A productive meeting of the PSI Council took place in its headquarters on 25 April, where the next step in the expansion of pharmacists’ roles was discussed and the most appropriate mechanism for the delineation of pharmacies to allow pharmacist breaks was debated.
Opening the meeting, Registrar Joanne Kissane offered some highlights from the Registrar’s report. The first of these concerned an update on the work of the Expert Taskforce to support the expansion of the role of pharmacists in Ireland. The Registrar emphasised that the work of the Taskforce had been moving on “exponentially”; this pace was naturally having a significant impact on the PSI’s workload. Work on phase one is ongoing and pharmacists will have the power to extend prescriptions from September 2024, and the PSI is working to support pharmacists as this move begins. Phase two, which will empower pharmacists to prescribe within their scope of practice, is now underway. Although the Taskforce is due to present its recommendations concerning this next phase of work to the Health Minister by the end of June, Ms Kissane noted that the pace at which they are working may mean it is earlier than that. She also cited the Minister’s strong support for the expanded role of pharmacists, citing his announcement on 16 April that the Government had approved a proposal to amend the Health Bill, which would lay the groundwork for pharmacist prescribing and make provision in primary legislation for the further expansion of pharmacists’ roles.
“The die has been cast,” said Ms Kissane: “An amendment at this stage is highly unusual . . . and indicates broad Government approval and support for the expanded role of pharmacists. It is now possible that this piece of legislation could be completed by the end of summer term of the Dáil or very early into the autumn schedule.” She added that many of the recommendations of the Taskforce will inform the legislative amendments: “There is a lot of work to be done by a multitude of stakeholders in order to deliver on this ambitious programme.”
Ms Kissane also explained that existing Guidelines on the Counselling and Medicines Therapy Review in the Supply of Prescribed Medicinal Products from a Retail Pharmacy Business have been reviewed and updated to reflect the legislative change that enables pharmacists to extend prescriptions and they have been approved by the Regulatory and Professional Policy (RPP) Committee. The draft updated guidelines to support medicines therapy review, counselling and prescription extension will now go out to public consultation before an updated draft pending approval by the RPP, and then go forward for Council’s consideration at the June meeting; “We will seek the input of all registrants, to see if they find them appropriate to support them on the delivery of the extending prescriptions.” Ms Kissane also clarified that the updated draft guideline provides a principle-based framework.
The PSI issued its second workforce survey in November 2023, and Ms Kissane presented some highlights from the draft report, which was produced with support from Grant Thornton. While the response rate of 12 per cent was down from last year, there were 925 complete responses, including students. 73 per cent of the participants practice in community pharmacy, 14 per cent in hospital and 14 per cent in other settings. Key themes emerging from the survey were that pharmacists feel valued by the public but not the wider health system, although Ms Kissane noted that the survey had been issued prior to the announcement regarding the first recommendation of the Taskforce. There is a strong appetite for expanded roles within the health system, albeit pharmacists say they have less time for expanded roles. A decrease in numbers seeking to leave the profession was welcomed but leadership is an ongoing concern, and there is a limited preference for governance roles within pharmacy. This is at least partly due to the concern that they can never leave the pharmacy. Those in governance do not need to be present at the pharmacy at all times once an appropriate risk management system is in place in addition to robust procedures, protocols and adequate training, and a registered pharmacist is present.
The Registrar noted the risk associated with these types of surveys, however, and said its limitations and biases are noted in the report. Nonetheless, she said the PSI remains cognisant of the stress pharmacists are operating under, but she said the first survey in 2024 should “hopefully” show more positive trends.
A request for approval from Council of the Workforce Survey Analysis report 2023 was then sought by Mr O’Donnell, who said he “considers it to be a good report and worthy of Council’s approval”. This was subsequently granted.
Pharmacist Council Member Sean Reilly was positive about the findings of the survey and the ongoing work of the Taskforce: “A lot of things are changing and changing for the good . . . we are looking at issues that are affecting the profession that might have been sidelined before.” He did express concern about the operationalisation of the TCQR saying it seems to have, “hit a bit of a roadblock” and the findings of the workforce survey regarding workplace stress underline the importance of this: “We do depend on incoming pharmacists . . . what are the next steps and do they have the level of urgency that is required?”
