The Council of University Heads of Pharmacy Schools (CUHOP) comprises the heads of UK schools of pharmacy which enrol students to read for a Master of Pharmacy (MPharm) degree with the expectation of registering as a pharmacist in the UK. CUHOP has evolved from and replaces the former UK Committee of Heads of Schools of Pharmacy. The objectives of CUHOP are, to

1. represent the collective interests and views of the Schools of Pharmacy
2. develop and articulate a vision for pharmacy education in the UK
3. liaise with professional, national and local bodies on matters relating to pharmacy education and research
4. establish CUHOP as a body to be consulted on matters of higher education policy
5. engage with international bodies and at international forums on matters pertaining to pharmacy education
6. work with other healthcare professions to develop educational policy and practice
7. promote UK pharmacy education and research

CUHOP welcomes and, when invited, will engage with the RPSGB's pharmacy education policy review. CUHOP regards as sensible the setting out of principles to underpin and guide the review.

CUHOP is pleased to note that the principles, "are not intended to supersede any other sets of principles, standards or guidance issued by the Society or any other body involved in pharmacy education and training.";

Several CUHOP members have submitted views and comments to the CUHOP chairman and secretary with the purpose of producing a collective response, in addition to the individual responses from UK schools of pharmacy to the RPSGB. Given the wide scope of the draft principles, it is no surprise that there has been a considerable diversity of inputs. This has created something of a challenge in producing a CUHOP collective response. The approach we have taken is to try to express representative views while also including what we regard as important or interesting views or comments made by one or two respondents only. We have organised the set of responses by the sections of the original consultation document from the RPSGB; there are general views pertinent to a section and then more specific ‘answers’ to the questions posed in the consultation document. Quotations are direct from the responses of individual CUHOP members.

CUHOP would observe that in the letter and briefing paper sent to universities there was no description of how the present draft principles were derived and adopted as the focus of this consultation. CUHOP would welcome publication of some of the background thinking with, if at all possible, citing of the informing academic papers, Government documents and the like. As the pharmacy education review is taken forward, reference should be made to other professional organisations, colleges and faculties (e.g. the College of Pharmacy Practice). The pharmaceutical industry should be included among the stakeholders providing employment to pharmacists and pharmacy technicians.

It is clear that it is unnecessary for the next step in the pharmacy education review to ‘begin with a blank piece of paper’-type approach. Good educational practice is the norm for UK MPharm programmes and there are examples to be found of outstanding practice; as one CUHOP member puts it “we… are pleased to see that we are already conforming to most of the [implicit] recommendations”.

RPSGB is right to include the proviso about the achievability of developments in pharmacy education and training: that appropriate resources and investment are available. The whole tenant of this document would be undermined if appropriate resources were not to be secured. The RPSGB must secure guarantees of funding to universities and colleges before changes to curricula are made.

The science base of the profession seems understated, even undervalued in the consultation document.

Referring to those responsible for funding pharmacy education and training, RPSGB does not include overseas sponsors of international students in UK schools of pharmacy and more significantly does not include students and parents of students, both from home and overseas. RPSGB needs to be mindful of recent changes in the funding of higher education and their impact.

There remains a need to select undergraduates by academic ability, at the very least to try to ensure that schools of pharmacy predominantly enrol people who are able to cope with the demands of the MPharm programme, while also considering attitudes and skills. There are obviously equivalent considerations in selection for technician training. Assessing attitudes and skills (by for example effective interviewing or a national attitude and skills test) would present significant challenges and additional costs. This set of issues requires further information and discussion, not the least on what attitudes and skills one might reasonably look for in an 18-year-old, before there can be any decisions on selection strategies and methods to be employed in the future.

An overall caution is that pharmacy must be careful not to select only one type of applicant or ‘clone’; a path to limiting diversity.

A1. CUHOP would expect that for at least some schools of pharmacy not all applicants will be admitted and that there will be discrimination between candidates in their selection. As one CUHOP member has put this, “we need to be careful here that we don’t overlook the importance of academic rigour, nor do we overlook the principles of academic ability, potential and commitment”.

