Hereunder please find the views of the Council of University Heads of Pharmacy (CUHOP) on the proposals for a professional leadership body for pharmacy (PLBP) within and arising from the recent White Paper, Trust, assurance and safety - the regulation of professionals in the 21st century.

The membership of 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 with the Royal Pharmaceutical Society of Great Britain (RPSGB) and registering as a pharmacist in this country. 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 has evolved from and replaces the former UK Committee of Heads of Schools of Pharmacy.

With respect to the proposal for a PLBP for pharmacy, CUHOP held an extraordinary meeting of its members on Thursday 15 March at the School of Pharmacy, University of London. Three quarters of the membership attended, despite the short notice of the meeting.

At the meeting, CUHOP considered the set of 'prompt' questions at Appendix 1 to this letter. In doing so it took account of relevant views about the nature of a PLBP from CUHOP submissions last year in response to the draft Section 60 Order for pharmacy and to the Department of Health consultation related to the Donaldson and Foster reports (these abstracted relevant views can be found at Appendix 2).

Consensus views arrived at at the meeting were as follows. It needs to be emphasised that the consensus was clear in all cases and few if any points discussed proved contentious.

CUHOP assumes that the new General Pharmaceutical Council (GPC) will be responsible for the accreditation of pre-qualification education and training and the re-validation of practitioners both for pharmacists and pharmacy technicians. CUHOP further assumes that the GPC might choose to delegate or sub-contract to one or more other bodies the actual undertaking of these functions. The PLBP might be one of these bodies but as a guard against complacency and inefficiency it should in no way have a guarantee or monopoly of any of these functions¹ . By similar logic, it appears inappropriate to CUHOP that membership of PLBP should be mandatory for any class of registered pharmacy practitioner.

CUHOP is pleased with the White Paper proposal clearly to split the regulation and professional leadership of pharmacy. This was our consistently stated view in the two relevant major consultations last year. CUHOP believes it highly desirable that a vibrant and successful PLBP emerges over the coming years. While this is not especially in the gift of the national health departments, they can of course be helpful in achieving this end.

The PLBP should have as a main object the development and promotion of the science and practice of pharmacy and of medicines research, development and usage.

The PLBP should be a learned body. CUHOP believes that the RPSGB has been diverted from this role over the past decade and more. An object of the PLBP should be that it promotes, facilitates and celebrates excellence. Thereby its members will command the respect of other scientists, health care professionals and decision makers in society.

The PLBP should not and probably cannot, be a trades union. The objects of the PLBP should align with the public interest and the body should not have a direct role in protecting or promoting the interests of individuals among its membership. In the public interest, the body should be unfettered in its freedom to criticise Government or NHS policies and performance in the areas of education and health care and indeed in any other areas relevant to pharmacy and medicines research, development and usage. An illustrative example here would be the ability of the PLBP, if it so chose, to criticise Government on the level of public funding for pharmacy undergraduate education.

CUHOP does not particularly covet the Royal appellation (neither does it eschew it) but does believe that the PLBP should be a chartered body, as the medical Royal colleges, the Royal Society of Chemistry, the Institute of Biology and the like.

The PLBP should have a membership considerably beyond GB- or UK-registered pharmacists, i.e. should welcome appropriately qualified non-pharmacists and persons from overseas. There should be different classes of membership.

Full membership of the PLBP should be reserved for persons holding qualifications equivalent to chartered status in other scientific and engineering disciplines, i.e. Honours degree and significant postgraduate training. Current pharmacists of course meet this description.

Other categories of membership than Member should comprise or include, Student, Associate and Fellow. Pharmacy technicians should in the main be Associate or Licentiate members but on holding or obtaining a relevant Honours degree and with postgraduate training would qualify as, or progress to, full membership. With this scope of membership, the PLBP will be able to look at and influence the breadth and continuum of pharmacy education and training, through to high levels of personal development and achievement.

Membership of all categories should be open to any person - in the UK or anywhere worldwide - studying or with evidenced expertise in the science or practice of pharmacy or in medicines research, development and usage. This will enable non-pharmacist pharmaceutical scientists, pharmacy academics and practitioners of pharmaceutical care from other health professions to become members.

CUHOP envisages a faculty structure of or within the PLBP. Such a structure could accommodate diverse expertise and interests in pharmacy and in the wider study of medicines and their usage. It would also facilitate the quality assurance of postgraduate programmes of education and training, without resort to a cumbersome and expensive system of accreditation of many different postgraduate programmes. Entry to a faculty should be by a portfolio of evidence from each applicant, most often including as a major element a postgraduate diploma or postgraduate Masters qualification (from anywhere in the World). An assessment-of-portfolio method of entry to faculties would allow recognition of diverse forms of excellence. The faculties could be the vehicle or focus of the meaningful continuing professional development (CPD) activities of PLBP members. There might be higher levels of membership within or mapping to the faculties, e.g. Fellowship, arising from CPD or relevant personal achievements.

A faculty structure sits well with the aspiration of the PLBP being recognised by others as a learned body.

The ruling committee or council of the PLBP should comprise exclusively or overwhelmingly persons elected by and from its membership, though with guaranteed representation from each of several faculties within the body and from the different classes of members mentioned above.

The ruling committee or council should be able to co-opt to itself a limited number of non-members of particular expertise, e.g. from the law or business or from other health professions, but there is no strong case for including purely lay members (whose welcome role is within the ruling committee or council of the regulatory body for pharmacy).

It is to be hoped that the PLBP will be able, at least over time, to subsume some number of the existing 188 or more organisations and interest bodies known to exist within pharmacy.

CUHOP might be willing to come under the 'umbrella' of the PLBP for pharmacy but, given the unique managerial responsibilities upon heads of university schools of pharmacy, only if CUHOP is able to retain an independent and potentially dissenting voice to the faculties and even to the ruling committee or council of the body.

As has been stated above, CUHOP would rather that membership of the PLBP is voluntary. If, however, membership is made compulsory for pharmacists and pharmacy technicians then the costs of membership should be benchmarked against similar bodies in the UK, e.g. the Association of British Dispensing Opticians. Clearly, to be successful the PLBP will have to provide valued and efficient services to its members.

A final suggestion we would make is that CUHOP should be represented on the ruling committee or council of both the proposed GPC and the PLBP, following on from the principle recently accepted and acted upon of having a place for a university head of school of pharmacy on the Council of the RPSGB, presently the 'top table' for regulation and professional leadership within pharmacy.

If any of the above is unclear or you or colleagues would welcome expansion on one or more points, please do not hesitate to contact me or the CUHOP secretary, Dr Robert Dewdney, at the Welsh School of Pharmacy, Cardiff University.

¹ Reserved tasks from the GPC to a PLBP might even constitute a restraint of trade.

20 March 2007

Appendix 1
Appendix 2

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