Concerns about GPhC consultation on ‘pharmacy team’

After only seven years, the General Pharmaceutical Council (GPhC) appears to be using its powers under the Pharmacy Order 2010 to provide guidance for everyone whose activities affect the services provided by registrants (pharmacists and technicians). This guidance is designed to elaborate on the existing standards for registered pharmacies, particularly those obligations directed at owners. So perhaps we can feel a little more confident that the GPhC finally acknowledges that the quality and safety of services from a community pharmacy are not all under the control, and hence accountability, of the pharmacist on duty. Not even if he or she is designated the responsible pharmacist.

But there are a few flaws in the rationale behind their latest consultation on the ‘pharmacy team’ (Pharmaceutical Journal online 20 July 2017, doi: 10.1211/PJ.2017.20203234), not least the assumption that the professionalism expected of individual registrants will automatically characterise the attitude and behaviours of those who own or operate pharmacies. The focus of the guidance seems to be overwhelmingly skewed towards in-pharmacy support staff (now an outdated term, apparently) and managers of pharmacies. There is still little recognition that for at least half of British pharmacies, the owners are international enterprises whose prime concern is profitability and shareholder return. Decisions taken by managers of business centres, marketing and promotion departments and training divisions at the ‘top’, not to mention performance management, targets, budget setting and staffing deployment at regional and line manager levels have significant impact on the ability of the pharmacist to exercise patient-facing professionalism at all times. Perhaps these functions are implicit in the introduction term “leading and managing teams”, but this is not borne out by the succeeding eight heads of guidance.

As with the standards for registered pharmacies, (and indeed the ineffectual guidance for pre-registration tutors who also do not control the resources to do their job properly) the expectation is that pharmacy owners are committed to providing the right environment for good quality pharmacy care. Pious hopes such as pharmacy owners (will) “take responsibility for considering how best to organise and train their teams …” or “… have considered whether they can make protected time available for training” are slightly amusing. And what if they do not? Unlike the rigorous and detailed powers that the GPhC has to discipline pharmacists, the available sanctions against registered pharmacies are (and always were) so constrained as to be practically worthless. Yes, a pharmacy owner can be disqualified from ownership or specific premises can lose their registration but, as one commentator asserts in the Dale and Appelbe’s ‘Pharmacy and Medicines Law’ (11^th edition)^[1]
, “…proceedings are rare and only likely to be brought in the case of a business conducted in wholesale disregard of the rules governing the profession or in flagrant disregard of the need to protect patients and the public”. One might ask whether the time has come for the Care and Quality Commission (CQC) to take over regulation of pharmacies along with just about every other health care establishment. The CQC does make stringent requirements of those who own, operate and centrally manage ‘service providers’ and at least occasionally seems to enforce them.

Joy Wingfield

Honorary Professor of Pharmacy Law and Ethics

University of Nottingham