Supervision by pharmacy technicians at hospital aseptic facilities should be considered in an entirely separate consultation, PDA said.
The Royal Pharmaceutical Society (RPS) and the Pharmacists' Defence Association (PDA) have responded to the Department of Health and Social Care (DHSC) consultation on pharmacy supervision, which was launched in early December last year.
The DSHC set out proposals to amend the Medicines Act 1968 and The Human Medicines Regulations 2012 to allow registered pharmacy technicians to work without direct supervision, which in turn will help free up pharmacists to provide more clinical care and reduce GP appointments.
While the RPS supported the legislative change, it highlighted a range of topics that should be considered and clarified in regulations and guidance.
According to RPS, the new concept of ‘authorisation’, including around documentation, accountability, and the role of superintendent pharmacist and responsible pharmacist, needs clarification.
Additionally, they have urged the DHSC to consider workforce planning and investment for implementing the proposed changes, as well as to raise public awareness about them.
RPS President, Professor Claire Anderson, described this consultation as “a welcome step towards supporting the clinical role of pharmacists and making the most of the skills within pharmacy teams to support patient care.”
Nevertheless, she underscored the importance of maintaining consistent patient access to pharmacist expertise when these changes are implemented.
“Beyond legislative change, pharmacists and pharmacy teams will require support, both in terms of workforce development and adequate investment, to enable the consistent provision of high-quality pharmacy services.
“We need a more robust approach to supporting professional development to boost staff retention in all sectors of practice so that pharmacy teams can continue to flourish wherever they may work.
Anderson has urged the government to “reflect on the consultation responses and bring forward legislative change as soon as possible.”
The DHSC consultation is deemed by the PDA as “one of the most important government consultations for pharmacists in decades,” which will shape the future of pharmacy practice for many years to come.
The PDA stated that its current response to the DHSC consultation is based on the Supervision Practice Group report, published in August 2023.
It suggested that the DHSC could establish a framework for the safe delivery of pharmaceutical care and pharmacy services through the nationwide community pharmacy network, as outlined in the Supervision Practice Group Report.
However, these proposals alone will not be enough, the PDA said, adding that it is crucial to ensure that the rules and standards produced by the GPhC/PSNI (following consultation later in the year) are relevant and supportive of the profession.
In its response to the DHSC consultation, the PDA highlighted that “the physical presence of the pharmacist in a community pharmacy” is the bedrock of community pharmacy practice, and that this crucial aspect “must be explicitly stated in legislation” and not merely be inferred as is currently the case.
Regarding the proposal to allow a pharmacist to authorise a pharmacy technician to undertake the preparation, assembly, sale, and supply of medicines, the PDA said that such an authorisation “must only operate in the presence of the Responsible Pharmacist (RP).”
Further, it said, any authorisation given by the RP “must always be documented digitally or in writing” to maintain full records and it must be a two-way conversation with the pharmacy technician and “must be agreed and not be imposed.”
The PDA also pointed out the consultation didn’t cover the criteria for the absence of a pharmacist, which are vital when considering supervision.
The association didn’t support proposal 3 of the DHSC consultation (supervision by pharmacy technicians at hospital aseptic facilities) because it is “not suitable for consideration as part of the consultation on supervision.”
“Quite differently from in a community setting, pharmacy practice in hospital is undertaken within a NHS management structure, where certain aspects have entirely different governance frameworks and skill mix.”
“Proposal 3 deserves to be considered in comprehensive detail as part of a whole system consultation and in an entirely separate consultation,” the PDA said.
The association has appealed to its members to respond to the online consultation response survey, which closes on 29 February 2024.
