For 2017/18’s report, we carried out a targeted review of Standards 3 and 6 under Fitness to Practise. After considering the further information provided to us by the GPhC we were satisfied that the GPhC has met these Standards. This means that the GPhC has maintained its performance since last year and this is the third consecutive year it has met all of the Standards of Good Regulation.
Education and training: standards are linked to standards for registrants
The GPhC completed its review of its standards of education and training for the whole pharmacy team and identified a need to look at requirements for staff who work in pharmacies but are not registered. In the period under review it consulted on proposals to develop guidance to ensure a safe and effective pharmacy team. This included a proposal that the pharmacy owner and not the individual pharmacist should be responsible for making sure unregistered staff working in pharmacies are competent to carry out their roles. It also sought views on the proposal that it should stop approving individual training programmes and qualifications for unregistered staff. After reviewing the feedback it received the GPhC decided that more work was required to develop its future approach to the accreditation of courses and on the minimum competence level for unregistered staff. Consequently, it will continue to accredit courses for unregistered pharmacy staff, and the training requirements for unregistered members of the pharmacy team will continue as they are. Respondents also suggested that more information was needed on staffing levels, and the guidance it published in June 2018 included a section on what pharmacy owners should consider when deciding on the number of staff and the skill mix required to provide safe and effective pharmacy services.
Registration: registrants must maintain the standards required to stay fit to practise
We noted in last year’s review that the GPhC was proposing to change its arrangements for continuing professional development. Revalidation for pharmacy professionals was agreed introduced in October 2017 and came into effect in April 2018. Revalidation is designed to help registrants demonstrate how they provide safe and effective care to the public. Starting with registration renewals due by 31 October 2018, every time a pharmacy professional completes the annual renewal of their registration they will need to carry out, record and submit four CPD entries, one peer discussion; and one reflective account which demonstrates they are meeting the GPhC’s requirements of providing safe and effective care to the public.
Fitness to practise: anybody can raise a concern
When we look at this Standard, we take account of how regulators respond to complaints and concerns that they receive to ensure that they are not ignored. In January 2018, the BBC aired Inside Out: Pharmacists under pressure, an investigation into Boots the Chemist – looking into concerns raised by a whistleblower who had reported concerns about understaffing at Boots to the GPhC in 2015. The GPhC told us it had investigated the concerns, concluding that there was not ‘sufficient objective, independent evidence to suggest a risk to patient safety across the organisation’. It published guidance in June 2018 for pharmacy owners highlighting the need to make sure they have a safe and effective pharmacy team in every pharmacy. We also noted that the GPhC had been aware of the issues raised and responded to them, including hosting a ‘professionalism under pressure’ event in October 2016.
Fitness to Practise: the regulator will determine if there is a case to answer
In February 2018 the GPhC introduced new threshold criteria for use when deciding if a case should be referred to its Investigating Committee (IC). We will review the impact of the new criteria in our next review. We carried out a targeted review of this Standard as there appeared to be a discrepancy in the quarterly information we received which showed that the IC was only able to conclude 58-65 per cent of cases considered in any quarter. In addition, the number of cases where an outcome was recorded was greater than the total number of cases the GPhC told us the IC had concluded in each quarter. The GPhC clarified how it categorises cases. It told us it does not regard cases referred to the Fitness to Practise Committee (FtPC) as concluded because a final decision has not been made, and its rules allow the FtPC to send cases back to the IC for a final decision if the hearing has not yet started. Based on this additional information we could see that the IC concluded a high proportion of the cases referred to it. We are satisfied that this Standard remains met.
Fitness to Practise: cases are dealt with as quickly as possible
We conducted a targeted review of this Standard because we wanted to understand the performance information in more detail. We also noticed that the further improvements we had expected to see in the overall end-to-end time-frame for concluding cases had not yet materialised. We also identified a potential concern relating to the progression of cases to a final hearing following referral from the IC; and the proportion of cases concluding within the original number of hearing days allocated. The GPhC provided additional information. The performance information showed that the median time-frames in the three categories we report on had been sustained, with a slight increase in the overall time taken to conclude cases from 93.7 weeks in 2016/17 to 95 weeks in 2017/18. The GPhC identified an error in the information we held about the proportion of final hearings that concluded within the original number of hearings days allocated. The correction showed that the reduction in the number of cases that concluded within their original number of hearing days was similar to 2016/17. The GPhC told us the reasons why the data appeared to show a significant increase in the number of cases referred for a final hearing but that hearing has not yet started. The GPhC told us that the IC referred a large number of cases to the FtPC in quarter four of 2017/18. Based on the additional information and the explanations provided, we are satisfied that the GPhC has maintained its performance against this Standard. However, we will continue to monitor the GPhC’s performance in this area.