As part of her report to the PSI Council, Registrar Joanne Kissane outlined a forthcoming busy period for the Regulator as it begins preparing for the next phases in the expanded scope of pharmacists, following the August publication of the final report from the Expert Taskforce: “There is quite a bit of activity and quite a number of asks for PSI to deliver over the coming months,” she told Council members.
The Registrar noted a letter had been received from the Minister for Health outlining a number of requests of the PSI in relation to the publication of the Final Report by the taskforce and the associated actions that will be required. A specific request related to a policy decision that pharmacists should be enabled to prescribe to continue a prescription for contraception already initiated by another provider and training supports for this specific action are being considered in tandem with the development of the Common Conditions service, Ms Kissane explained. As well as preparing for the regulation and governance of the expanded scope of practice, the PSI has initiated research into potential approaches for training programmes for the eight common conditions named in the report; Ms Kissane confirmed that further detail on the scope of the enabling legislation is required before progressing with any the development of any training programmes.
Ms Kissane also highlighted the progress of the Business Transformation Programme (BTP) and the launch of the new PSI website in July, emphasising that the objective of that programme is to ensure that the PSI becomes a digital first regulator and holds a customer-focused view of its pharmacists and pharmacies. Noting that she is cognisant of the major investment made by the PSI in this particular programme, Ms Kissane alluded to earlier difficulties with the BTP saying that in her experience “digital projects don’t always go to time”. Happily, however, phase two was delivered on time and within budget in August 2024 and the new website has already elicited significant positive feedback. One of the major benefits of the new mobile responsive and user-friendly website is the breadth of data that is now readily available on registrants and pharmacies, and Ms Kissane said PSI will present this data periodically to Council. For example, the data currently shows that there are 7,576 pharmacists registered with PSI, a number that is growing, and 189 pharmaceutical assistants, a number that continues to decline. This real time information will be of immense value, she said.
Council member and pharmacist Sean Reilly expressed his praise for the various elements of the update, noting that “everything is going in the right direction”. In relation to the work of the Implementation Body and Taskforce, he said his understanding was that the PSI has “an aspiration for an omnibus Pharmacy Act” and he asked for an update on this. Ms Kissane agreed that this is still the overall ambition, and work on complete reform of the Pharmacy Act as it stands began in 2022. Since then, the Council has been continually engaging with the Department of Health: “We met earlier this year, highlighting to them the various aspects of the Act they need to have reformed in order to deliver on strategic objectives,” she explains. Now, in the context of pharmacists prescribing, they will need “additional functionality” given to the PSI to support them in monitoring pharmacist prescribing; “We hope to get the Pharmacy Act opened again to us this quarter and make the amendments we are looking for — not everything but a number of pieces,” Ms Kissane said. Mr Reilly said, given the sheer number of amendments, the legislation is “a bit of a mess at this stage”.
Dr Laura Sahm, Vice-Dean of the School of Pharmacy at UCC and new Council member, reiterated the high level of activity required in relation to the expanded scope of pharmacists and asked if additional resources had been allocated to the PSI in that regard. Ms Kissane explained that the regulator had sought sanction for two additional roles and received sanction for both — they will be commencing recruitment soon: “The Department is cognisant that there is increased activity,” she said.
Pharmacist Council member Emily Kelly sought an update on the delineation model for retail pharmacy businesses. Ms Kissane noted that public consultation showed that support for the delineation model was “very positive”, however the consensus at the last Council meeting was that the principles-based guidance suggested was “far too prescriptive” and this is being reconsidered as a result.
PSI President Katherine Morrow then furnished Council with an update on the development of the PSI’s next corporate strategy covering the period 2025-2028. While the response rate to public consultation was low, the feedback was broad based and welcome, and the PSI has also had substantial stakeholder engagement as it developed the strategy. They will now go to the Minister with the proposed strategy following Council approval at the meeting. Emily Walsh praised the new strategy but asked if the PSI’s aspiration to show value for money should be somehow incorporated into the document. In response, Ms Kissane said the PSI’s expenditure is very transparent and the budget is freely available. The document was also welcomed by Paula Barry Walsh.
A brief report to Council from the BTP Programme Board was given by Ms Grainne Power and the functionality of the new PSI website was praised by Council members. Following this, Ms Ann McGarry presented the report of the Performance and Resources Committee and she highlighted the revised treasury and investment management policy in light of Council concerns regarding the return on the PSI’s monetary assets. While no final decision has been made, she said they had received some good financial advice and are “heading in the direction of proposing to Council at next meeting that we appoint an investment manager”. They will also be looking at the PSI HQ on Fenian Street and the future costs associated with that building as part of a strategic financing review. Having proposed signing off on the PSI management accounts to the end of June, this was approved by Council. Rory O’Donnell congratulated Ms McGarry on the already significant progress made in relation to the investment issue, noting that this has been discussed for many years.
Mr O’Donnell then delivered the report from the Regulatory and Professional Policy Committee, noting they had met in September to finalise the themes underpinning a model of CPD for pharmaceutical assistants. The consultation was very positive, he noted — “everyone is very happy with it” — and the approval was subsequently granted by Council. A request for approval from Council of the accreditation panel for MPharm visits to the National University of Ireland, Galway, was also granted. Offering his quarterly update on the operation of the IIOP, Mr O’Donnell asked if these could be biannual or annual, given the limited information. Damhnait Gaughan agreed that this could be reassessed as part of the contractual arrangement, which is currently under review.
“As well as preparing for the regulation and governance of the expanded scope of practice, the PSI has initiated research into potential approaches for training programmes for the eight common conditions named in the report.”
The results of the Codeine Specialist Surveyor Report were also outlined by Mr ODonnell, who explained that 250 pharmacies were visited by mystery shoppers in May 2024; “The expectation was that nobody would be supplied based on the scenario presented by the mystery shoppers”, he said. However, 150 pharmacies did supply the “customers” with the codeine products requested. Ms Gaughan noted that there will be various levels of regulatory action taken depending on the pharmacy’s actions in each instance. Mr Sean Reilly conveyed his disapproval with this approach, expressing his belief that the codeine legislation and guidelines “are not fit for purpose”. The HPRA could solve this by either reducing pack sizes, banning it, or putting it on prescription, he said. Mr Reilly also pointed out that by “value and volume”, codeine is the highest seller in any single pharmacy in the country, showing public demand: “There are instances with abuse potential and a lot of it, but this isn’t solving that problem,” he asserted. Mr Reilly said the guidance clearly cannot be followed in the way that the PSI wants it to be followed, and pharmacists found themselves in a “Catch-22” situation, where there are complaints but the PPC “overwhelmingly decides it does not warrant action”. Emily Kelly suggested a video approach, clearly showing pharmacists the various scenarios in which they should and shouldn’t prescribe codeine. President Katherine Morrow said each pharmacist appreciates that it is a difficult situation and suggested that this issue should be given some space on the Council agenda going forward, looking at the implications of the codeine guidance and if they “could do things a better way”.
President Morrow then delivered the report of the Special Purposes Committee, and Council approved several appointments to the PSI’s Disciplinary Committee Panel, as well as the chair of the Preliminary Proceedings Committee (PPC). It was agreed that these appointments should be for a term of three years, as opposed to two.
The next PSI Council meeting will take place on 12 December 2024.
Danielle Barron
PSI
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