Retention fees

Many members of the Royal Pharmaceutical Society are complaining about the proposed increase in their retention fees. However, as yet, no one seems to have commented on the increase for preregistration trainee pharmacists (PJ, 4 August, p129).

As a current trainee I think that the increase in the training fee from £153 to £230 is also a disgrace. Is this increase just to combat the poor financial management of the pension fund?

The cost of the examination has increased from £180 to £270. Does this mean that the examination is going to be printed on more expensive paper, or is this just another way that the Society can combat its mistakes by penalising poor students? Not to mention the hike in the examination late entry fee to £540. May I ask for some justification for this increase?

I can understand that the splitting of the Society has led to financial instability, but I would like to ask the Society what further support it is going to offer preregistration trainees? Will future trainees be offered more than a folder?

With the recent government changes in tuition fees, students are leaving university with even more debt and being faced with even higher costs before they have even started their jobs as preregistration trainees.

It was suggested in the past that this fee be paid after students have started their preregistration year. Is this a feasible opportunity, or is this still something that the Society is choosing to ignore from its student members?

In my opinion, penalising students will not help the future of the profession. I would like the Society to address these issues to help ensure the future of a profession that I care about.

James Davies
Preregistration Trainee Pharmacist
Guy’s and St Thomas’ Hospital,
London

ANDREW GUSH, Treasurer of the Royal Pharmaceutical Society, responds:

Mr Davies’s views will be analysed along with the formal responses to the fee increase consultation document and considered by the Council of the Society in October 2007.

The fees consultation asks about the overall approach to fee setting — responses relating to the overall balance of the increase between the different fee categories would be welcome in response to Question 6.

We welcome input and responses from the preregistration trainees and their tutors in general but particularly if the input covers issues specific to the proposed preregistration fees.

What improvements can we expect?

From Mr M. Patel, MRPharmS, and Mr L. David, MRPharmS

With reference to the proposed large increase in Royal Pharmaceutical Society retention fees, the Society’s Council has said it is for the benefit for members. Will the Society let members know what improvements or benefits it proposes?

Also what time scale is it working on for these benefits, if any? If members of the Council are unable to provide such information, we suggest that members should pay last year’s retention fee plus 10 per cent to cover inflation, etc.

It would be interesting to know which members voted for the increase in fees and how many of the Save Our Society members voted in favour.

For information, it would be pointless calling a special general meeting (PJ, 1 September, p220) as the Secretary and Registrar has in the past stated that the outcome of such a meeting is not binding on the Council.

Milen Patel
Northwood, Middlesex
Leo David
Hounslow, Middlesex

ANDREW GUSH, Treasurer of the Royal Pharmaceutical Society, responds:

As Mike Beaman wrote recently (PJ, 15 September, p292), it would be helpful to us if members could consider the content of the consultation paper and respond to it by the deadline of 3 October 2007.

The consultation document on our website makes clear that the increase in fees is largely due to a range of external factors and is necessary as the Society seeks to repair its finances and put itself on a sustainable financial footing for the challenging years ahead.

Again, as the consultation document says, the Resource Management Committee was looking at financial projections for the next three years. I will summarise the background since it is helpful to have this opportunity to restate the case for the proposed increase.

Despite expected increases in the costs of regulation as the Pharmacists and Pharmacists Technicians Order (the Order) was implemented, the Council, mindful of the burden on members, decided to restrict the level of fee increases in 2006 and 2007 and, as a result, incurred deficits in both those years.

This, together with an exceptional contribution of £1.9m to help address the pension deficit in 2006, had a significant negative impact on our reserves.

Based on our draft budgets for 2008, the proposed fee increase will enable the Society’s reserves to return to the level they were at at the end of 2004, although that itself was at a historically low level of £5.8m.

The implementation of the Order continues to involve additional operating costs, but we are seeking efficiencies wherever possible and the actual increase in our operating expenditure for 2008, over 2007, is a relatively modest 7.8 per cent (£1.6m).

Apart from the effects of inflation, the single largest increase is expected to arise from the costs of implementing the new continuing professional development and education rules arising from the Order.

Our education and practice activities remain a cornerstone of the Society’s work and are of real value to our members. Continued investment in these areas is vital.

In addition, there has been a change in the tax regulations which exposes us to up to an additional £1m per annum. This tax charge arises from our publishing activities whose surpluses are used to support our general operating costs and thus relieve the burden on membership fees.

