The PSI Council meeting of 26 June opened with congratulations to Denis O’Driscoll upon his election as President, alongside the incoming Vice-President, Laura Sahm. In his first address as President, Mr O’Driscoll welcomed the new pharmacist members of the Council.
An update on PSI activities was given by way of the Registrar’s report, which was noted as being longer than usual, given a number of coinciding requests and reports. Key points which were considered are set out below.
Regarding the updates to Vaccination and Emergency Medicine Training Requirements for Pharmacists, PSI Registrar Joanne Kissane noted that the training requirements were last reviewed in 2019.
The PSI has sought patient and public perspectives on this, via the Health Products Regulatory Authority (HPRA) patient forum in March. The perspectives of community pharmacists were sought from the IPU and also via survey, with over 200 responses received. Collating this information has led to the furnishing of eight recommendations, which Ms Kissane outlined. Notably, pharmacists will annually self-assess if they have the necessary skills and competencies to safely administer vaccines and/or emergency medicines. Ms Kissane noted there was “strong support” for self-assessment of pharmacists, that was evident throughout the stakeholder engagement.
A further recommendation is that pharmacists will be required to repeat Medicines Administration (Parenteral) (PAMT) training when they have had a two-year break or longer; “This change is intended to provide more flexibility for those returning to vaccination after a 12-month break,” Ms Kissane explained. Support resources and tools will be updated, and peer review will be more widely used to assist pharmacists.
The Registrar reiterated that their engagement found that most did not agree with the need to repeat vaccination training on a frequent basis and the requirement to do so will no longer be mandatory. If the eight recommendations are approved, the PSI would communicate these changes in advance of this coming autumn/winter vaccination season, she added.
The report regarding updates to Vaccination and Emergency Medicine Training Requirements for Pharmacists was approved by the Council.
Draft guidance for the Common Conditions and the Continuation of Contraception Services was brought before Council, in addition to the draft proposal outlining the Education and Training required to prescribe medicinal products in accordance with the services. In terms of the education and training, this will include a mandatory core regulatory module, as well as a mandatory common conditions specific module for each condition, all being prepared in association with IIOP.
Emily Kelly queried the length of the modules and how much of a time burden it would mean for busy pharmacists. It was clarified that each module would be up, to but no more than, an hour in length.
In relation to the draft guidance for public consultation Joan Peppard highlighted her concerns about the use of the phrase “explicit consent” in the context of service provision/record keeping/data sharing saying the language used is “very precise”. She said she is worried that it “goes too far” and could be potentially onerous. It was noted that it won’t be expected for pharmacists to share their consultation records with the patient’s own GP, but new pharmacist member Margaret Donnelly expressed her own concerns around this highlighting potential antimicrobial stewardship challenges.
Approval was granted by Council for bringing all draft documents forward to public consultation.
The request for approval from Council of the IIOP ePortfolio Review Policy was met with a positive response. Revised rules for annual CPD will come into effect in 2027.
A request for approval from Council of the continued recognition and approval of MPharm Degree Programmes (RCSI, TCD, UCC) was granted, and University of Galway accreditation was also approved.
Council was also set to discuss the draft Position Paper on Gaps in Hospital Pharmacy Regulation, and Ms Kissane noted that consecutive PSI corporate strategies have included commitments to clarify the role of the PSI in relation to hospital pharmacy regulation. The Society has had “significant engagement” with the hospital sector, as well as HIQA and the HPRA, and has also carried out a mapping of the PSI’s legislative framework. The Registrar admitted it has been “challenging” to determine whether activities carried out in hospitals constitute a retail pharmacy business or as part of the hospital activities per se.
The paper identifies two key issues, specifically the PSI’s limited regulatory remit in relation to hospital pharmacies registered as retail pharmacy businesses, and also a lack of a clear scheme of delineation of regulatory responsibilities across the relevant regulators in this sector.
Mr Peter Dennehy noted that he would have expected that the PSI regulates the environments pharmacists work in and the public take that for granted but it is wrong; while he supports the position paper, much more needs to be done on this. Approval was granted by Council.
Geraldine Campbell highlighted the protracted Fitness to Practice (FTP) timelines and asked if there was an update on how this was being addressed. Ms Kissane said they must acknowledge that, “they aren’t where we want them to be”, but said the Preliminary Proceedings Committee had not only increased the number of complaints heard at each meeting but had also increased the overall number of meetings. A number of longer legacy cases were also almost ready to be concluded; “We are starting to see progress made and by the October Council meeting that KPI will look quite different.”
Gráinne Power delivered a report from the Audit and Risk Committee, noting they had approved the internal audit on disaster recovery and business continuity. The Committee is also working on the internal audit recommendations; Ms Power assured Council they are “making good progress and narrowing these down”.
Geraldine Campbell offered a report to Council from the Business Transformation Project Programme Board. While phase one and two of the project have been delivered and are now operating, a third party has been engaged to validate the “extensive user requirements” for phase three, the provision of which far exceeded the available budget. Revisiting the requirements has taken some time, she noted, “and we are still not at the point of issuing these final requirements to the service provider”.
An interim solution has been developed for internal case management using internal expertise, however, and it was suggested that this could perhaps form at least some of the basis for the phase three requirements. Paula Barry Walsh commended the work done by the executive on this matter and said there will naturally be trade-offs, “but even if there are trade-offs it can be built on at a future stage”.
