My submission to the Health and Social Care Committee’s Pharmacy Inquiry (as amended from my original submission in July; the committee invited me to submit a version with a reduced word count).



Thread 🧵committees.parliament.uk/writtenevidenc… Some excerpts (with minor amendments) from my original submission:

The term “pharmacy” is often used, incorrectly, interchangeably with “pharmacists”. To illustrate, a parliamentarian recently referred to community pharmacy closures, and in that context asked whether the government had got the contract with “pharmacists” right.

Pharmacies are the businesses, or premises; pharmacists are the healthcare professionals.
In England, the government contracts nationally (pursuant to s.165(1)(a) of the National Health Service Act 2006) in consultation with community pharmacy businesses, not pharmacists, and pharmacists as a profession have no say in that national commissioning process for community pharmacy. It is by no means uncommon for people to confuse or switch between the words “pharmacy” and “pharmacists”, including for political purposes.

Privatisation in pharmacy, as a field of practice in healthcare, is highly advanced, at least arguably moreso than in any other area of healthcare. There are parallels in the field of optometry, but some of the largest pharmacy businesses have connected businesses involved in the wholesaling and manufacturing of medicines, so their political influence, influence on the NHS, and profile, is far greater than that of their optical counterparts.

The Health and Social Care Committee (“the Committee”) may receive submissions to the inquiry from the organisations described below in the “Pharmacy Organisations and Bodies” section of this submission. If it is claimed, or it appears, that they represent (for example) “pharmacy” or “community pharmacy”, it is crucial to understand whose interests they represent in fact.

Many who interact with “pharmacy representatives” will, though they may not realise it, not have interacted with the profession or its representatives. The profession of pharmacists often struggles to have its voice heard - and it is, instead, drowned out by the voices of pharmacy businesses.

—

The interests of pharmacists and pharmacy business owners may conflict in certain respects. By way of example, the Company Chemists’ Association and Community Pharmacy England, which represent pharmacy business owners, have each called on the NHS to stop recruiting pharmacists into the Additional Roles Reimbursement Scheme (“ARRS”). This could potentially be contrary to the interests of pharmacists, and, at least arguably, the interests of the public. The apparent basis of the request (the alleged insufficiency of the availability of pharmacists) was not supported by the citation of evidence, if any such evidence exists, and the pharmacy media seemingly did not insist on any such evidence being provided, or comment on the lack of it. It should be borne in mind that it is in the interests of pharmacy owners to have more pharmacists available, so that there is increased competition for jobs, remuneration therefor can be reduced, costs are lowered, and profits are increased.

A pharmacy business owner will want to run his business at the greatest possible profit, which means making his costs as low and revenues as high as possible, whilst seeking to avoid reputational harm. A pharmacist will want to be paid the best possible salary, to practice within regulatory parameters so that his career is not put in jeopardy, and to work in conditions conducive to that end and to his own wellbeing. It is also to be hoped - through professional training and by virtue of his career choice - that he will want his profession to develop, and to use his skills to deliver safe and effective care to patients. If he fails to meet regulatory requirements, he may face regulatory sanctions - but the same cannot presently be said of pharmacy businesses/premises. This issue is explored in more detail below under the heading “Regulation”.

The "Supervision in Community Pharmacy" report, produced without any input from the profession itself, and seemingly without legal advice, is another discreditable chapter in the history of pharmacy supervision.



Thread 🧵/rpharms.com/Portals/0/RPS%… Where was the draft report, for comment? Where was the communication, transparency, or collaboration and discussion with the profession, whilst the group’s activities were going on? What did group members do to seek the views of, and represent, their own membership cohorts? Where is the analysis of the patient safety risk, the effect on costs and public confidence in pharmacy, and the impact on pharmacists’ pay and the availability of jobs?

2/

Some of the issues with "foregone clinical checks" – where a clinical check is done on a prescription supply then no check is completed for any number of subsequent supplies occurring within a defined period - have not yet been highlighted by #pharmacy bodies.

Thread 🧵/ Pharmacists considering raising concerns to the superintendent (“SI”) about foregone clinical checks should remember that the SI has already signed off on the procedure.

2/

My experience of submitting a subject access request (“SAR”) to the Royal Pharmaceutical Society @rpharms.

Thread 🧵 The RPS’s initial response was to provide a spreadsheet listing over 2,000 internal emails/documents it held mentioning me, from which I selected 397 for disclosure. Some emails had interesting subject lines - see for example the image below.

2/

Part 2.

Pharmacists might sometimes feel isolated and alone, and wonder whether their concerns are shared by others. Often though, people will contact the PDA about the same issues, independently.

21/

https://twitter.com/thisislawton/status/1614320986320703489

How many “unmanageable workplaces” are there at Boots?
Again, is there a company list?

How many company proposals to address workload would only be suitable for a “novice”?

How often is there an “incomplete understanding” of the issues people are facing, from management?

22/

Comments on the Wayt & McPherson v Boots employment tribunal case. It reveals some of the internal culture at Boots.

Two Area Managers ("AMs") successfully claimed unfair dismissal, after a restructure made their workload unmanageable.

assets.publishing.service.gov.uk/media/62f673e7…

Thread/ The AMs made no complaint about routinely working overtime: 60 hours per week over 6-7 days, whilst contracted for 37.5 hours over 5 days.

How many AMs propagate that culture? How many expect routine overtime from pharmacy staff? What happens if the pharmacy staff complain?

