Richard Hough discusses the consultation on the regulation of unregistered pharmacy staff

On 11 October 2017, the General Pharmaceutical Council (GPhC) concluded a 12-week consultation on guidance for pharmacy owners about ensuring a safe and effective pharmacy team. The GPhC regulates pharmacists, pharmacy technicians and registered pharmacy premises. However, many pharmacy staff are unregistered and outside the scope of GPhC regulation, including delivery drivers, dispensers and medicines counter assistants and some pharmacy managers.

The consultation guidance is intended to support the GPhC’s standards for registered pharmacies by focusing on unregistered pharmacy staff. Pharmacists have a professional obligation to ensure that dispensing, pharmacy and medicines counter assistants are competent for the areas in which they work. The guidance does not affect the accountability of individual pharmacists, but provides that pharmacy owners should be jointly responsible for ensuring that unregistered staff are competent for their roles. The guidance is to replace the GPhC minimum training requirements that were approved in 2011.

Other policies for support staff have been in place since 2010, but these are now viewed as outdated and inconsistent with the modern approach to quality governance and teamwork. The consultation document states that the current framework fails to reflect the diversity of roles within pharmacies, and a more flexible outcome-focused approach is necessary to address the needs of current and future patients.

The GPhC’s regulatory powers do not extend to unregistered staff and its statutory powers of accreditation for training courses are explicitly for courses leading to a regulated position. The GPhC proposes that pharmacy owners should be responsible for selecting appropriate training for staff, but be accountable to the GPhC for their decisions.

The guidance (summarised below) is based upon the GPhC’s principle that “staff are empowered and competent to safeguard the health, safety and wellbeing of patients and the public”, and focuses on pharmacy owners’ responsibility for unregistered staff.

Governance
Pharmacy owners should ensure that staff numbers and roles are appropriate for the services they provide (including suitable plans to cover absences) and that everyone in the team knows their own, and each other’s, duties and responsibilities. Pharmacy owners should be open to innovation and the development of roles in line with the evolving nature of modern pharmacy practices. Effective risk management procedures should be implemented and all staff should know how to assess and reduce risks in their roles. Unregistered staff should work only within the limits of their competence and refer to pharmacy professionals where necessary, and everyone in the team should be able to raise safety concerns or suggest improvements. All staff should uphold the principles of confidentiality and privacy and should understand their responsibilities for record keeping and the storage and sharing of information.

Training, skills and development
Pharmacy owners should ensure that all staff are appropriately trained and that training records are retained. Training requirements should be flexible to address the needs of patients (both generally and specifically in the local area). Role-specific inductions and competency assessments should be undertaken for all new staff to identify training needs, and those dispensing or supplying medicines must meet the minimum training requirements. Unregistered staff requiring training to achieve competency should be enrolled on appropriate courses within 3 months of starting. Continuous learning and development for all staff is also vital. Pharmacy owners should ensure that procedures are in place to identify and address skills gaps at an individual and team level so that the knowledge and skills of all staff are up-to-date and appropriate for the services provided. Interpersonal skills are also important in providing the quality of care that patients expect. Pharmacy owners should ensure the provision of compassionate care which is adapted to the needs of the patient, identifying vulnerable patients and acting accordingly and taking steps to overcome communication barriers.

Management
Pharmacy managers need not be registered pharmacists, but have a significant influence on culture and practices within pharmacies. Pharmacy owners should assess and ensure the competence, skills and experience of their managerial staff so that they can carry out their roles without compromising safe and effective care. Managers should understand the relevant legal and regulatory frameworks and the obligations and responsibilities of different members of the pharmacy team, as well as the need for pharmacy professionals to prioritise patient safety and wellbeing.

What’s next?
The GPhC aims to agree the new framework by the end of 2017 after having considered responses to the consultation. The overarching theme of the guidance, and the direction in which the GPhC appears to be steering the regulatory framework, is that pharmacy owners need to take charge of their businesses at all levels and, above all, must be responsible and accountable to the GPhC for the safe and effective provision of pharmacy services by the whole pharmacy team. The current policies and minimum training requirements continue to apply in the meantime.

Richard Hough is partner, pharmacist, and head of healthcare at Brabners LLP. Contact him on 0151 600 3302, or at richard.hough@brabners.com.