A new strategy for managing concerns about pharmacy professionals

What you need to know about the General Pharmaceutical Council’s (GPhC) new strategy for managing concerns about pharmacy professionals.

The GPhC said it wants “to move away from a process which can be adversarial and slow” .

Instead, it wants to “take quick action to protect patients when that is needed, while at the same time promoting and encouraging a learning culture that allows pharmacy professionals to deal with any concerns and go back to practising in appropriate circumstances.”

So what does the strategy say about how the GPHC will achieve this?

GPhC will use its full range of regulatory tools to prevent, anticipate and resolve concerns

“We realise that there will be situations when the only outcome can be restrictions on a pharmacy professional’s practice or their removal from practice.”

• the most serious concerns, and those that are disputed, reach a hearing.
• GPhC will aim for early solutions and remediation (giving the professional the chance to put things right) recognising that most pharmacy professionals who have difficulties in their practice are willing and able to improve and put the problem right. The focus on remediation will also apply to local investigations and employers.
• more enquiries in the early stages of its process after receiving a concern.
• an additional check at this early stage that will focus on whether the pharmacy professional subject of a complaint has themselves raised a concern with their employer.

 Flexible range of outcomes

 The GPhC said it will:

• depending on the circumstances of the concern, ask the professional to complete a learning and review statement. This will be specifically related to the nature of the concern, if there are health and performance issues, and will promote reflection and learning.
• raise awareness about voluntary agreements. We use these to support professionals to voluntarily deal with issues so they can remain in practice while making sure that any potential risk doesn’t develop into a future patient-safety issue. We will introduce an information pack for professionals who have health issues that don’t pose a risk to patient safety.
• produce guidance on when we will consider using voluntary removal from the This will allow professionals who want to, to be removed in appropriate cases.

A person-centred approach that is fair, inclusive and free from discrimination and bias

“Taking a person-centred approach will help us recognise that everyone is an individual with different needs. It means we will be able to better understand the concern about the pharmacy professional. And it will help us understand the impact of our approach on the people directly affected: patients, their families and carers, as well as the wider public and pharmacy professionals.”

The GPhC said it will:

• achieve by publishing in a Being person-centred in fitness to practise document that shows how these promises will be built into a number of areas including: communications, giving reasons for decisions, and supporting vulnerable people.
• introduce an assessment of needs that will record the needs of any person involved in the concern or whether the professional has a mental health issue or specific communication needs.
• produce guidance for professionals on the importance of being represented.
• provide better information on the type of concerns we deal with and how we deal with them.
• also improve the section of our website that people use to submit concerns, including the online facility for submitting concerns.

Promoting professional values and behaviours that encourage openness, learning and improvement in pharmacy

“If professionals conceal, or don’t report, incidents this can affect patient safety. It also does not promote a professional culture of openness, learning and improvement.”

The GPhC said it will:

• develop a ‘knowledge hub’ to share insights and learning from a number of aspects of fitness to practise
• publish anonymised cases where we haven’t taken any regulatory action
• include people who have been involved in a concern in helping us to improve including asking them for their feedback.

include anonymised feedback and feedback gathered by third parties we commission, at various points and from various participants, including witnesses.

Taking account of context and working with others to address problems

“We need to look beyond the individual and see the wider context when we assess concerns. Regulatory action against an individual professional may not be enough, or even needed, to make sure that a wider problem and a future public-protection issue has been dealt with. The root cause of an incident may be a wider system failing rather than an individual professional’s behaviour.”

The GPhC said it will:

• will consider the wider context within which the professional is working and decide on the most appropriate way of managing the concern.
• use all available sources of information when assessing the risk to patient and public safety. This includes making sure that public protection risks are managed effectively by the right people, including our team of inspectors.
• share information we gather about the wider context with employers to support our work in developing a culture of openness, learning and improvement.
• adopt, as part of our initial enquiries, a requirement for us to share information that is relevant to another regulator or investigatory body.
• improve its understanding of why it gets a disproportionately high number of concerns about BAME professionals, and the context in which these are made.
• collect more data about the sources of concerns, including the profile of those that raise concerns, the role and setting of the professionals in question and the nature of these concerns, to help us take the appropriate action to deal with any bias that we discover.