RPS Strengthening Pharmacy Governance (Supervision)

Policy Position Statement

RPS believes that supervision legislation is needed to protect the public. We advocate for changes to the current legislation to enable progressive, safe, and effective pharmacy services within a modern and advancing NHS.

RPS supports the principle of moving specific components of legislation to regulation. Any changes should be supported by clear professional guidance.

The following eight principles should apply to any change:

  1. Pharmacists and the pharmacy team should be accessible, approachable, and available in a reasonable timeframe for patients READ MORE
  2. Supervision by a pharmacist and delegation of activity should be decided by the Responsible Pharmacist (RP) supported by regulation to ensure appropriate pharmacy services can continue in their absence READ MORE
  3. Pharmacists must be enabled to expand their professional and clinical services for better patient outcomes READ MORE
  4. Pharmacy technicians, as registered professionals, must be enabled to take increasing responsibility for managing technical tasks such as routine dispensary processes READ MORE
  5. A pharmacist can only be the Responsible Pharmacist (RP) for one pharmacy at any one time READ MORE
  6. Digital opportunities should be harnessed to enable pharmacists to undertake more professional roles from pharmacy premises READ MORE
  7. A shared understanding and interpretation of supervision legislation is needed. This should be supported by clear up to date professional guidance while maintaining a focus on patient safety and wellbeing READ MORE
  8. Any changes to legislation should lead to improved patient care, not lead to an increase in risk to patient safety, and any changes in workload must be considered. READ MORE

Principle 1

Pharmacists and the pharmacy team should be accessible, approachable, and available in a reasonable timeframe for patients.

Community pharmacists are among the most accessible healthcare professionals. This accessibility and approachability means that pharmacists can provide patients with medicines advice and support when needed.

The pharmacy team have the skills and knowledge to help support patients and escalate queries appropriately for the pharmacist's attention within a reasonable time. With pharmacies offering more services which require time in a consultation room, the expectation of access needs to be managed carefully.

Principle 2

Supervision by a pharmacist and delegation of activity should be decided by the Responsible Pharmacist (RP) supported by regulation to ensure appropriate pharmacy services can continue in their absence.

The current legislation allows pharmacists to be absent from the pharmacy for up to two hours. However, during this time, patient care is currently impacted in terms of the supply of medicines, and access to professional advice.

Change required

Legislation change is needed to enable appropriate medicines that have been clinically checked, dispensed, and accuracy checked, to be given to a patient or their representative when the pharmacist is signed in as RP but absent.

This would require that a pharmacist has approved the medicines are suitable to be given to the patient with no planned further intervention by the pharmacist. Given to the patient includes handed out by trained pharmacy staff when the pharmacist is not present, delivered by a delivery driver, or put into a vending machine. In all three scenarios, arrangements must be in place to enable the patient to ask for a consultation with the pharmacist, using technology or in person, within a reasonable time.

There should be no change to the sale of Pharmacy (P) medicines as it is important that the pharmacist can intervene when these medicines are sold.

This category is important to allow patients' access to certain medicines without the need for a prescription.

Any change in the need for a pharmacist to oversee P medicines sales and be able to intervene could affect future POM to P switches and have a detrimental effect on patients' ability to self-manage appropriate conditions.

Supply of P medicines via NHS services such as Pharmacy First and Common Ailment Services require a pharmacist to be present. These services have achieved equity of access for deprived populations and therefore a change to permitting the sale of P medicines without a pharmacist present would introduce a new inequity.

Principle 3

Pharmacists must be enabled to expand their professional and clinical services for better patient outcomes.

It is essential to future-proof the supervision arrangements to ensure community pharmacists can provide an expanding range of professional services for patients. This includes regular, planned, and ad hoc patient consultations in consultation rooms within the pharmacy premises and the provision of symptom assessment, advice and/or treatment.

Therefore, patients need access to a pharmacist, and long periods of absence from a pharmacy are undesirable. This must be balanced against provision of the current services which may require an occasional home visit by a pharmacist to ensure a patient is fully involved in decisions about their medicines.

Pharmacists need to be able to make professional decisions to support the best care and outcomes for their patients. It is not possible to plan for every eventuality and professional decision making is a skill, this must be encouraged and supported by robust record keeping.

Change required

Successful provision of all professional roles can be achieved through a combination of good skill mix in pharmacies and clear interpretation of the current supervision legislation.

Pharmacists must have the confidence to delegate to pharmacy technicians and other staff according to their skill set and competences underpinned by clear frameworks for establishing competency in pharmacy staff.