Ann McGarry delivered her report to Council from the Performance and Resources Committee (PRC). Approval was granted by Council of the PSI’s Corporate Procurement Plan 2025-2028, as well as Q1 PSI Management Accounts to 31 March 2025. Ms McGarry also noted in relation to the core funding review, Mazars had delivered an initial presentation — the PRC is now looking forward to the next meeting and offering an update on the core funding review.
In relation to the request for approval from Council to issue draft PSI (Retail Pharmacy Businesses) (Registration) Rules 2025 for public consultation, there was robust discussion. Ann McGarry asked if it was worth including a definition of medicinal product in the rules — as a non-pharmacist she would expect to see this, but it wasn’t there.
New pharmacist member Áine McGrory expressed her belief that it was disproportionate to not allow the sale of GSL medicines when the pharmacy was operating the delineated model in the absence of the pharmacist given that such products can be supplied via non-pharmacy outlets. The PSI’s Shane McGlynn noted they got a lot of legal advice on this, and said a medicinal product is classified as such, whether it is prescription or over the counter, under the Pharmacy Act. In the context of community pharmacy all medicinal products must be supplied under the supervision of a registered pharmacist. As such, it is not possible, under the current legislative framework to allow GSLs in a pharmacy to be sold unless under the supervision. Concerns about how prescriptive the rules were, was raised. Ms Kissane said the intention is that this is “operational guidance” and will be operated by the individual pharmacist or pharmacy and their own governance structures.
Ms Donnelly asked if there would be adequate flexibility for pharmacists to adjust the hours of their delineated business and the PSI’s Damhnait Gaughan agreed that there would be: “This is supposed to be an empowering tool. It is principles-based and not supposed to be prescriptive advice.”
Another issue discussed was the move to public consultation for the draft Guidance on Pricing Transparency. Ms Kissane reminded Council that in April of this year, this move was requested by the Minister for Health, on the basis of ensuring that patients have a renewed understanding of pricing. It was highlighted that this is a health policy matter. While the PSI already has guidance on this issue, they have sought to “review and build on this as a foundation to deliver on this request from the Minister” and participated in a wide range of engagement activities, the Registrar explained.
Pharmacist Council member Mark Jordan queried whether the Competition and Consumer Protection Commission had had any input into the guidance on pricing transparency, noting that the potential exists for an unsustainable race to cheaper prices potentially leading to “the closure of pharmacies in economically disadvantaged areas, impacting both the profession and patients”: “I admire what you are trying to do but I don’t know if this is the way to go about it.” The Registrar responded by saying that once the model is in operation, any negative effects would become obvious and could then be addressed. She also reiterated that, “the patients and public are very much looking for this”.
Further discussion saw Emily Kelly express her belief that “price transparency already exists” and asked if the patient panel was being afforded the same weight as the pharmacist engagement. She feels that an itemised receipt would cause more confusion for the customer but welcomes other parts of the guidance.
Pharmacist member Nigel Moloney said he has received information from the Annual B&A Survey (not yet published) which showed the majority of people surveyed (74 per cent), said they were “satisfied or very satisfied” with pricing transparency and felt final price was the most important: “By offering price breakdowns, we may be creating a level of additional complexity that is possibly not needed and may also increase workload for pharmacists. To get a price check on something, you have to dispense it on the computer, so essentially you are doing it twice for no additional revenue.”
Mr Moloney added that when dispensing errors have been made, they most often occur when a pharmacist is busy and the pharmacy is understaffed; “Now we are increasing that busy-ness without any financial reward . . . Potentially sacrificing safety for financial transparency that isn’t requested or required by the public.”
Pharmacist Council member Áine MacGrory expressed her concern that patients may be confused as to whether this applies to solely private prescriptions and may feel it impacts their GMS prescriptions — this needs to be clarified in the public consultation, she said.
Joan Peppard said she was “unhappy with the continued use of the old-fashioned term of dispensing fee as it encompasses so much”, noting it was a significant missed opportunity to change the language around this; “It is a professional service — not just dispensing, it involves so much more . . . it’s just a convenient phrase that gives a misconception of the pharmacist’s role.” While Ms Gaughan said this is aligned with what the patient understands, Ms Peppard again reiterated that it is a missed opportunity to change this fundamental understanding — “It is too narrow a description.” Paula Barry Walsh echoed this, noting the “time, effort and education spent on giving this professional advice”.
Ms Kissane agreed they should be defining the role of the pharmacist in the context of the dispensing fee and professional services. An opening explanatory note of what is involved in dispensing would be of use, she said; “We can also make further amendments based on the public consultation and this feedback.”
Gráinne Power said that pharmacists need to have confidence in their role and standing as trusted healthcare professionals and most reasonable members of the public will appreciate that; “We cannot stop the tide at the threat of something.” Meanwhile, Richard Hammond agreed that professions can feel overburdened by regulation but this is clearly a priority of the Minister, so it is their job to implement it as sensitively as possible. Ms Kissane concluded this discussion by noting that the results of the public consultation may allow for more consultation with the Minister.
The newly elected President outlined the report to Council from the Special Purposes Committee and requests for approval for a number of appointments and re-appointments to the PSI’s Disciplinary Committees, Advisory Committees, and BTP Programme Board were made to Council and all were approved.
With this, the meeting concluded. The PSI Council will meet again on 2 October 2025.
Danielle Barron
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