The PSI Registrar Joanne Kissane opened the PSI Council meeting on 6 March with some highlights from her report. A further update on the phase two recommendations of the Expert Taskforce was offered, with Ms Kissane noting that “this will remain an important topic of discussion for the remainder of the year”. The PSI is the lead for the second workstream of the Community Pharmacy Expansion Implementation Oversight Group (IOG), ‘Education and training for pharmacists and regulatory matters’, which includes oversight of the delivery of training for the Common Conditions Service and continuation of prescriptions for contraception.
The Registrar noted that rollout of this next phase is intended to happen in the winter of 2025, “so we will need to be ready before autumn so that pharmacists can carry out their training”. The PSI will continue to communicate to the profession “extensively” as the Common Conditions Service is rolled out.
Ms Kissane also outlined the public consultation report and proposed amendments to PSI (CPD) and PSI (Registration) Rules. The draft rules included the flexibility to continue to operate the CPD system via the outsourced mechanism or otherwise, which pharmacist Council members were happy with. The Registrar noted “positive strong support” for removal of practice reviews, but there were mixed views on the move to a policy-based approach to the quality assurance of CPD activities delivered through the IIOP.
Later in the meeting Council was asked to approve the necessary amendments before they are submitted to the new Minister for Health Jennifer Carroll MacNeill for her consideration and consent. The Regulatory and Professional Policy Committee would then present the approved rules to Council in quarter four 2025 with a view to implementing these amendments over the following months, Ms Kissane said.
The PSI has also gone out to tender to seek assistance in carrying out its core funding review, which will include a review for cost effectiveness and value for money as part of the process. This will support Council with evidence-based decision making on resourcing requirements, Ms Kissane said. The hope is to have a provider appointed by April and complete the report by the end the July, a timeline the Registrar agreed was “ambitious”.
Council member Laura Sahm queried whether the PSI would receive additional funding to aid it in carrying out its tasks as per its membership of the Community Pharmacy Expansion Implementation Oversight Group (IOG). There has been significant engagement with the Department of Health on this, noted Ms Kissane, and PSI recently received confirmation that it will receive additional funding this year in light of expansion and the ongoing work to develop training for the Common Conditions Service. The PSI has also received confirmation that additional funding for IIOP would be forthcoming as that fee has remained static since it was established, she added.
Pharmacist Council member Sean Reilly queried whether the PSI needed another assessor to assist with the core funding review, noting the probable high cost involved. Ms Kissane said PSI did not have the “bandwidth to carry out a project of that magnitude” and would be working closely with the provider, who would be providing a skillset PSI did not have. The requirements are an assessment of where value for money can be sought, she said; “where we may need to look at a fee increase, we need to ensure that that fee increase is independently assessed, there needs to be a strong evidence base there.”
It was noted that given the changing CPD rules and the need to ensure the continuity, trust and stability of the IIOP, the PSI is engaging with them to put measures in place to ensure that consistency. It was also confirmed that an eLearning course on open disclosure will be available in the next few months from the IIOP, and other workshops and webinars will be held to augment this training.
Council members also engaged in discussion around the ongoing failure of the Preliminary Proceedings Committee (PPC) to meet its KPI, with zero per cent of cases being dealt with within six months. While additional meetings of the PPC are on the agenda for this year, a full review of the Committee will take place later this year. The PPC continues to work through a number of legacy cases but there have been instances where it has paused hearing cases for a period of time or cases subject to criminal charges. The intention is that all legacy cases will be heard and completed in full this year, but the Council heard of a need for a “realistic KPI” for the Committee. Ms Kissane noted the PSI had gotten recent advice around dealing with cases subject to criminal charges — this may mean PSI “takes a different approach and progresses them a lot faster”.
Richard Hammond said he did not believe the PPC was ever consulted about how reasonable or realistic its KPI is; “While six months is achieved in a significant number of matters, there are always matters where complexities arise and more information required and that simply takes time. The setting of the KPI cannot be arbitrary.” A query on why cases apparently never go to mediation was answered by Richard Hammond, who said that the cases that are deemed worthy of further investigation are naturally at the more serious end of the scale and do not lend themselves to mediation. Mediation is also regularly suggested by the Committee but declined by the complainant, who may view it as a time consuming or expensive process.
