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GPhC got its pre-reg exam approach wrong 


GPhC got its pre-reg exam approach wrong 

The General Pharmaceutical Council demonstrated a failure of leadership and imagination to reform pharmacy education, says Mohammed Hussain... 


As Covid-19 spread, the General Pharmaceutical Council had to decide whether or not to postpone last year’s preregistration exam. It was a fateful decision. 

The implications for individuals but also the profession and the NHS were significant. The exam could not be conducted as normal, social distancing was a new term, the first national lockdown was in force. No-one knew what was to come but we could see the nightmare unfolding in Italy. 

Preventing the 2020 cohort of pharmacy preregistration candidates entering the profession would have been unconscionable when the NHS needed every person to save lives.  

The options were to hold a Covid-secure exam, go online as universities had already done so, waive the entrance examination for this cohort altogether or establish a provisional registration, with the exam postponed. 

The GPhC chose the provisional registration approach with a delayed exam. Prov-regs were able to progress from pre-reg to the register, they were able to work as pharmacists under the supervision of a senior pharmacist (this could simply be that the senior pharmacist was contactable). 

They could be a Responsible Pharmacist, working in a community pharmacy as the sole pharmacist. They could not be a locum pharmacist. A prov-reg can supply medicines, conduct clinical and final checks, undertake medication reviews and vaccinate. 

Once the decision on provisional registration had been made, the purpose of the exam seemed obsolete and an alternative, reformed approach was needed. 

These are individuals who worked for nine months as pharmacists, so forcing an exam on them during a pandemic feels like a failure to follow the inevitable logic of provisional registration. 

Either provisional registrants are safe and competent or they are not. An exam will inevitably lead to some not succeeding, so what is the consequence for them and their careers, or indeed all the prescriptions they have dispensed, the patients they have seen or the vaccines they have administered? 

It is perverse that those who have been able to work as pharmacists through a pandemic could face the prospect of being removed from the register, their year of real world experience in the toughest of health care contexts and responsibility discounted as if it had never happened. 

The unique experiences of this cohort deserves a unique approach. The retrospective pre-reg exam demonstrates a failure of leadership and imagination to reform pharmacy education. 

Alternatively, this cohort could demonstrate their competence and safety by using the revalidation mechanism. Revalidation is meant to assure the public that all registrants are safe and competent and recognises that no initial level of competence, sometimes decades ago, is sufficient. 

It is also worth reminding ourselves there are still many registered pharmacists who never sat the exam as it was only introduced in 1997. There is no argument these individuals should now sit the pre-reg exam. 

An enhanced revalidation mechanism for the prov-reg cohort would be a far more suitable and appropriate means for ensuring ongoing competence. It could be used as a model for further modernisation of the initial pharmacy education and training system. Pharmacy technicians as registrants are able to demonstrate their safety without undertaking the pre-registration exam. 

What is most damaging and disappointing about this scenario has been the lack of compassion and competence shown by the regulator to the individuals most affected. After determining the exam needed to be undertaken, the GPhC advised that students would have to sit an in-person exam in an exam centre (with some exceptions allowed on an individual basis). 

Questions about why this was not possible last year were immediately raised, especially as universities had done so. Indeed, other professions managed to hold their registration exams over the summer last year. 

The latest disappointment was news that after having stated in January that the remote assessment was possible for some individuals, the regulator announced in February it would not allow a number of overseas students to sit the exam from abroad where there was a greater than five-hour time difference to the UK and they would have to return to the country to sit the exam in person. 

This had major implications on students in terms of cost, potential quarantine, and stress at such short notice. It smacked of a lack of compassion. It introduced a new inequality, targeting directly those candidates who may perform less well in the exam even under normal circumstances. 

The GPhC does not employ many pharmacists in senior roles but it does have a governing Council of 14 members, split equally between registrant and lay members. We should look to the whole Council and the registrant members in particular to step in. The ultimate responsibility sits with the governing Council and they need to act. 

The least we can expect from the regulator is clear communication. All else can be debated but equity and compassion are expected and we have had neither. 


Mohammed Hussain is a non-executive director at Bradford Teaching Hospitals Foundation Trust and an independent contractor. 

A response from the General Pharmaceutical Council 

We are very aware of the significant stress and pressures that candidates have experienced during the pandemic. We greatly appreciate their patience and the enormous contribution they are continuing to make to the care of patients and the public during this hugely challenging time. 

Our position remains that passing the registration assessment is an essential step towards full registration. It is not feasible to introduce alternative routes to registration for provisionally-registered pharmacists that would uphold standards, protect patient safety and be fair to all candidates.

We carried out a thorough and compliant procurement process to make sure that we could hold an online assessment that meets our rigorous requirements for quality, security and accessibility.

We are aware that candidates overseas have raised concerns about not being able to sit the March sitting of the registration assessment in their current country of residence. We are carefully considering the points that they and the other candidates affected by this have raised with us.

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