Ms Kissane explained that in context of overall number of registrants, this year’s numbers align closely with last year, and in terms of registrants coming into Ireland, “if we continue on same trajectory, we will do very well this year — the numbers of pharmacists coming in under the TCQR this year is higher than this time last year.” While there are challenges around its operationalisation, this was the focus of major discussion at the most recent RPP Committee meeting, and the committee will be coming to Council in June with recommendations around operationalisation and a concrete proposal for Council approval.
A brief update was then given on the 2024 Service Plan by the Registrar, who noted that of 12 strategic projects, nine are trending green and three tracking amber as of the day of the meeting. In terms of the amber projects, which include the PSI’s new website and the CPD model for pharmaceutical assistants, none of these projects are at risk of not being delivered by the end of the year, “there is just a more protracted timeline”.
Mr Reilly queried the number of pharmaceutical assistants currently registered, and it was confirmed to be 189, although it is not known how many are currently practising. Mr Reilly then noted the cost of developing a new CPD model for this decreasing cohort; Ms Kissane said the PSI is being “pragmatic” around the approach to this and using existing structures where possible, “but we have obligations under the Regulatory Professions act to develop a new CPD model for PAs.”
Pharmacist Council Member Emily Kelly sought an update on the exploratory work on fitness to practise, and asked how likely it is that Council is to see something soon given the current workload. Ms Kissane admitted it was “unlikely”, and as it stands the PSI will be very challenged to deliver the service plan, but remained very focused on bringing this as part of the next corporate strategy: “The workload is immense at the moment and we are very enthusiastic about it . . . we are not going to miss this opportunity but we are also being realistic about what we can deliver.”
Work has already begun on the PSI’s 2025-2028 corporate strategy and President Katherine Morrow offered an update on its development, noting that a draft will hopefully be shared with Council at the June meeting.
Caroline Murphy, the PSI’s Legal Affairs and Fitness to Practise Manager, then sought approval for an amendment to the Council’s publications and disclosure policy, noting that while it is the policy of the Council to publicly post the outcomes of Fitness to Practice hearings, including details of sanctions and in some cases the names of the pharmacists in question, on the PSI website, a request had been made that those related to deceased members should be removed, given that it no longer serves the public interest if the pharmacist has passed away.
The PSI has considered that there is “nothing to be gained by maintaining notice on website of every pharmacist who has been the subject of a Fitness to Practice hearing”, she said, and noting that the power to publish is delegated to the Council, she was asking them to consider delegating to the Registrar the function to remove a notice, “subject to the proviso that if the Registrar has any doubt they could bring to the Council to decide.” The Registrar would retain a certain element of discretion when exercising their judgement, she added. The new approach and wording have been validated by external solicitors.
Council Member Paula Barry Walsh pointed out that while removing the name of the deceased person may make sense, other information in relation to the hearings is useful in terms of learnings — she asked how much nuance there would be, and if it would just be a case of redacting the name and leaving the transcript online. Ms Kissane confirmed that if Council wishes those learnings to remain online, that could be facilitated, and it would be considered on a case-by-case basis.
Council Member Richard Hammond said he overall supports this proposal but agrees that it would benefit from the addition of a “parenthesis” that would clarify those editing powers of the Registrar: “Once the pharmacist is deceased, it is no longer a public interest issue but it does remain a professional standards issue,” he said, adding that it is important that the Registrar could retain the discretion to maintain the information online, albeit in an anonymised format. Sean Reilly pointed out that in the UK, the coroner is required to report the death of a pharmacist and he queried if it is the same situation in Ireland; “It might be something to look at . . . it’s important to ensure that registers are accurate.”
The report from the RPP Committee was delivered by Chair Rory O’Donnell, who sought Council’s approval for a delineated model for retail pharmacy businesses and proposed amendments to the Regulation of Retail Pharmacy Businesses regulations. This topic sparked significant discussion among Council members, with pharmacist Council members expressing concerns about the prescriptive nature of the model, including the provision that shuttered areas must be locked while the pharmacist is away. There were also queries regarding the proposed maximum two hours allowed for breaks.
Mr O’Donnell clarified that this model had been developed to allow for a pharmacy to remain open to allow a pharmacist and other professional staff to take lunch breaks, during which non-medicines would still be for sale. He said they envisioned a maximum of two hours for these breaks, that could be consecutive or non-consecutive.