We believe it is essential that the Society has a stable financial platform as we move towards the separation of our regulatory and professional leadership activity.

The £3m funding recently announced by health minister Ben Bradshaw will be under the control of the Pharmacy Regulation and Leadership Oversight Group, led by the Department of Health, and is specifically ring-fenced for the transition process.

The additional £6m generated from the Society’s fee increases will be used to repair our reserves and fund current activity as follows:

• Pension Fund — £1.9m
• Prior year deficits — £1.6m
• Increased operating costs — £1.6m
• Increased tax charge — £0.9m
• Total — £6.0m

As I have said before, we have to anticipate and plan ahead to give the Society the financial stability and viability for the next few years. They are not easy decisions, but they are necessary and considered.

Please be aware that increased financial burden placed upon members by these proposals is appreciated and that it is never pleasant to have to deliver such unwelcome and unavoidable news.

Persona non grata

From Mr M. W. Jackson, MRPharmS

Andrew Gush, Treasurer of the Royal Pharmaceutical Society, advises that due to EU legislation concessions, an age discrimination in relation to reduced subscriptions cannot be made to members who have served the community for a period of 50 years (PJ, 8 September, p256).

If this is the case, why is my local golf club able to make a similar reduction to its members, regarded as seniors, who have reached the age of 65? Why do certain organisations and societies always have to follow the dictates of the EU? France and Spain are much more selective in the rules they implement.

If there is going to be no future concessions for the old boys (and girls) in relation to age and years of service, many of my friends and acquaintances will, at the end of the year, declare themselves persona non grata in relation to pharmacy.

Have the President and Council, who appear to have lost direction completely, considered the impact of this unwelcome fee increase on the future manpower of community pharmacy?

I recall reading that the Society wishes to become more customer-focused and improve its face with its members so they would join even if membership were voluntary — some hope! If this is to be the case, they should start taking lessons from the National Pharmacy Association, which is at the present time introducing to free newspapers a half-page advertisement on the value of one’s local pharmacist in relation to training and the advice on medicines — this is excellent.

Maurice Jackson
Brent Knoll, Somerset

I hope answers can be found for the retired

From Mr H. W. T. Layer, MRPharmS

I echo the letters of Bill Brookes (PJ, 18 August, p178) and Rodger Baker (PJ, 8 September, p257). The huge increase in fees proposed by the Council of the Royal Pharmaceutical Society shocked me.

In particular, the fee for retired members would mean that I would resign if it were implemented. After 63 years on the Register and my interest in the profession still undiminished this would be a sad end to my membership.

The Treasurer, Andrew Gush (PJ, 8 September, p256) states that a reduced fee would run foul of European legislation, but surely this is not about age, but the length of time on the Register? I hope Lambeth can find a suitable answer to the problem.

Henry Layer
Brentwood, Essex

Perception that Society is grabbing what money it can

From Mr P. J. Francis, MRPharmS

I gather that within a short period, the Royal Pharmaceutical Society will lose its right to administer the Register of pharmacists. Therefore pharmacists will no longer have to be members of the Society, in order to practise legally in Britain.

The hike in retention fees, to pay for a pension shortfall among Society staff, appears therefore to smack of opportunism. It is as if the Society is acknowledging that few members will want to pay its retention fee, once that no longer confers the legal right to practise pharmacy in Britain.

Therefore the Society appears to be grabbing what money it can while pharmacists still have to pay whatever it demands in order to practise. I could be wrong, but appearances can matter.

Paul Francis
Brisbane, Australia

ANDREW GUSH, Treasurer of the Royal Pharmaceutical Society, responds:

The White Paper proposals to establish a new regulatory and professional body for pharmacy have been well reported in the pages of the pharmacy press.

However, the Council’s proposals to raise registration fees are not an act of opportunism; rather they are a necessary requirement to help ensure that pharmacy is in a position to shape its own future.

The Society has outlined the full reasons behind the fees decision in a comprehensive Q&A on its website. There is also an ongoing consultation which I would encourage members to engage with.

How do other concessions differ?

From Dr I. H. Stockley, FRPharmS

Andrew Gush says (PJ, 8 September, p256) that concessions, such as life membership of the Royal Pharmaceutical Society for those over 90 years, and nominal fees for those on the Register for over 50 years, would fall foul of the Age Discrimination Act 2006.

How then would these concessions differ from those which I get because I am over 60, such as a free bus pass, cheaper rail tickets with a senior rail card, and reduced entrance charges for museums, exhibitions and entertainments? Even a cheaper hair-cut!

