Response to the General Pharmaceutical Council's consultation on revised threshold criteria

The Consultation

We welcome the opportunity to respond to this consultation from the General Pharmaceutical Council (GPhC) on their revised threshold criteria. We recognise that the GPhC’s intention in updating the threshold criteria is to ensure they are in line with the revised standards for pharmacy professionals, which are due to be published in May of this year.

General Comments

Threshold criteria form an important part of the case handling process and can be a useful tool for those making decisions on which cases to refer on, and for complainants and registrants in understanding the basis on which cases move to the Investigating Committee (IC) stage. It is positive that the GPhC are seeking feedback on their proposed changes to the criteria.

We welcome regulators reviewing their approach to fitness to practise, looking at options for taking forward only the most serious cases, and disposing of cases consensually where appropriate. However, within the confines of the current legislation, there are limited and defined ways to dispose of cases transparently and accountably. Regulators need to respect the boundaries set by their legislation and the case law.

We welcome the inclusion of the over-arching objective and three limbs of public protection, which are helpful in framing the criteria around the purpose of regulation. However, it would be helpful if this was placed more prominently.