The Government has never been able to explain the rationale behind its thinking satisfactorily, but the plan to allow pharmacy technicians to operate a pharmacy in the absence of a pharmacist has never been far from its thinking. Having consistently tried and failed to win the arguments and therefore change the legislation in parliament with the support of the profession since 2006, the Department of Health continues to try and advance this policy. Currently its Rebalancing of Medicines Legislation and Pharmacy Regulation programme board is studying the supervision arrangements and seeking to make changes.
Judging by the fact that the government intention has been to enable a pharmacy to be operated by pharmacy technicians in the absence of a pharmacist for many years, it is perhaps safe to assume that this programme board will receive considerable encouragement from the government so as to deliver upon its long standing ambitions. This is of concern to many within the profession.
There is no doubt that the current supervision rules need to be updated, however, the PDA has always maintained that the new rules on supervision and also enhanced roles for pharmacy technicians must seek to make the pharmacist more accessible to the public in the community pharmacy and not less available by dint of not being in the pharmacy at all. The PDA has consistently argued that operating a pharmacy in the absence of a pharmacist will impact upon the safety of the public, will be damaging to the profession and it will also harm the unique feature of the community pharmacy which is currently the place that provides easiest access to a healthcare professional for hours that are often longer than those of a GP surgery.
They are trying to change the two hour absence rule
Currently, under the two hour rule when a pharmacist is absent, the pharmacy can do very little when it is open to the public. For example, P medicines cannot be sold and no prescriptions can be dispensed and handed out to the public. Arguably, this is the main reason why the two hour absence provision has thus far made very little detrimental impact upon community pharmacy practice – because it is virtually inoperable.
Despite these limitations however, some large employers have found clever ways to exploit these regulations for their commercial gain. In some instances the ‘two hours permitted absence’ has been used by certain pharmacy employers to operate their pharmacies for two hours prior to opening where they dispense medicines for residential homes before the arrival of a pharmacist by requiring their RP to retrospectively sign on upon arrival. In this way they have extended their operational hours and because they do not pay the pharmacist for this time, as they argue that it is not really work, they do not incur the cost of additional pharmacist cover. This demonstrates how a permitted absence designed with the intention of benefitting patients, can simply be used instead to improve profits by reducing operational costs.
However, the limitations on the current arrangements could soon be lifted as the Rebalancing Committee is now considering what should be permitted to happen while the pharmacy is open to the public in the absence of a pharmacist.
In April, a meeting was held involving representatives of the government, the Rebalancing board and various pharmacy bodies including the PDA. This meeting considered what should be permitted to occur in the two hour absence of a pharmacist – the ‘Elephant in the room’ was discussed.
Pharmacy Technicians want to sell P medicines with no pharmacist present
Representatives from the Association of Pharmacy Technicians UK argued that registered pharmacy technicians should be allowed to hand out dispensed prescriptions, and sell P medicines in the absence of a pharmacist and that they would be able to hold medicines back if the pharmacist needed to have a word with the patient. They felt that this would allow the pharmacist to ‘pop out for half an hour’. But did they consider for one moment what would happen if a patient coming into the pharmacy while the pharmacist was absent, for a relatively innocuous purpose like the collection of a simple dispensed medicine was actually quite ill at that particular moment and required an urgent clinical intervention? However, because they lacked the clinical expertise to identify that a problem existed in the first place, they failed to take any necessary actions.
Had they imagined the effect upon the safety of patients if this half an hour were to be extended to two hours, then four hours and ultimately eight hours as is entirely possible if the initial two hours is agreed in the first place. A situation where a pharmacy would be allowed to operate without a pharmacist at all?
The PDA is aware that the Company Chemists Association has also provided the Rebalancing Board with its views on what could be done in the absence of a pharmacist. Although we have not seen this document, we believe that it is safe to assume that they will be arguing for changes to the absence provisions which enable their pharmacies to become operable in the pharmacists absence.
The PDA’s position remains as described above, we do not believe that the patient’s interests are best served by a pharmacy operating in the absence of a pharmacist.
All of these views are now being considered by the board, albeit against the background of significant encouragement from the government to deliver change.
If the board does recommend that a pharmacy with an absent pharmacist should be allowed to operate in the same way that it would had the pharmacist been present, then all of this will occur whilst the absent pharmacist takes personal responsibility for anything that happens in their absence due to the implications of the Responsible Pharmacist regulations.
Remote Supervision – Not at all needed
When the idea of remote supervision was first put by the government in 2006, it argued that the benefits of pharmacists being able to leave the pharmacy and deliver a range of new and professionally fulfilling services to the public out in the wider community outweighed the risks of not having pharmacists available in the community pharmacy. Indeed, the government argued (back then), that unless pharmacists could develop these new services, then this would likely damage the profession over the long term. However now, nearly a decade later, there are more pharmacists available than anyone dreamed about when this risk vs benefit analysis may have been undertaken in 2006.
With the rate at which so many newly qualified pharmacists are being produced, within a couple of years, there’s likely to be several thousands of pharmacists looking for employment. Consequently, the opportunities out in the community can now very easily be delivered by pharmacists, without the need for the pharmacy to be left with no pharmacist on the premises.
There is no longer any need to introduce the risks associated with operating pharmacies without pharmacists. The question that needs to be asked is why the government is still attempting to introduce risks to the public by continuing to proceed with its policy on remote supervision, when these risks are now entirely unnecessary.
It is vital that the views of those who potentially stand to gain through the diminution of the pharmacist’s role in the pharmacy are not the only views that are considered by the programme board.
To assist the Rebalancing programme board with their work, alongside the views provided by the Association of Pharmacy Technicians, who at best represent a few hundred members mainly from the hospital sector and also those of the representatives of large employers, it is important that they also receive the views of front line employee and locum pharmacists.
It is extremely important that member’s views on what should or should not happen in a pharmacy in the pharmacists absence is made clear to the Rebalancing Board and we ask that members complete the attached survey. We will use the results to try and impress the concerns of practicing pharmacists on members of the board.
Since Remote Supervision was first mentioned by the Government it has blighted the profession, it is a threat to patient safety and to the very essence of the profession which must be challenged. We appeal to all pharmacists to support our efforts and we ask you to support our campaign.
Please respond to the survey enclosed and encourage your colleagues to do so.
The survey has now closed, but the questions asked can be found here for reference:
We thank you for your support and we will continue to update you on any progress.
Article published in Insight Spring 2015