Consultation Document

Questions

I Are the functions set out in the Carter Report sufficient as the remit of a new body?
We think that the new leadership body should exist:

- to promote and facilitate the interests and personal development of its members, for the public good

- to provide leadership and professional advice to Government, NHS bodies, the pharmaceutical industry and the public on policy matters and strategic developments in or related to pharmacy

- to develop and promote the practice and science of pharmacy and medicines research, development and usage.

II Are there functions set out in paragraph 12 of the Consultation Document, or in the Carter Report, which should not be part of the role of a professional body?
The new body should not undertake any form of policing.  A function of the new body should be giving of its expertise or the expertise of its members.  It might undertake or facilitate forms of peer review.  The interface and relationship with the General Pharmaceutical Council (GPhC) will be key to the new body not being perceived as a tool to censure pharmacists or other members; deterring those persons from seeking membership.

In respect of accreditation of educational provision or possibly pharmaceutical services, the new body should have a role of attesting that an individual or organisation has evidenced meeting an explicit standard but dealing with any person or organisation that has failed to meet such a standard should be a matter for the GPhC, where the standard pertains to a regulated activity.

The new body should have a role in standard setting and development.  A bit like the relationship of the Health Professions Council with the professional bodies in its constituency.

III Are there any additional functions that the body should perform?
The new body should have a broad scope in respect of health and medicines (including medicines discovery/design, development and clinical usage) and an international perspective and membership.  It should not be just for GB-registered pharmacists nor indeed just for pharmacists.

IV Where these functions are currently performed by existing organizations, how should those organizations relate to a professional body in the future?
This should be entirely a matter for those other bodies once they have experienced the new leadership body in existence and operation.  It will help if, as soon as possible, the new body is clear about its roles and processes.  Where there is an intention of other bodies to join we would urge that this take place early on, in order to strengthen the development of the new body.

V What activities are essential to gain the maximum support from the profession and ensure the financial viability of a professional body?
Within a broad educational role to enhance knowledge and skills, the leadership body can serve a particularly useful purpose and survive by focusing on helping its members to fulfil the CPD or personal revalidation requirements of the GPhC, other regulatory bodies or employers.  This might be the key selling proposition of the body but it could engage in all manner of other membership services, such as professional indemnity insurance.

In attracting and retaining members, professional or certified status with designatory letters after one's name will be important.

We expect the new body to engage in and be valued for educational provision in partnership with other bodies, especially Schools of Pharmacy.

VI Following the establishment of the GPhC should the residual RPSGB assume all the functions of a new professional body?
If the leadership body emerges from the Royal Pharmaceutical Society of Great Britain (RPSGB) then CUHOP would expect this to be the case; indeed it would be essential in such a case.  There are some valuable departments and personnel within the RPSGB that it would be a shame to lose.

VII If so, what changes to the RPSGB’s Charter and Constitution of Council would be required?
It is for the process of change that CUHOP has some of its most serious concerns about the way ahead.  When the RPSGB Council receives the recommendations of the Clarke Inquiry, we hope that all proposed significant changes will be embraced and a cogent package of reform implemented.  Perhaps there will have to be a steering group which draws from the Council and from outside to oversee the transition that might be necessary following the Clarke recommendations.

As to the outcome, CUHOP hopes that the new body will be organized and run as a business, with a small governing board of directors informed by such national and other advisory committees as the organization can afford.

VIII If not, what should the division of functions between the residual RPSGB and a new body be?
CUHOP does not foresee a viable future for RPSGB unless it becomes the new body, other than potentially providing certain resources and personnel that could be retained by the new body.

IX Which, if any, organizations should ‘coalesce’ to form a new body?
No body other than perhaps RPSGB should be compelled to form in whole or part the new professional leadership body but CUHOP would hope that some or all of the 'Waterloo Group' of organizations would merge with or come under the umbrella of the new body; the new body being constituted to allow for the needs and wishes of special interest groups to do with medicines and their usage.  CUHOP recognizes the current successful agreement between the APS and the RPSGB and believes that great strength could be imparted to the leadership body if the APS were to be part of this new organization.

X Which, if any, of them need to be included from the start?
No comment.

XI Do you favour the use of the title ‘Royal College’ to describe such a body?
On balance CUHOP would be in favour of such an appellation.  For bodies in the UK, Royal in a title is a mark of standing and this is recognized internationally; bodies such as the Royal Society of Chemistry and the Royal Academy of Engineering are august bodies.