There needs to be some closer idea given of what the terms “flexibility, inclusiveness and equal opportunities” mean. However, assuming our understanding is not awry, there are relevant principles of this type already embedded in UK higher education. As simple statements of fact: all universities have to demonstrate that they are compliant with the five principles described in the Schwartz Report, Fair admissions to higher education. Thus and in addition, universities need to make their admission policies public. Universities and other HE course providers should be able to determine levels of prior academic attainment necessary for admission on to their courses. Applicants need to demonstrate that they are proficient in the language in which the course they want to undertake will be taught.

CUHOP does of course recognise that there will increasingly be needs or demands to consider potential fitness to practise at selection for, or at an early stage within, the MPharm programme, especially if clinical placements are to be an essential part of the programme. However, judging the suitability of applicants for a career in pharmacy might come into conflict with the pressures for widening access, flexibility, inclusiveness and equal opportunities identified above. For example, it is one view that “certain disabilities, such as severe dyslexia, are not compatible with pharmacy practice despite the Equal Opportunity laws which apply generally”.

The need to promote a ‘skills escalator’ (a route for pharmacy technicians or graduates of related science disciplines to gain ‘accelerated’ entry onto MPharm programmes) is recognised. 

A2. The main discriminators for deciding on selection will inevitably remain as academic achievement at secondary education level and evidence of commitment to pharmacy or wider health care (most usually evidenced by work experience). However, there are important other considerations emerging:

An increasingly important consideration for entry is that of previous criminal convictions and whether an enhanced CRB check may be required. There are two sets of ramifications here. Firstly, an adverse CRB disclosure will exclude the applicant from a growing number of activities related to the pharmacy profession, particularly where there is a responsibility of care to vulnerable people. Secondly, as most curricula now require placements in local NHS Trusts, albeit of short duration, an adverse CRB disclosure may bar a student from undertaking this important part of their studies and lead to failure to meet the required learning outcomes.

The RPSGB should provide guidance to all organisations and bodies as to specific circumstances or conditions that may potentially represent a barrier to registration or practice by an individual, e.g. serious criminal conviction, medical conditions. To an extent this could be alleviated if student registration was introduced but CUHOP is guarded against this step unless as part of an integrated package of developments.

Two contrasting observations from CUHOP members are: “the selection statement makes no mention of improvement, encouraging excellence, rigour etc. It appears to require the ‘bare minimum’” and “with the large growth in pharmacy undergraduate numbers of the last years, it is possible that in future recruitment onto MPharm programmes, rather than selection, will be the norm”.

A3. There was no consensus on the response to this question. Its scope was thought to be “so broad as to be almost meaningless” The only thing that might be said is that consideration of principles to apply to selection for entry need to be looked at programme type by programme type.

CUHOP broadly agrees with the relevant principles.

However, “there could be some robust discussion over the relationship of education and training. Some of our hospital colleagues believe that the pharmacy degree should be about training rather than education. Pleased to see that Science is still included in the learning outcomes but could be given more prominence.”

Pharmacy should be very careful in approaching the higher education funding councils in relation to possible funding band changes for the subject. Clearly, we want to get some recognition and acceptance of the importance of patient contact and some tangible support for it but would not want this to be with the loss of 'science funding' for classroom aspects of the undergraduate programme. What would perhaps be better than a funding band change would be to have mandatory access to the NHS i.e. funding to recognise the costs to the NHS.

The long talked about idea of a five-year integrated degree is generally accepted as a desirable goal on academic/professional/motivational grounds but there is the need for much more discussion on resourcing and responsibilities in terms of who sources and then quality assures the elements outside the university. For this to progress to fruition there would definitely be a need for mandatory access to the NHS, with NHS pharmacy staff being committed to roles in teaching and training.

A4. CUHOP members harbour some reservations about the vagueness of flexibility, inclusiveness and equal opportunities. However, in universities, in the areas of curriculum development and content, promotion of these sorts of features is probably straightforward, not the least because such principles are already embedded. Indeed, one CUHOP member opines, “there is probably no particular need for separate guidance relating to Pharmacy”.

At least one CUHOP member wonders if promoting flexibility may extend to allowing part-time provision of pharmacy undergraduate education. He feels that the profession and the university sector within it need to decide whether or not to engage with this idea.

A5. The draft principles here are unobjectionable and for the most part already complied with in the university sector. They are not however, thought to be sufficient.