2/

There appears to be some further misinformation circulating regarding “pharmacist shortages”. This “Locum Rates Study” was prepared for Employers by Locate a Locum.

workforce.locatealocum.com/hubfs/Pharmacy…

#pharmacy

1/ The document states:

“Another notable change in the pharmacist market is the movement of community pharmacists to Primary Care Networks. In May 2022, Pulse reported that 16,780 *pharmacists* had been hired with support from the Additional Roles Reimbursement Scheme (ARRS).”

2/

RPS:
“The evidence from our 2021 Workforce Wellbeing survey shows that the pressures on the pharmacy workforce continues to negatively impact on mental health and wellbeing…”

1/

rpharms.com/recognition/al… From the survey - the top factors for poor mental health and wellbeing:
70% - inadequate staffing
64% - long work hours and lack of work/life balance
53% - lack of protected learning time
52% - lack of colleague or senior support

2/

20,924 reported #pharmacy closures in a year. Most common reported reason: “locum could not be found”.
Was the locum hiding somewhere, in a bizarre game of hide and seek?
Or couldn’t they find a locum *willing to work in the conditions on offer*?
Did they try to find a locum?

1/

https://twitter.com/ChemistDruggist/status/1591161342152814593

In no cases was the reported reason “it would have cost more for a locum in a free market than we wanted to pay” or “unable to find a pharmacist willing to work in the conditions in the pharmacy”. The reported reasons don’t tell the whole story.

2/

RPS representation of pharmacy technicians would mean it couldn’t properly represent either pharmacists or pharmacy technicians.

1/

https://twitter.com/rpharms/status/1577599989139873792

The change would pave the way for a pharmacist-only professional leadership body which doesn’t have the issue of trying to represent two distinct groups, whose interests will often conflict and compete.

2/

PSNC distances community pharmacy from the NHS

“…the NHS tactic of poaching community pharmacy staff to work in general practices is absurd and having very damaging consequences for community pharmacies."

1/

https://twitter.com/telegraph/status/1577110855686279168

“Poaching” suggests it is done in a clandestine manner, ignoring the fact that staff will be actively applying and engaging with recruitment processes for other roles

2/

New internal Lloydspharmacy documents reveal how it manages the GPhC, and how the GPhC allows itself to be managed.

Thread /🧵 The documents say that the GPhC will continue to “support pharmacy” (as opposed to regulating it?) and “seek assurances” about how the pharmacy *is continuing to meet* the standards (as opposed to determining impartially *whether or not* its standards have been met).

2/

From the House of Lords Motion to Regret the Pharmacy (Responsible Pharmacists, Superintendent Pharmacists etc.) Order 2022 (28 June 2022)

1/

hansard.parliament.uk/Lords/2022-06-… One peer argued as per the image in this tweet.

The irony being that they’re discussing the outcome of a *consultation* in which the responses opposing the new regulatory powers were set aside, then saying don’t worry, any changes will be *consulted* on.

2/

GPhC to acquire new duty to have regard to the principle of *minimising* the burdens on the businesses it is meant to regulate, when deciding rules for when pharmacists are responsible, and RP absence. #pharmacy

legislation.gov.uk/ukdsi/2022/978…

1/ If an “expected benefit” is reduced labour costs, then the *minimum* burden on businesses to secure it could be “you don’t need a responsible pharmacist at all”.

2/

I think it's important to focus on preventing pharmacists being put in that position.

Thread/

https://twitter.com/Gurinder_Singh1/status/1500555470624407555

Mere “say no” campaigns, for example, place the responsibility solely on the pharmacist to say *no* to those who put them in that position in the first place.

2/

RPS membership numbers vs. GPhC-registered pharmacists, since 2011. GPhC registrations are based on public data. RPS numbers may be estimates, and for some years the data has been interpolated from that which is publicly available.

1/ RPS membership numbers - sources:
chemistanddruggist.co.uk/news/rps-membe… (2011+2012)

pharmaceutical-journal.com/article/news/r… (2014 + 2015)

2/

It appears that there’s a critical “error” in @CCApharmacy’s calculations, and that it draws attention to evidence which, far from showing a shortage of pharmacists, suggests a surplus. @Telegraph @ChemistDruggist @lizrob92
@NHS_HealthEdEng @DHSCgovuk @APPGPharmacy

Thread/

https://twitter.com/CCApharmacy/status/1491362395754668033

If that’s the case, in the interests of integrity, those who quoted the CCA’s claims ought to correct the record. The integrity of the numbers is important. The CCA said itself, “We are concerned that important policy decisions may be based on inaccurate data.”

2/

The latest MEP (Ed 44) has a section on "workplace stress", advising that pressure and anxiety are “part of normal life”. It recommends daily “worry time”, where pharmacists proactively worry in advance of whatever causes it. If that’s not normalising it, I’m not sure what is. 1/

https://twitter.com/rpharms/status/1481295027783585805

It isn’t just the content of the MEP that concerns me, though. Looking around I see materials on such matters from other organisations recommending, for example, breathing exercises, “worry o’clock”, and yoga, as solutions to workplace pressure. 2/

A rundown of some of the arguments advanced for dropping the pre-reg exam.

In no particular order.

Thread / 1. In employment law, you’re a pharmacist if you’ve worked as one.

A: In employment law, if you’ve had certain arrangements for a period of time, you can acquire the status of 'employee' or 'worker'. It doesn’t change your profession, and has nothing to do with regulation.

Remember the surprise #pharmacist #apprenticeship proposal? An FOI request was submitted to the IfATE to find out a few things.

Thread/ The IfATE confirmed that the RPS was aware of the proposal and an individual it employed was party to exploratory discussions (though it should not be assumed that the person was acting as a representative of the employer).