“The reason for pausing [BTP] is to make sure we have the budget for the solutions to the problems we set for the developers. If it means a delay of three or six months, then it is prudent.”
A 2025 service plan update, also delivered by the Registrar, noted that at this stage of the year, 13 projects are green and one is red, namely the BTP phase 2. A report was then delivered to Council from the Business Transformation Project Programme Board by Grainne Power. She noted that while the PSI had its “own vision” for the next phase of the project, the cost of requirements for the project far exceeds the budget that is remaining. The Board will now need to review the estimate from the third-party provider, to see if it is reasonable. She confirmed that at the next BTP Board meeting in April she will have a number of critical pieces of information regarding the next steps. Sean Reilly queried why the consultants who had overseen the project were not retained and it was confirmed that they are brought in for a set number of days but are available to PSI if they needed them for any future work. In reply to Mr Reilly’s assertion that the project is “way over budget”, Ms Power noted that no money had been committed to the next phase of the project at this time; “The reason for pausing is to make sure we have the budget for the solutions to the problems we set for the developers. If it means a delay of three or six months, then it is prudent.” Ms Kissane added that the agreement was that consultants would be in place to carry out a quality assurance approach; “The process that was previously agreed was the process that has been followed.” Ms Power also stated that there is technical background that validates the estimate in terms of other organisations’ experiences with similar transformations; “It may be that we have to live with something else that is more in line with our budget.” The current budget is approximately €250,000 and the current estimate is “significantly north of that”.
The report to Council from the Performance and Resources Committee was delivered by Ann McGarry, who also detailed the need for external expertise as the PSI carries out its core funding review — “The timescale is ambitious but it is important to press forward.” The PSI was tasked with implementing NIS2 in pharmacies as per the request of the National Cyber Security Centre (NCSC). The Registrar has engaged extensively with the Department of Health to determine what might be involved in this, and Ms Kissane noted that many other regulatory bodies have been put in the same position, such as the HPRA and the Mental Health Commission, and they have also made representations to the Department of Health. The concern is that this will be a “complex and costly” process, and the Registrar noted that it would need to come “fully funded, but even then, we would not be in a position to take this on”. The implications, it was agreed, are “enormous” for the PSI in terms of resources, costs and deadlines, but while it was hoped the engagement might lead to influence, this seemed unlikely. Ms McGarry said she appreciated “it is uncomfortable for Council to know something is coming but have no understanding of the scale of it”. Following this discussion, a request for approval of the Performance and Resources Committee 2025 Work Plan was granted, as was the request for approval of the updated PSI procurement policy.
The report to Council from the Regulatory and Professional Policy Committee (RPPC) was given by Rory O’Donnell. A request for approval of the RPPC work plan for 2025, which contains the core regulatory functions of the Committee and maps out what is envisioned for the year was granted. This was followed by a request for approval from Council of the public consultation report and proposed amendments to PSI (CPD) and PSI (Registration) Rules, as previously discussed. Mr O’Donnell noted that the public feedback had been “slightly contentious” around the issue of annual submissions and the RPPC had considered this against the backdrop of the policy that has already been adopted by Council. They felt there is a need for annual submissions that relate to registration, instead of having to go through complex processes to determine someone is not fulfilling their CPD. As it will be the end of 2025 before everything is embedded and operational, there will be ample time for extensive communication with the profession in the meantime to try and avoid any confusion. Emily Kelly welcomed this, saying the PSI cannot underestimate the level of work that goes into communication around this to avoid confusion as the rules change.
Geraldine Campbell expressed her belief that this communication will be centred on the shift to a focus on the outcome of the learning rather than inputs or outputs; “it’s about bringing people on that journey to understand that.” It was confirmed that it will be the second year of implementation before sufficient communication has been done and the move to annual submissions can begin. The proposed amendments were then approved by Council.
An update for Council on the 2024 Survey of the Register Report received very good feedback. “As a lay member it is a very interesting report and gives a lot of colour to the profession,” said Council member Martin Higgins.
The Special Purpose Committee president Katherine Morrow then oversaw the approval of a number of appointments to the roles of Chair and Acting Chairs on the PSI Disciplinary Committees, appointments to the Health Committee and a number of re-appointments to the PSI Advisory Committee.
Danielle Barron
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