Appropriate staffing levels, competencies, and clearly defined processes which trigger appropriate referral to the pharmacist, when necessary, are key to delegation and freeing up time for clinical care achieved by appropriate workforce planning.

This would enable the pharmacist to leave the pharmacy premises for short periods, for example to undertake a home visit, while still being contactable if advice is required urgently using technology. If absences were short and infrequent, this would avoid reduced access to services provided directly by pharmacists.

Therefore, clearer interpretation of legislation around the pharmacist being able to intervene in a medicines or advice supply situation is required.

Workforce planning is needed in each country to ensure continuity of workforce for pharmacists and pharmacy technicians and that staffing levels are of sufficient level to avoid reduction in pharmacy services and face to face access to a pharmacist when desired.

Principle 4

Pharmacy technicians, as registered professionals, must be enabled to take increasing responsibility for managing technical tasks such as routine dispensary processes.

RPS recognises the important roles of pharmacy technicians as registered professionals who are accountable for their responsibilities and should be encouraged to work to the top of their competencies.

Recognising and enabling the roles of pharmacy technicians to lead on the technical processes/services within the pharmacy and undertake accuracy checking, where appropriate, will support pharmacists to fully maximise the opportunities in the current legislation.

Defined career pathways for pharmacy technicians would support with retention and recruitment into the profession. More frameworks for quality assurance which enables the pharmacy technicians to develop are needed within pharmacy.

Principle 5

A pharmacist can only be the Responsible Pharmacist (RP) for one pharmacy at any one time.

It is essential to have professional oversight by a pharmacist in every community pharmacy. RPS is opposed to remote supervision and believes that patients require access to a pharmacist, in person if desired, and long periods of absence from the pharmacy are undesirable.

Some pharmacies will require more than one pharmacist on site to safely deliver the range of medicines supply, clinical and public health services required by the NHS.

Principle 6

Digital opportunities should be harnessed to enable pharmacists to undertake more professional roles from pharmacy premises.

Digital systems need to be safe, efficient and fit for purpose to support clinical decision-making. Better use of digital technology, such as remote and asynchronous consultations, can be used to provide patients more choice and access to pharmacists where they are unable to travel to the pharmacy.

Digital developments should also be maximised, so pharmacists can engage virtually with local multidisciplinary team meetings and multi-professional patient consultations without leaving the pharmacy premises.

Advances in technology will mean robotics and artificial intelligence will improve clinical decision-making; opportunities for near-patient pharmacogenomic testing and treatment monitoring will widen.

We do not support the use of digital technology to allow remote supervision of a community pharmacy.

Principle 7

A shared understanding and interpretation of supervision legislation is needed. This should be supported by clear, up-to-date professional guidance while maintaining a focus on patient safety and wellbeing.

It's important that NHS bodies, the General Pharmaceutical Council and pharmacy contractors apply supervision legislation in a consistent manner to ensure equity of access to pharmacy services for patients.

Consistency in the interpretation of supervision legislation across all pharmacies would also enable pharmacists and pharmacy teams to work in the same way to provide truly person-centred holistic care, offering a full range of services in all locations. Pharmacists acting in good faith, putting their patients' needs first, should feel supported to do so without being hindered by legislation.

Change required

NHS bodies, the General Pharmaceutical Council and pharmacy contractors must agree a consistent interpretation of supervision legislation.

 Pharmacists and pharmacy teams must be educated on what supervision legislation means to ensure they can apply it in a way which allows them to provide a person-centred service enabled by quality systems, processes, and risk assessments.

RPS will provide updated professional guidance, toolkits and supporting documents, supported by the GPhC, on how to interpret the guidance in practice to assist pharmacy teams.

Principle 8

Any changes to legislation should lead to improved patient care, not lead to an increase in risk to patient safety, and any changes in workload must be considered.

The priority must remain to provide the most effective and safe care for patients. This means any changes to legislation should not result in an increased patient safety risk or a reduction in accessibility to a pharmacist when a patient needs it.

With ever-increasing clinical commitments in community pharmacy, employers must establish suitable working conditions and provide the right environment for pharmacists to be able to focus on their clinical roles and the right skill mix to allow pharmacy teams to manage the technical workload.

RPS believes pharmacists should embrace new ways of working to shape what pharmacy will look like in future: the opportunities within the existing supervision legislation should be used to their full potential, alongside the changes described above, to achieve this and ensure pharmacists and pharmacy teams maintain and deliver high standards of clinical and medicines governance.