CUHOP would hope that there could be principle/s related to the pursuit of excellence in teaching, learning, assessment and student achievement. There should also be a principle that for future pharmacists a significant proportion of teaching is research-led.

As to syllabus content, many would subscribe to adding something along the lines: the application of scientific knowledge, method and thought in the practice of pharmacy.

There has been one call for “consistency in certain core areas of the curriculum; which could be achieved (and made more efficient for staff) by sharing of teaching resources. Consider the excellent resources developed by the APPLET Project for example.”

There should also be (a) principle(s) related to the development of “the mindful (reflective) practitioner/professional – the ability to recognise and define personal/professional 'scope of practice' and to know one’s own limitations. Interprofessional working (best achieved in the clinical environment) also needs to be stressed.”

There are currently constraints on “fully meeting the objectives of ‘patient centred’ education, as any placement contact within the four-year undergraduate programme is severely limited. Therefore students have little contact with patients or other health care professionals to allow them fully to contextualise their learning. Solutions may lie in the incorporation of elements of pre-registration training into the MPharm programme and extra clinical funding for placement activities.”

A cautionary note is that “careful thought needs to be applied to the balance of knowledge, skills, attitudes and behaviour. There is a danger that the latter agenda is running away at the expense of knowledge.”

A6. Generally and without presuming to ‘tread on the toes’ of those in the FE sector, CUHOP would answer, ‘yes’, to this question. As one CUHOP member has put it, “it is essential that all education and training is focused on the well being of patients and the use of advancing knowledge and skills to achieve this well-being. Inter-professional education and training should be encouraged but must be managed in such as way to maximize the benefit of such education for all concerned and should be clearly focused on improving patient care.”

Another has responded, “there are occasions where these conditions would apply for postgraduate programmes, e.g. in University based higher degrees or when a professional competency is being acquired (e.g. independent prescribing). On other occasions (e.g. basic CPD) this is clearly not appropriate.” A comment from another links quite well; “generally the principles should be applied but an exemption made for certain roles and/or specialisations”

Within the university sector, clearly there could be problems of achieving research-led teaching if research endeavour were completely to disappear from some schools.

The Quality Assurance Agency for Higher Education (QAA) Code, QAA institutional reviews and university internal regulations, guidelines and audit procedures do much to assure high quality in the conduct of student assessment.

A7. CUHOP would like to know some of the detail of the provenance of the suggestion of, “the involvement of the public and patients in assessment development and process” However, as to the suggestion as stated, CUHOP believes that this is happening to some degree in all or most UK schools of pharmacy already, for example within objective structured clinical examinations (OSCEs).

Of course, in the case of programmes leading to formal qualifications (especially undergraduate programmes) this patient/public involvement has to be very carefully managed to ensure consistency and validity of assessment. Where patients/public are or are to become involved in formal assessment then adequate training and support has/would have to be provided. Furthermore, careful consideration needs to be given to when it is most appropriate to expose students to patients/public in a ‘formal’ assessment situation. This will naturally fall into areas that are seen as clinically or practice related, particularly if involving some form of OSCE. Furthermore, as clinical competencies such as prescribing become incorporated into the undergraduate curriculum, this type of patient partnership will grow as it has in most other Health Professions. A block on such developments to their full potential will be if the current model of education does not change and greater patient contact is not undertaken during the undergraduate programme.

Other healthcare professional groups have long enjoyed the involvement of the public and patients in assessment development and process and such would be welcome within pharmacy education but it will require great care, control and management, which will necessarily involve a significant cost. 

A8. Assessment of university students must be valid, reliable and explicit, to conform with Quality Assurance Agency for Higher Education (QAA) requirements. The draft principles reflect these needs and so should cause no difficulties for university schools of pharmacy. Furthermore, CUHOP accepts that the assessment of competencies, as well as knowledge, is appropriate for patient centred healthcare professionals and this should be a growing part of pharmacy education and training programmes.

One principle we would add is that at least for those assessments that impact on professional qualification or accreditation for delivery of services they only be carried out with rigorous 'candidate confirmation'. In the case of assessment for MUR/PI service provision this has been in doubt. Universities and other institutions should be able to demonstrate in such cases that the person undertaking the assessment is the candidate him/herself.