Ivan Stockley
Loughborough, Leicestershire

ANDREW GUSH, Treasurer of the Royal Pharmaceutical Society, responds:

These members are important and their loyalty and contribution to the Society must be recognised so we are indeed searching for a solution to this difficult problem. I am therefore pleased that the question of concessionary fees has been asked again as it is important that members of the Society are informed of recent legislative developments.

The recent Equality Act 2006 (the Act) sets out a new legislative framework to protect human rights, to limit prejudice and discrimination and to promote equal opportunity. The Act sets out a statutory duty for public authorities, including those having a function of a public nature, to uphold the principles of the Act.

It is questionable whether nominal fees and concessionary rates would be seen to be in contravention of this duty, as with most of these issues, it is not just about the letter of the law, it is about the spirit of the law. In due course some of the examples of concessions quoted in the letter may be tested and rulings given about their compatibility with these requirements.

Previous advice from the Privy Council has also suggested that in specifying an “over 50 years” rate there could be potential discrimination against women pharmacists (who may be less likely to have maintained their registration over a 50-year period, particularly if they have taken a career break to have a family) and against pharmacists who have been registered in another EEA state, as the time spent practising there would not count towards the 50 years.

What might initially be seen as an attractive way forward does raise some fundamental issues which, rightly, should be subject to further debate. Again, I assure members that we are determined to find a solution that will allow the Society to recognise these important members.

Discount due on 50 per cent increase

From Mr W. Y. Tang, MRPharmS

In the Royal Pharmaceutical Society’s consultation on fees, one of the reasons behind the unprecendented 50 per cent increase in fees is attributed to the “costs of the Government plan to demerge the Society into a new regulatory body and a professional body”.

In light of a recent Government pledge by the health minister Ben Bradshaw to provide £3m towards funding this, can we have an assurance from the Society’s Treasurer that the 50 per cent increase will be decreased by the appropriate amount?

It should be noted that the report “Economic analysis of pharmacist regulation” estimated that costs of the separation would be £3.2m indicating that near enough the total budgeted amount contributing to the 50 per cent increase should be removed from proposed increase.

Wing Tang
London

ANDREW GUSH, Treasurer of the Royal Pharmaceutical Society, responds:

The health minister has made it clear that the £3m earmarked will be under the control of the Professional Regulation and Leadership Oversight Group and, as such, will be directed entirely towards the establishment of the General Pharmaceutical Council.

These funds will not be used to underwrite any transitional costs for the professional body over the next few years.

Mr Tang has unfortunately misread the NERA report “Economic analysis of pharmacist regulation”. The analysis identified the ongoing additional annual costs of running a regulator and a professional leadership body as distinct from our current arrangements as being in the order of £3.2m at 2006 prices.

This was the lowest of a range of costs identified on the assumption that the regulator and the professional body would rely on certain shared services and perhaps even occupy the same building. The NERA report acknowledged there would be transition costs but did not attempt to estimate these costs.

The Society has not budgeted for any set-up costs of either the GPhC or the professional body at this time; however, the Society is fully committed to continue lobbying strongly to ensure these costs are funded by the Government.

Be assured we are determined. We want a fair outcome for all our members.

Dread and foreboding

From Mr A. H. Madge, MRPharmS

It was 33 years ago when I joined the Royal Pharmaceutical Society’s Register and I recall a letter in The Journal about that time from a member who was then retiring.

The member stated sentiments to the effect that in his entire working career the Society had to his mind been a complete and utter unproductive waste of time and effort.

I am now reaching the twilight era of my own career I heartily agree with this viewpoint.

The current increase in fees leaves the Society in great danger of resembling a bunch of comic book bureaucrats running a protection racket, in other words “you pay our pension or we stop you working”.

The sooner the Society is abolished the better. The thought of the Society with its current track record, converting itself into some sort of college fills me with dread and foreboding.

The only time in the past three decades I can ever remember any organisation seeming to be of any serious value to the profession and the public was the National Pharmaceutical Association under the leadership of the late Tim Astill.

However, looking forward and onward it seems there is a small glimmer of hope with the Pharmacists Defence Association. It lives in the real world with the rest of the fee-paying membership.

Alan Madge
Worthing, West Sussex

Foreign pharmacists should pay lower fees

From Mr O. Picard, MRPharmS

I qualified as a pharmacist in France in 1999 and have worked in the UK ever since.

