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Draft Pharmacy Practice Framework
Council of University Heads of Pharmacy (CUHOP) Response to Consultation
Document
General remarks
This is a useful attempt to put into the context of a framework
model the activities of pharmacists in 'practice' but it is probably
too detailed and would need frequent revision in light of new product
development and changes to practice, for example, there is little
mention here of prescribing roles.
The first specific point that must be addressed is the need for
a good working definition of 'practice'. Most, but not all, of the
framework relates quite comprehensively to those vast majority of
pharmacists in clinical practice, that is in the community and hospital
sectors. There are also areas of the Framework of relevance to those
advising other health professionals without any direct patient contact,
e.g. those working for health authorities and trusts. It is alluded
to that it should also apply to academic and industrial pharmacists
but this is covered somewhat superficially and the Framework adds
little, if anything, to the professional obligations normally expected
of those working in these areas, e.g. the standards expected of
all HEI academics. This does highlight a long standing question
which needs to be clarified concerning whether or not pharmacists
involved solely in these two areas can be considered as practising
the profession of pharmacy. With the new General Pharmaceutical
Council this may be resolved anyway but it needs to be considered
carefully. Perhaps some framework will be needed for those involved
in teaching specifically practice and clinical aspects of pharmacy
and these people alone in academia might operate as practising pharmacists,
especially if they have patient contact through teaching. Similarly
those in industry involved in clinical trials might also be included
under the umbrella.
A case could also be made that even for community and hospital
pharmacists the draft Framework does not clearly demonstrate what
makes a pharmacist unique.
One introductory paragraph (page 7 of the document, titled A reference
point) is of particular interest to CUHOP. Here an attempt is made
to explain how the Framework would apply to a pharmacist on 'day
one' and how it could relate to the MPharm or pre-registration year.
One view in response to this explanation is that there is much that
an MPharm graduate could not fulfil in terms of the Framework. It
reads much as a competency framework, which is quite understandable,
but it must be recognised that much of the MPharm is not competency
based in its assessment. This is because although clinical and practice
skills are taught they are not actually assessed, or developed by
the learner in a practice setting. Therefore the competency part
of pre-qualification preparation for practice is mostly undertaken
in the pre-registration year. Although this could be changed if
in the future there were an integrated degree - pre-registration
programme, even in this scenario there are a number of areas in
which competence on 'day one' would not be expected within the Framework
described, e.g. management and HR skills, which seem to be set at
a high level of sophistication and even expectations of a new pharmacist's
clinical capabilities; perhaps overly ambitious in some respects.
At a more philosophical level, university study should be more focused
on education than on vocational training. Another view, compatible
with the view that the Framework is not realisable by a 'day one'
pharmacist, is that the Framework does not attempt to outline a
career structure for pharmacy, whereas similar frameworks written
by/for other professions do describe what might be expected of a
practitioner up to a 'career', advanced or consultant level. This
may be a missed opportunity and certainly such a framework would
aid in design of postgraduate educational programmes. Further in
this vein, the Framework could be tied in with CPD for post-registration
pharmacists, to ensure the development of the knowledge, skills,
attitudes and values of the 'day one' pharmacist.
On general reading it does become apparent that a good indication
is given of what may be needed from certain areas of the MPharm.
These include:
a. Social and behavioural sciences
b. Pharmacy practice - pharmacy management and the modern pharmacy
c. Legal and ethical issues
d. Clinical pharmacy and therapeutics
e. The 'biological sciences', e.g. pharmacology, biochemistry, immunology,
although this could be more clearly presented in the text.
f. Public health
g. Health-/Pharmaco- economics
There seems very little reference to the physical sciences, within
which one would include many aspects of materials science and manufacturing
processes plus analytical and synthetic chemistry. Formulation itself
is not actually mentioned and compounding (Role 4, Function A, Activity
1) and asepsis only relates to a single activity. Overall, the pharmacist
as the scientific expert on medicines really needs to come across
in this Framework. S/he does not at present.