Cost - benefit analysis should be made when considering various types of assessment, for example OSCEs (which are time-consuming to set up and assess well) compared with Multiple Choice Questions. 

Q9. Yes, any assessment must be appropriate, robust and fair whatever environment it is being carried out in. However, while the principles might equally apply, there will be significant process and practical differences between assessment of education and that of training.

CUHOP recognises that this question relates very closely to the question of whether or not student registration should apply in pharmacy. We are responding for the status quo situation but in the belief that some of what follows will be equally valid and possibly even more important if there is a move to student registration.

However, in our responses here we are making certain assumptions about what is rather sparsely written in the consultation document. There is a need for clarification about what the two principles here mean - do they refer to academic failure or lapses in professional standards or both?

“The GMC has set out for its GP members the types of criminal act that would bar them from practice, it has also informed its members that they are not subject to the Rehabilitation of Offenders Act. Guidance has been adopted by Medical Schools' Admissions Group’ which help clarify the circumstances when students should be refused admission or removed from courses.

“In relation to pharmacy, the HEIs and other course providers need to have a dialogue with the professional body to determine basic criteria that would allow these institutions to:

• Refuse entry to students

• Remove students from their course.

“This might involve representatives of the RPSGB engaging with HEI fitness to practice Boards. Guidance on types of aberrant student behaviour that should be reported to the RPSGB and that which could be managed 'in house' will also be useful. There also needs to be clarity as to what would happen to the information that is provided to the RPSGB about students' behaviour.

“The HEIs might be in breach of the Data Protection Act if they keep information on file about students for no purpose.”

Others are wary of this level of engagement: this is “ an extremely contentious area. I think it only becomes appropriate if we have a properly integrated 5-year programme (linked with a structured post-registration programme also) which I support strongly in which case students would be on a confirmed track to becoming a pharmacist when they enter a school of pharmacy.” “This needs careful consideration and is alluded to in our response to question 2 regarding previous criminal convictions. At… there are currently robust Fitness to Practice procedures that relate to all of the Health Professions except pharmacy. This is because of the current position of the RPSGB, namely that there is no formal requirement for the Schools of Pharmacy to pass on any information regarding Fitness to Practice issues that have arisen whilst students are undertaking the programme. It should therefore be made explicit to students on entry that such issues will be recorded and may affect a decision by the RPSGB to allow a student to undertake pre-registration training. Incorporation of a true placement experience into the curriculum may resolve these issues as employers will be directly involved in any Fitness to Practice considerations as in the other Health Professions.”

Drawing things together somewhat, CUHOP is in no doubt that if pharmacy is to further develop as a patient centred healthcare profession, and funding is available to increase the number of clinical placements undertaken on the MPharm course, then it will need to address fitness to practice issues at the undergraduate level to allow early patient contact.

A10. UK schools of pharmacy and presumably providers of pharmacy technician training as well, need the RPSGB to provide explicit guidance and tangible support in respect of “identifying students/trainees whose performance, conduct or health may put patients, colleagues or themselves at risk” and with respect to “advice, extra training and support as and when appropriate”. RPSGB does not even undertake this for itself with respect to preregistration trainees and as was heard at a recent meeting hosted by the Society at Lambeth is disinclined to give such guidance or support. The proposal for university schools to “take steps to prevent unsuitable students/trainees from progressing…” is fraught with difficulties. A dialogue between CUHOP, the higher education funding councils and RPSGB needs to be opened on these matters.

A11. Among the barriers here are lack of clarity and no resources to pay for expensive medical and legal advice and legal defence costs.

General comments on Teaching and Training

CUHOP would convey the cautionary comments: “The tenant that all registered pharmacists and technicians should be willing to contribute appears sensible until one realises there should be schemes to check their suitability for this contribution. It would seem a dangerous step to make such contribution mandatory.”

However, others are more sanguine at the practical level for the average or better practitioner: “The principles relating to teaching and training by registered pharmacists and technicians are well established within the secondary care sector. Extension of these principles to the community sector will be more challenging but greater involvement with students through placements and work experience schemes should assist.” And “I am supportive of colleagues being involved in mentoring, where they themselves are supported and where it is appropriate for them to do so.”