XII What should the role of a professional body be, in developing and setting professional and ethical standards?
The new body should design and promote standards in consultation with other organizations and its own members, in pursuit of the above-mentioned object of the development and promotion of the practice and science of pharmacy and of medicines research, development and usage.  Clearly it will only be able to introduce standards by consent.

XIII What would the requirements of the regulator be, if it were to permit a professional body to take the lead in drawing up standards?
It should not expect the professional leadership body to police such standards; that would be a job for the regulator itself or another delegated or contracted body (not the professional body).  The professional body should help individuals, groups or organisations demonstrably meet standards and attest that they have been met.

XIV To what extent are such requirements met currently?
To a reasonable level, in respect of accreditation of both pharmacy undergraduate education and training for prescribing, to a mixed extent in respect of pharmacy preregistration training and assessment and inspection of pharmacy premises, facilitatively for CPD though for CPD no requirements really exist yet.

Clearly there is scope for improvement and for most such requirements there would be value from academic input; expertise from the university sector could be better marshalled and applied to these purposes.  There is a particular worry that the present process of review of the criteria and syllabus relating to the undergraduate programme is being rushed.  The “fit for the future" process needs more engagement with the academic community.

CUHOP recognizes benefits in a professional body freed from regulatory responsibilities that could be more proactive in supporting institutions preparing for the degree accreditation process.

XV What should the role of a professional body be, in undergraduate education?
The curriculum, that is the syllabus and methods of assessment, 'belongs' to the profession.  In pharmacy's case this would most obviously be embodied by the new leadership organization and further in pharmacy's case it should extend to preregistration training as an integrated package with the undergraduate programme.  Furthermore, the new body should have a major role in confirming that university schools have met or continue to meet appropriate explicit standards for or relating to the curriculum; a very different role from ‘policing’.  In short, it is essential to locate educational thinking and development in the new body and for it to engage with the higher education sector.

XVI How would this be financed?
The GPhC should fund any confirmatory processes forming part of or linked to degree accreditation.  (It should be kept in mind that pharmacy academics presently subsidise such processes by not charging market rate costs for their personal involvement.)  In reaccreditation there is immediate benefit to the regulator in the School of Pharmacy concerned graduating prospective new registrants.  Universities will continue to meet the costs of assembling the evidence of their meeting appropriate explicit standards.

XVII Which of the existing functions of the RPSGB should be performed by a new professional body?
Those which are sufficiently valued by its fee paying members or contractors for its services.

XVIII How should they be funded?
From the body's general funds derived largely from membership fees and by payments for contracted services.

XIX Are there any other functions a professional body should undertake for pre-registration trainees?
The professional body should do what RPGSB does now and further develop relevant policies and processes; there is a particular need for better support for students as proper, formal student members of the new leadership body.

XX What should the role of a professional body be, in post-registration education?
Primarily facilitation of evidencing CPD or meeting revalidation requirements; acting as a facilitator and accreditor/attestor.

Linking to the new body’s educational role, CUHOP would expect it to run short courses and conferences, probably including the British Pharmaceutical Conference.  It must be a centre of education thinking for pharmacy.  The new body would most probably work in partnership with Schools of Pharmacy in respect of more formal, credit- or award-bearing courses.  In such cases, it might be universities approving the quality of delivery, based of the relevant precepts of the Quality Assurance Agency (QAA) for higher education (or equivalent bodies abroad).

XXI What should be the role of a professional body in CPD?
See earlier comments.

XXII Should a professional body be a provider or an accreditor of CPD? Or should it be both?
It can be difficult for a professional body to take on both of these functions; conflicts of interest can emerge.  There will need to be an open relationship with members or other 'consumers' about these matters and open and clear agreements with other organizations in individual sectors or localities; in some cases the new body will be the provider and in some cases it will be the accreditor but not normally both together.  Where it is the provider, one or more universities might be the accreditor.

XXIII Should a professional body be involved in developing standards and systems for revalidation?
Involved -- developing, testing and promoting underpinning research -- within a framework defined by the GPhC.

XXIV Should a professional body offer services to members to assist them in meeting the regulator’s revalidation requirements?
Definitely, yes.