I was contacted a few weeks ago by a Royal Pharmaceutical Society inspector who warned me that if I was caught working as the sole pharmacist in charge, on any pharmacy premises which had been registered as a pharmacy for less than three years, I would face disciplinary action by the Society.

This means I cannot work in any pharmacy that is a new business (including new 100-hour pharmacies or internet-based pharmacies) or an existing business, which has relocated premises with the past three years.

Apparently it has been the law since the 1960s, yet no one seems to know about it. This restriction applies to all European-qualified pharmacists who work in the UK.

Until the Society inspector contacted me, I was completely unaware that such a law existed, despite working for many years for several large pharmacy multiples that frequently required me work at new premises, thereby asking me to break the law each time.

Now that I have been made aware of the rule by the Society, I cannot work in any new pharmacy. This severely limits my ability to make a living as a pharmacist in this country.

So why then, if EU pharmacists are not afforded the same rights as British-qualified pharmacists, should we pay the same membership fee?

Olivier Picard
High Wycombe, Buckinghamshire

JEREMY HOLMES, Chief Executive and Registrar at the Royal Pharmaceutical Society, responds:

The Society has received a number of letters and calls about pharmacists who have registered with the Society with a qualification in pharmacy, awarded in a European state, not being able to be in personal control of premises registered for less than three years. All EU-qualified pharmacists are informed of these restrictions when applying to join the Register.

With the introduction of the Pharmacists and Pharmacy Technicians Order 2007, the Medicines Act 1968 (the Act) now states that the personal control which meets the conditions relating to premises which have been registered pharmacies for less than three years cannot be fulfilled by persons who are “pharmacists by virtue of a qualification in pharmacy awarded in a relevant European state”.

This had the effect of amending the previous wording of the Act, but has not affected the meaning of the paragraph, which is still as reflected in the Law and Ethics Bulletin issued in The Pharmaceutical Journal of 2 December 2006 (p675), entitled “Restrictions on personal control”, which reminded pharmacists of this requirement.

Changes to the current requirements would require a change in primary legislation.

It is the responsibility of all pharmacists practising in the UK to ensure that they are familiar with all relevant legislation relating to pharmacy practice. This obligation is set out in Paragraph 6.6 of the Code of Ethics which came into force on 1 August 2007.

The Society aims to remind pharmacists of relevant legislation and good practice through Law and Ethics Bulletins, such as the one described above. In addition, one of the important roles of the inspectorate is to enhance awareness and understanding of the Code of Ethics and legislative requirements and on this occasion this has worked.

Rule 4(1) of the Royal Pharmaceutical Society of Great Britain (Fees in Connection with Registration) Rules 2007 defines only one practising fee for pharmacists wishing to be retained on the Register of Pharmacists to practise in the UK.

The Society cannot discriminate by setting differential fees between pharmacists according to their place of qualification.

Ratio of salary to registration fee

From Mr M. J. Shucksmith, MRPharmS

My salary on qualifying many years ago was £950 per annum — a reasonable start in those days. This was some 180 times the registration fee of five guineas (£5.25).

If this ratio were applied to the proposed £425 fee, a newly qualified pharmacist would require an initial salary in excess of £75,000 per annum. That puts into perspective the outrageous increase being proposed.

M. J. Shucksmith
Fordingbridge, Hampshire

Does anyone remember those 2 per cent increases?

From Mr K. J. Baxter, MRPharmS

While reading one of the two PJs that appear on my doorstep each week and debating intensely the issue of Royal Pharmaceutical Society fees with my wife, I found that the historical fees charged were of benefit in our debate:

1993, £112	2000, £138
1994, £115	2001,£142
1995, £117	2002, £186
1996, £120	2003, £195
1997, £125	2004, £205
1998, £129	2005, £256
1999, £134	2006, £267
	2007, £283

Does anyone remember those 2 per cent increases we enjoyed in the past? We currently reckon that for 2009 we must both put aside £1,100. Does anyone think it will be higher?

We just cannot work out which inflationary measures the leaders in their ivory towers on the south bank of the Thames will dream up for next year and the excuses made to justify this appalling state of affairs.

Keith Baxter
Worcester

How can we be responsible for liabilities?

From Mr U. A. Patel, MRPharmS

We have been advised that the assets of the Royal Pharmaceutical Society do not belong to the members. In that case, we cannot be responsible for its liabilities.

U. A. Patel
Northwood, Middlesex

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