This month both myself and Richard Cattell have been invited to join an advisory group to produce professional standards led by the Royal Pharmaceutical Society. This is a major initiative that we have been keen to get off the ground to form a series of evidenced based professional standards which are achievable, not aspirational, and build on the minimum standards set by the regulator for a safe systemThese would be used to designate a quality system. They could also be used to link into both capacity planning, ensuring the right numbers and type of staff, and credentialisation, ensuring those staff can be identified as having the right skills. This will be a recurring theme in my reports over the next 6-9 months as the RPS has set a challenging deadline for completion of March 2012.
We began our discussions on the Higher Education consultation, issued by the Department of Business Innovation and Skills, focusing on the three main themes of pay as you earn based on the new tuition fees, increased competition between providers and using increased social mobility.
Consultations responses during the summer are reduced and this month their was only a response on a consultation from the MHRA on whether Pariet gastro-resistant tablets should be reclassified from a Pom to P medicine. The other response on the review of the procurement of seasonal flu vaccine was more interesting in that it started out as a potential joint response with the Royal Pharmaceutical Society. Guild took advantage of its links with the Procurement and Distribution Interest group (PDIG) and as there was a fundamental difference in viewpoint we provided a separate and sole response. The RPS response produced in conjunction with Pharmacy Voice and PSNC was influenced by GHP and RPS members in hospital and primary care but reached different conclusions to many of the questions.
I received this month an issue of Insight the “in-house” magazine of the Pharmacy Defence Association and I was interested in how much space they devoted to ourselves. In addition, in an accompanying letter to this edition, they raised the issue of whether the readers feel union representation for hospital pharmacists is important (I think you can guess this met with a categorical yes) and what kind of representation is wanted by their non-member readers. It also suggested that the two organisations joining forces would be in the interests of hospital pharmacists, whilst highlighting, that in their opinion GHP has not persued this approach but also recognising the fact that the two organisations appear at odds on a range of issues as subsequently described.
The final question raised was whether this idea of joining forces should be persued with vigour or if the two organisations should continue to “go it alone” . GHP Council have in practice always sought to work with other organisations from a professional, clinical and industrial perspective and on many issues we have common views with the PDA. We accept that this commonality may not always be expresssed in the same tone or certainly volume of rhetoric nor often by following the same methods of seeking to achieve objectives. For example on the issues of resonsible pharmacist we would support the PDA stance that the RP must have appropriate level of autonomy and authority over accountable matters including the sole decision on whether an absence is undertaken– although there are already so many records that we would not welcome additional documentation and as I described last month we have a set of principles to seek a modern patient facing definition of supervision. However their statement that Hospitals should be exempt needs clarification as hospitals are already exempt under section 55 of the Medicines Act from the requirement to having a responsible pharmacist in that they only apply to registered (hospital) pharmacies. In addition it is unclear if they want this exemption to apply to all providers including those multiples that now operate some hospital pharmacies. This topic also illustrates the difference in approach in that in September 2010 the PDA made a public statement calling for a suspension of the RP regulations whereas GHP recognising that the problems in the hospital service were less to do with the RP regulations themselves and more to do with the outdated Medicines Act. Hence we worked with the DoH, MHRA and regulator to agree an interim joint advisory document whilst the Act was reviewed over the next 5 years.
In answer to the second question on “joining forces” I must admit that on a personal level I joined GHP as I wanted an organisation that specifically and solely represented on a professional and industrial level pharmacists working mainly in the NHS. I wanted one that could represent those views and not have them drowned out by members from other branches of the profession. I personally also sought an organisation that had experience and links to a major Trade Union that could provide an industrial infrastructure, representation and expertise in the workplace. Although the provision of liability insurance was not a major driver for me GHP Council has in the last few years recognised its appeal for some members and the true market cost with the provision of an additional PLI policy costing £15 per year for members as an optional benefit.
This GHP policy was itself the lead topic in a two page spread in the PDA magazine and the major issue raised in the magazine is whether members undertaking pharmacy locums are covered in this additional policy? Having discussed the issues in the article with the Head of Health Fiona Farmer and the policy underwriters at Unite I can re-confirm for the record to Insight readers that
“Pharmacists who are members of GHP and carry the additional Unite PLI will receive Trade Union support and have cover in place when working for a pharmacy employer, service company or other Pharmacist who has PLI cover whether as a direct employee or a self-employed locum.
This cover includes extended roles such as supplementary and independent prescribing. It also provides for the cost of legal representation at a coroner’s inquest or inquiry in respect of any death, the cost of defence of any criminal proceedings brought or in appeal against the Pharmacist for an offence of criminal manslaughter and for proceedings in any court arising out of any alleged breach of statutory duty, (including Corporate Manslaughter). “
We have always accepted that PLI policies are not always required. The traditional GHP Council view on professional liability arrangements has always been that, if a pharmacist works only in hospital, s/he is covered by their NHS employer’s vicarious liability arrangements. We totally accept and openly admit that this alone is sufficient for completion of the General Pharmaceutical Council requirement for professional indemnity cover. However we also accept that some members, myself included, want additional support either as prescribers or working within or outside the NHS for certain legal defence and potential civil liability costs in addition to the trade union support already providing the representation in the workplace. This NHS nationally recognition for representation covers Disciplinary and Grievance Issues, Sickness procedures, Organisational Change and internal inquiries. This Union membership providing support beyond the workplace through to Employment Tribunals for disputes that cannot be resolved with the employer and it also provides continued representation to the regulator’s disciplinary processes for practice undertaken during employment.
We also have openly stated that NHS employers’ liability will not cover work in community pharmacy and although community pharmacy employers must have their own employer’s vicarious liability arrangements, as whether or not the employer will seek to recover damages from the employee is not clear cut - although for the record, the National Pharmaceutical Association (NPA), the main insurer has never pursued a locum for recovery of damages to date. In recognition of the unclear situation, we have thus through Unite, provided the additional policy supporting members that also undertake pharmacy locums.
Perhaps I should not say this as there is a danger of being quoted out of context, but maybe choice is sometimes of benefit and pharmacists in the managed sector now have a choice of professional and industrial representation.
Finally I finish with one of the downsides of being in a large organisation of 1.5 million members. This is that we need to constantly keep track of the GHP members. So if you do not receive GHP correspondance like the annual report , or details of the annual conference through the post then please check your membership record with Unite or when asked to update membership details please ensure that you have been allocated to job code 65.