XXV Is there support for an Academy of Pharmacy Practice?
CUHOP supports the model of the new professional leadership body having a number of academies or faculties within a matrix structure to see a home for cross-sectoral interest groups among the 188 or more pharmacy-related bodies/interest groups within the UK.

XXVI Would an Academy of this sort be financially viable?
Possibly not as an academy of pharmacy practice; more likely to be sustainable are academies/faculties congruent with employment sectors; community (possibly titled primary care), hospital, industrial, etc.  A guiding principle should be that persons potentially interested in joining the new body should recognize 'a home' easily and quickly.

XXVII Would existing specialist bodies and groups be prepared to work to develop such an Academy and would they be prepared to be subsumed within it?
Joint working; certainly so.  To be subsumed; such should be according to the relevance of the new body to the objects of the individual specialist bodies.

XXVIII Should the Academy of Pharmaceutical Sciences become a component of a professional body?
This is entirely up to APS and its members.  CUHOP would not envisage APS, any other organization or group, or any individual being coerced into the new body, but it does see the value in demonstrable alignment of scientific and practice effort in the advancement of the profession.

XXIX How should a professional body (or bodies) be best structured to address national and regional issues?
Given devolution, there will have to be some structuring to allow addressing of issues particular to Scotland or Wales and there is value in the new body not being overly 'London-centric'.  University Schools of Pharmacy, widely dispersed around the country and sometimes with satellite academic practice units in more remote areas, are well placed to help the new body with meetings at a national or regional, or even at local level.

XXX What governance model should be adopted for a professional body?
Possibly, the new body should be a Company limited by guarantee with charitable status for as many of its activities as possible.
 
CUHOP envisages that members will join the new body directly into one of the academies/faculties as their main academy/faculty and vote for that academy/faculty’s representative/s on the governing board of the new body with the President elected by and from the board.

XXXI How should committee structures be determined?
As judged best by the governing board apart from within the academies/faculties; deciding for themselves, within a given budget

XXXII What principles should determine the proportions of elected, nominated and appointed members of committees?
What will best assemble the competencies required to fulfil the remit of the committee.

XXIII Should specific recognition be given to sectors?
Definitely.

XXIV How should specific functions be reflected?
If this means specialties, probably not beyond the academy/faculty structure.

XXV What should the lay input be?
Expert and only as invited; not lay input for its own sake.  The new body, not being a regulator, should be a pharmacy-driven organization.  It must have the capacity to argue across the heath and political landscape from a pharmacy perspective.  In activities such as standard setting it would need lay involvement but there is no need for contrived involvement at an organizational level.

XXVI Should there be different categories of membership of a professional body? If so, what should they be?Student and Member but also there should be recognition of Chartered status, with designatory letters, over and above ordinary membership, and there should be Fellows.  Chartered status equates with postgraduate qualification or experience.  Pharmacists would all be Chartered as would pharmacy technicians with a degree and structured postgraduate experience.  Most pharmacy technician might be fitted into this structure as just Members.

Categories of membership and how one can progress through them should bring credibility to the Student or Member and to the leadership body.  It may be possible to have Licentiate, Associate and Graduate sub-categories of Member.

Fellowships should be awarded or granted by the academies/faculties.

XXVII If membership is to be wider than those registered with GPhC, who else should be included?
Anyone from the UK or Worldwide who is a practitioner or expert in researching or the use of medicines should be welcome to join.  However, the new body must also be a credible representative body for pharmacy in the UK.

XXVIII Should student membership be allowed/encouraged and if so, should they pay subscriptions? Yes and pay an initial fee, not an annual fee, for such student membership.

XXVIX Should pre-registration students pay subscriptions?
Yes, as now.

XL What should the incentives for membership be?
There might be separate letters for membership and, for those members warranting such, chartered status, respectively MRCPh and CPharm.

XLII Should a new professional body share premises and facilities with the GPhC?
Most definitely not; such an arrangement would not convince stakeholders of a proper separation of regulation and the professional body having been achieved.

XLIII If not, where should a new professional body be located?
Wherever is most cost-effective for its business plan.  There may need to a base for lobbying in London but this need not be accommodation for which the new body has freehold or extended leasehold.

XLIV Should a professional body act as the guardian of the archives and museum of the RPSGB? Not necessarily.  These might need to be disposed of; being too great a load for the new professional body, whether or not it emerges from RPSGB.