The Pharmaceutical Society of Ireland (PSI) held a series of roadshows during the month of October. In this article, the IPU’s Head of Strategic Policy, Clare Fitzell, provides an overview of the events.
The PSI Roadshows covered three main topics: emerging risks to the future pharmacy workforce, guidance for those occupying governance roles in pharmacies and the fitness to practise (FTP) and complaints process. The IPU professional team attended these events, and below are the topline key takeaways that should provide information for those members who were unable to attend these events in person.
The last roadshow of the series took place in the Clayton Hotel, Leopardstown, on 24 October and the presenters at this event were Joanne Kissane (PSI Registrar and Chief Officer), Laura Irwin (Acting Community Pharmacy Quality and Safety Manager), and Caroline Murphy (FTP Legal Affairs Manager). The presentation was followed by a Q&A session in which John Bryan (Head of Community Pharmacy Assurance) joined his colleagues to address questions posed by attendees.
Ms Kissane opened the event giving an overview of what would be covered and then introduced her colleague Caroline Murphy, who gave a brief and concise overview of the FTP process. Ms Kissane openly shared her experience of the FTP process, having personally been subject to a complaint. She shared with the audience how the process was challenging and stressful but also, on reflection, formative. She outlined that legislation in place to ensure patient safety should be seen as enabling and empowering pharmacists to make independent, autonomous decisions and as such the legislation has a dual aim of supporting of the profession, whilst ensuring patient safety. It is clear from attending this event and from hearing Ms Kissane at the recent IPU conference, that she is keen to lead a change in approach to the management of FTP cases, and acknowledges that changes in the Pharmacy Act 2007 are required. In the interim period, the PSI are reviewing their internal processes with a view to identify changes that can be made. She went on to explain that she has a vision for the Regulator to become more compassionate, with a more human approach, and that she was cognisant of practitioner health, and her hopes that this will help change the perception of those considering a governance role. Ms Kissane ended the introduction session with a declaration of her commitment to being a transparent regulator.
Caroline Murphy (FTP Legal Affairs Manager) began her session by outlining that the FTP process was a legal process with a statutory basis from start to finish, and the PSI’s role was to adhere to the legislation as provided for in the 2007 Pharmacy Act. Ms Murphy gave some brief statistics, for example 0.2% of registrants have ever been subject to a PSI Inquiry, and in 2023 so far they have received 100 concerns (i.e. not a formal complaint but an unsolicited communication from a member of the public or another third party, which suggests that there may be cause to be concerned as to the safety or competence of a pharmacist or a pharmacy), 62 complaints and 21 inquiries. She outlined how concerns are reviewed internally to determine if further action is required. Complaints must enter into the formal process and are formally reviewed by the Preliminary Proceedings Committee (PPC) to decide whether further action is necessary. Ms Murphy noted that complaints that require further action post-PPC review can be resolved by the mediation process, where both parties agree to the process without having the need to be heard in front of a Committee of Inquiry. Part 6 of the Pharmacy Act was discussed in terms of professional misconduct and poor professional performance, as was the level of “seriousness” and the impact of the Corbally judgement. Ms Murphy had a number of key messages for those pharmacists who find themselves in an FTP process, which were: to engage early; keep good records and documentation; read the PSI complaints guide; respond to the PSI with your observations; and reach out and seek advice from others, for example your legal team and the IPU prior to responding, as your response at an early stage follows with you through the entire process. For those pharmacists who progress to a Committee of Inquiry, she strongly highlighted the importance of appearing in front of the Committee.
Ms Murphy outlined the role of the expert witness, which was to be independent, impartial and objective. She provided a brief overview of their role and the importance of their contribution to the process of determining the threshold of seriousness, that may be applied. Ms Murphy also clarified that these pharmacists receive training and remuneration, and that later this year the PSI will be seeking expressions of interests for pharmacists interested in this role into the future.
Laura Irwin (Acting Community Pharmacy Quality and Safety Manager), then gave an insightful presentation on current governance roles as provided for in the Pharmacy Act 2007. Ms Irwin shared with the audience the plans that the PSI has for supporting these roles into the future, and she outlined that guidance regarding this topic will be published before the end on the year. What was clear from her presentation is that while three governance roles are provided for in the legislation, i.e. pharmacy owners, superintendent pharmacists and supervising pharmacists, the PSI is also clear that any pharmacist who is not in one of these roles also has significant governance responsibilities. These responsibilities apply to all pharmacists whether they are permanently employed in a pharmacy or not, and Ms Irwin clearly outlined how all pharmacists are responsible for their own professional actions or inactions. Ms Irwin explained what “whole time charge” means for supervising pharmacists, and was keen to point out the flexibility within the Act, in that no set number of hours are specified.
Ms Kissane then led the final session on the recently launched Workforce Intelligence Report. She discussed its link to the PSI Corporate Strategy (2021-2024), and how this work has enabled baseline data collection which supports in assessing the risks to the future sustainability of patient-facing pharmacist roles. She outlined that this was a sentiment-based survey but that results could be deemed statistically significant. Copies of the survey were available on the night for attendees. Ms Kissane gave a comprehensive overview of the key findings and recommendations contained within the report. She also highlighted how this work will be fed into a Department of Health-led project on the wider healthcare workforce and outlined plans to collect data on an annual basis to establish trends. She finished this session outlining that there was good momentum and positivity at the moment regarding progress in key areas, and she highlighted her commitment to supporting the recommendations in the report.
During the questions and answers session, the panel received questions on the Working Time Directive, the Third Country Qualification Recognition (TCQR) process, the Committee of Inquiry and on timelines for the FTP process. The night wrapped up with Ms Kissane highlighting pharmacists’ role as autonomous healthcare professionals and the PSI plans to move away from a standards-based approach to one of a principles-based approach. Overall, the feeling from attendees was of cautious optimism, and a feeling of being listened to by our Regulator.
Head of Strategic Policy, IPU