The Council of University Heads of Pharmacy proposes that pharmacy must be included in the list of exempt subjects. It appears anomalous that it was omitted from the original Student Fees (Qualifying Courses and Persons) (England) Regulations and Education (Student Support) Regulations).

• Pharmacy is a vocational healthcare profession and should be treated no differently from all other medical, dental and allied health professions.
• Pharmacists are on the UK Skills Shortage Occupations List.
• The shortage of pharmacists is recognised elsewhere - in a 2006 survey 6.5% of junior pharmacist posts in the NHS were vacant (www.nhspedc.nhs.uk/pdf/Report%202006.pdf).
• The 4-year undergraduate Master of Pharmacy degree qualification, followed by 1-year's pre-registration training, is the only route to registering with the regulator for pharmacy, the Royal Pharmaceutical Society of Great Britain.
• Greater than 95% of students reading for the MPharm qualification proceed to register and practise as pharmacists (Willis et al. Pharm J. 2006:277,137-138.)
• Workforce modelling commissioned by the Royal Pharmaceutical Society, in partnership with the Department of Health and the Welsh Assembly Government indicates that over the next 10 years pharmacist numbers will need to grow by 5% per annum. Even with greater efforts to increase retention and participation rates in employment a significant increase in the volume of the training pipeline is indicated.
• This increased demand for new pharmacy undergraduates combined with the 18 - 30 year old demographic profile between 2006/7 and 2026/27 means that demand for pharmacy undergraduates will exceed supply in the traditional recruitment pools. The inability of graduates to re-train as pharmacists will place a serious constraint on healthworker development across the NHS and run counter to the government's goal of getting patient care closer to patients.
• If workforce demand is to be met substantially by new graduates (in addition to retention and increasing participation rates) then pharmacy will need to look to non-traditional recruitment pools to meet employer-led demand - any barriers to for example graduates re-training as pharmacists will place a serious constraint on development of the pharmacy workforce and more generally across the NHS and run counter to the government's goal of getting patient care closer to patients.
• Students highlighted as ELQ in the schools of pharmacy have 'first' qualifications in the pharmaceutical area, but as stated above the MPharm is the only vocational qualification leading to registration as a pharmacist. First degrees in chemistry, medicinal or pharmaceutical chemistry, pharmacology or related biomedical science predominate.
• The current proposal makes extremely unlikely that a graduate entry route into pharmacy, which has been so successful in medicine, will be a meaningful option.

Consultation question 8: Do you have any further comments?

The ELQ proposals run completely counter to continuing professional development, life-long learning and skills development. It makes no sense (academic or otherwise) to bundle PG Certificates, Diplomas and Masters together as equivalent qualifications.

• Within the NHS, the Agenda for Change career framework is based on escalating post-graduate qualifications (the KSF - Knowledge and Skills Framework).
• Extensive use is made of PG Diploma and Masters qualifications in Pharmacy to support NHS workforce development and enable the delivery of important aspects of health policy.
• There is a clear academic progression route and practitioners should not be denied the opportunity build up their qualifications.
  The context here is the development of the pharmacists clinical role and specialisation as envisaged in Our Health, Our Care, Our Say and Our NHS, Our Future. It is strongly recommended that these planned professional programmes be exempted from the proposals to withdraw funding for ELQ. They are clearly different from a selection of unrelated programmes being chosen by students at random.

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