Another thinks the RPSGB has not gone far enough in its proposals and: “would like to see the first statement morestrongly worded e.g. It is expected that all registered pharmacists, technicians and organizations will contribute to training students and colleagues.”

CUHOP would here reiterate the desirability of mandatory access to the NHS for pharmacy students, with the appropriate resources directed to NHS pharmacy from the DH/SEHD/WAG/NI Office.

A12. CUHOP of course accepts that “pharmacists and technicians with responsibilities for teaching, training and providing supervision and mentoring should gain and develop appropriate knowledge, skills”. It is essential that anyone involved in formal education and training is appropriately trained to do so. It is also essential in pharmacy if sufficient clinical placements for undergraduates are to be secured. However, CUHOP has reservations about the inclusion of “attitudes and values”. What are these? And if they do not presently exist who is to define and review them?Another concern here is that the principle/s should be more explicit in defining how practitioners would be monitored and assessed in their training roles. There is a feeling that those working in the community sector have less support to undertake the role of trainers and educators.

It is to be hoped that persons other than just pharmacists and technicians should be willing to contribute to training students and colleagues in these times of inter-professional training.

A13. One has to guess at the provenance of the suggestion of, “the involvement of the public and patients in teaching and training” and so it is a little difficult to respond to this draft principle. As to patient involvement in teaching and training, CUHOP believes that this is happening in all schools already and would be pleased, with more funding for clinical teaching, to build on this relatively low base.This is though a contentious area for some, within one school, “we are divided as to the advisability of involving the public and patients in teaching and training; some members of staff (one of whom has experience of this) are enthusiastic but others are concerned about the level of such involvement by persons with little or no knowledge of the profession of pharmacy. We recognise that it is an important policy area with implications that need careful management; however, it has cost implications too and would need centralised guidance. It may not be practicable at all levels and may need to be reserved for higher levels of training.

A.14 The education and training role undertaken by community pharmacists may be problematic as this lies largely within the private retail sector. Unlike the hospital trusts they do not have the educational and training infrastructure at present to support this role. However, if a model were introduced whereby HEIs were responsible for an integrated five year degree incorporating the pre-registration placement, then it is possible to construct a package of support and training that could be properly quality controlled.

Some CUHOP members advise that “the application of the general principles needs to be made on an ad hoc basis”. “Sometimes, it would depend on the nature of the programme.”.

While RPSGB might adopt these principles, there is really no way of guaranteeing adequate resources for education and training in the higher or further education sectors. For more than two decades RPSGB and universities were helpless as the student unit of funding and staff : student ratios worsened. They would be equally powerless if these trends were renewed, as seems entirely possible.

There are an array of individual comments from CUHOP members which form a consistent theme:
“Clearly I must support the tenant of the introduction to resources. Again source of funding will need to be secured.”

““The key here has to be a well-argued case for clinical placements. My feeling is we should go for complete integration of the pre-reg into a 5-year programme.”

Those employing pharmacists and others undertaking education training and CPD should be expected to set aside appropriate time for students and trainees.”

“The principles of resource are sound but the professional body needs to ensure that employers and the NHS are aware of the CPD commitments within professional regulation so that adequate time can be reserved for pharmacist and trainees to fulfil these commitments.”

CUHOP would reiterate the warning about the caution needed if approaching Government and funding bodies in relation to clinical placements and possibly a five-year integrated MPharm.

Q17. Not only are these principles accepted they are fully complied with already and have been for some years in the university sector. RPSGB needs to recognise that it is only one player in this area with respect to university schools of pharmacy and the quality of their educational provision..

Q18. CUHOP is not in a position to know and would not presume to conjecture what principles may or may not be applicable outside the university sector.

Neither the draft principles nor these responses appear to CUHOP to be Home country-specific. However, it should be borne in mind with respect to the funding of higher education that in Scotland and Wales students and their parents are set to make a significantly different contribution to costs than in England, and that in Scotland and Wales pharmacy student numbers are far more constrained than in England. This being said, and recognising that practices in HE and the NHS may well significantly diverge for different parts of the UK, it appears that the pharmacy academic community would wish for the foreseeable future to have a single register of pharmacists entered by one qualification and overseen by one regulator (or perhaps one regulatory framework is the best way to put this – discussion here did not conflate with the question of the continued role of the PSNI).