Ms Barry Walsh noted that it would be a “big change” for the public, as they would now be effectively denied their medication while the pharmacist is away. Mr Reilly highlighted his concern that while this was being introduced in a bid to prevent pharmacist burnout, he felt it wasn’t explicit enough in terms of advertising that it was being done for this purpose; “This is a proposal in the round to deal with it and it says nothing about those breaks . . . in tandem with this, it should say pharmacists are contracted employees and have to adhere to the working time directive.” He added that he was “more than a little concerned” about the practicalities of delineating each pharmacy, given they vary so much in their individual layout: “Shutters are expensive and a lot of sites would find it difficult to install them,” he pointed out, adding that across Europe this model is effected with the use of blinds and these work very well — “Very prescriptive hardware changes will make a good idea and a good piece of work undoable.”
Ms Kelly expressed her opinion that the proposal, “seems like a convoluted way of solving the lunch break issue” and said it is “at odds with the workforce survey where pharmacists see themselves as healthcare professionals and not retail employees”. She also suggested there are more progressive technologies that could be employed “rather than old-fashioned fixed answers like shutters”. Mr O’Donnell agreed the RPP did not consider any other solutions and could potentially consider alternatives. “It seems like a lot of work, and we already have a lot of work,” said Ms Kelly.
John Bryan, Head of Community Pharmacy Assurance with the PSI, said they are bound by legislation with respect to this issue, but he stressed it is “just one element of trying to provide breaks for pharmacists — there are other pieces to it”. This was echoed by Ms Kissane, who said it is a solution to one of the problems pharmacists have identified, that of being unable to take breaks, and will help in making pharmacy an attractive career.
“It is a significant patient safety issue when pharmacists are working 12-hour days and can’t take a lunch break at a normal time,” she said. Ms Kissane also refuted suggestions that the model was overly prescriptive, noting that it had simply specified lockable shutters, it hadn’t suggested a particular size, or stipulated that they must come down from the ceiling; “We are just proposing that it is not accessible and how that is provided for will have to be suitably robust so that there is no breach.” She also expressed her belief that this model was emphasising that a pharmacy is a healthcare environment and not simply a retail one.
Mr Reilly said he is “one hundred per cent behind it”, apart from the idea that the shutters must be locked — screen blinds would suffice in his opinion and there is CCTV in all pharmacies. Mr Hammond gave his opinion that CCTV is not sufficient, as “we want to prevent those difficulties happening in the first place and we can’t go down that route in case of glitches in the system”.
Mr O’Donnell reiterated that this is not the only solution, and while it is “not perfect”, it might go some way to address the issue in question; “It is just one piece of the puzzle of a very, very, long jigsaw.” Mr Bryan also reiterated that this model was designed to comply with the law, “which is very specific”, hence the lockable aspect of the shutters being stipulated.
Ms Kissane said the development of the delineated model had been a priority for her since becoming Registrar, given that 53 per cent of workforce survey respondents indicated they never or rarely get a protected lunch break: “We spent a lot of time seeking to implement a very workable solution . . . while also adhering to the regulations in the Pharmacy Act and ensure patient safety and public protection remains at the forefront of what we are trying to do.”
Regarding the drafted amendments to the Regulation of the Retail Pharmacy Businesses Regulations (S.I. 488of 2008), Council member Peter Dennehy also stated he was not a fan of the prescriptive nature of the regulations and disliked the use of words such as “shall”; he said the guidance should be provided, but in a more general way, “then we have the best opportunity to make it workable . . . pharmacists are not a homogenous group”.
The President asked if they are minded to ask the RPP to revisit this given the feedback from the Council meeting but Ms Kissane said they had spent significant periods of time engaging with Senior Counsel on this, with “many meetings and many drafts and iterations . . .The PSI as an organisation is happy with what is currently proposed.”
A vote was eventually taken on who was in favour of approving the proposals, with eight members in favour and six against — those against mostly consisted of the pharmacist members of Council.
Mr O’Donnell also sought approval from Council for an implementation proposal for a CPD model for pharmacists, following the completion of the review in 2023. It was outlined the various recommendations of the proposal and how the PSI will implement these proposals, for example:
Approval was granted, although Ms Kelly advised that she wasn’t sure that the recommendations of the review as adopted “had allowed sufficiently for the advancement of pharmacy practice”.
Approval was also sought from Council regarding a proposal paper on the Systems for Quality Assurance of the CPD training programmes, and activities for Pharmacies. This topic raised discussion regarding the standards programmes should meet. Approval was granted.
Danielle Barron
Highlighted Articles