General comments on seven principle roles
As discussed, the focus is mainly upon the activities of hospital
and community pharmacy. The knowledge base of much of the MPharm,
outside of practice, as currently taught in most programmes is not
obvious from these roles. Function E within Role 1 is somewhat strangely
constructed and imprecise terms have been used, e.g. "compound
pharmacology", "bio pharmaceutics materials science"
and "advancements". Indeed, 1E is quite differently worded
on p.7 compared with p.13 of the RPSGB's document. Contained in
this Role 1, in Function E, is a mention of three branches of science
in pharmacy and their relation to industrial pharmacy, yet in the
actual Framework they only relate to one activity. There seems to
be no mention of some areas such as analytical methods, natural
products, radiopharmacy and manufacturing process technology. A
better approach might be to develop a portfolio of roles and match
these to job functions, e.g. a hospital teacher-practitioner may
need a range of generic, hospital and academic roles. A research-active
academic a different set, and so on.
The level of detail in practice elements appears to deny the sense
of a broad Framework. This is especially noticeable when examples
of detail include "products for disposal are stored in a suitable
container and clearly identified". This detail could be reduced.
When one considers the seven principal roles it leads to the thought
that a new one might be created from role 1E on medicine design
and that Roles 2 and 6 might be amalgamated and supplemented with
diagnosis and prescribing and possibly other elements.
Some comments on functions and activities
We are aware that others have made or will make detailed comments.
We will not rehearse all of these but would observe that the consensus
view is that there is much work to be done, both in content and
a consistent suitable form of language, to arrive at a revised Framework
for potential adoption and implementation. A limited number of comments
from CUHOP are set out below.
Role 1 Function B Activity1
Should be rephrased to read; 'has easy access to key electronic
databases and bulletins on line in the place of work and uses those
which are relevant to practice on a regular basis'.
Role 1 Function E Activity 1
As stated above, within this one activity appears to be the focus
of the R&D side of industrial pharmacy that should really demand
a much larger set of individual activities and indicators if one
is working within this field of practice.
Role 1 Function F
This attempts to give an overarching framework for training and
education roles within pharmacy. The activities are generally useful
for practitioners who are involved in training activities e.g. pre-registration
tutors, although it is difficult to identify their pharmacy-specific
nature. It may be just as useful to state that those involved in
training must keep up to date with training techniques and pedagogy,
undergoing the appropriate CPD and short courses (training the trainers)
to maintain competence in this activity. Likewise the 'educational'
part of the function might best relate to activities 3 and 4, but
they are not pharmacy-specific and neither do they relate to the
full range of activities of academics in education. It would be
just as effective to state that all those involved in HEIs are expected
to adhere to the standards of HEI lecturers by completion of a post-graduate
qualification in teaching, and compliance with the QA procedures
of their institution for learning and teaching. This raises the
question of whether or not academic pharmacy is considered as a
'pharmacy practice' area.
Role 2 Function B Activity 1
The term concordance is used a bit out of context here and in other
parts of the document. Concordance cannot be assessed in the sense
it seems to apply, other than it could be assessed as to whether
or not this model of practitioner-patient interaction is being implemented.
Much of this section could be rewritten in the light of pharmacist
prescribing.
Role 2 Function B Activity 5
Probably needs a lot more with statements on diagnosis and clinical
examination skills.
Role 3 and Role 4
In general, standard operating procedures should be referred to
specifically in the various activities. Again reference should be
made to prescribing.
In particular Role 3 Function A needs to be phrased more broadly
to include all the pharmaceutical sciences (not just pharmacology)
that are important for the appropriate and rational use of medicines.
Role 3 Function C Activity 3
Does not really describe concordance, i.e. the patient's valid input,
indeed it seems antipathetic to the concept.
Role 4 Function A Activity 1
Has already been discussed and seems to describe the process of
compounding and extemporaneous preparation, which is not undertaken
in community pharmacies and only in certain hospital units or by
specials manufacturers. There is a great deal more involved than
these activities, for a useful Framework. What about manufacturing
and formulation? If there is to be little recognition of these in
the Framework then it may have implications for the curriculum.
Role 5
Most of this section seems inappropriate for a 'day one' pharmacist.
It is doubtful that these could be covered by HEIs as described
by this Framework; the MPharm does not teach change-management,
for example.
Role 6 Function A Activity 1
Preferable would be to state 'always provides a safe, quiet environment'.
16 October 2007
RPSGB framework resp.doc
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