defence Association is a company limited by guarantee. Registered in England; Company No 4746656.

The Pharmacists' Defence Association is an appointed representative in respect of insurance mediation activities only of
The Pharmacy Insurance Agency Limited which is registered in England and Wales under company number 2591975
and is authorised and regulated by the Financial Conduct Authority (Register No 307063)

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