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Letters to the Editor
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The Society
Not living in the real world
From Mr S. J. Halliday, MRPharmS
In the real world where most of us live, a business that had so mismanaged
its finances that it faced a £6m deficit would not be in a position
to pass on the costs to its customers. Clearly the Royal Pharmaceutical
Society is not living in the real world but could someone explain what
options to cut costs have been explored, starting with the £1.6m
proposed increase in operating costs?
Simon Halliday
Bolton,Lancashire
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ANDREW GUSH, Treasurer of the Royal Pharmaceutical
Society, responds:
Cost savings are always being sought, but the
requirement
to satisfy our regulatory responsibilities while also trying to
satisfy our ambitions to provide leadership and support for the
profession limits our ability to reduce costs.
The Society undertakes
a rigorous budget process every year. The process involves budget
holders, directors and the chairmen of the statutory committees
who discuss budgets in detail, line by line, before they are submitted
to the Resource Management Committee and then recommended to the
Society’s Council for their approval.
During the budget process, cost-saving initiatives are considered
and in fact a budgeted efficiency saving is agreed and implemented
into each all-departmental
budget. In addition, wherever possible, projects are delayed or cancelled in
order to arrive at the final approved budget. For the 2007 budget, some difficult
decisions were taken by the Executive and Council to delay or cease projects.
Unfortunately, in 2008 and beyond, we are seeing the full year impact of the
implementation of the legislative changes.
We are fully committed to delivering benefits to our members as well as providing
robust, fair and transparent regulation. To continue to do this we are prepared
to make difficult decisions based on the current financial situation — which
results from external factors out of the Society’s control — and
to plan ahead with prudence for the changes to come.
The consultation on fees
has closed and we are now waiting for the results from the independent analyst.
I ask that members continue to be patient until a decision is announced on
1 November 2007. |
Protecting the public should not endanger registrants
From Mr G. Southall-Edwards, MRPharmS, Barrister
Jeremy Holmes,
Chief Executive and Registrar, states that the Royal Pharmaceutical Society
has a duty to refer questions of fitness to practise
to the Investigating Committee (PJ, 6 October 2007, p383).
This
may be correct, but what is lacking at the Society is effective and sensible
decision
making, with the result that risk-averse employees of the Society are
referring everything to this committee, instead of realising when referral
is pointless and sending only worthy cases forward. Even when referral
is necessary, the way in which it presently takes place is truly shocking
in its psychological effect on registrants.
By way of example, some cases I have dealt with have been referred to
the Investigating Committee when even the Society’s own investigation
has concluded that the member is fit to practise; in addition, cases
involving allegations which lack any substantive supporting evidence
are often referred, only to be later thrown out with “no further
action”, as too are trivial matters such as an allegation by a
patient that a pharmacist was heard laughing in a dispensary.
The anxiety caused to the (often young) pharmacist recipients of these “bundles” is
possibly far greater than even I suggested in my recent Broad
Spectrum article (PJ, 25 August 2007, p204). I know of two
pharmacists who have each made two determined attempts to commit suicide
after they
became
involved
in fitness-to-practise proceedings. In addition, there are three more
pharmacists, about whom both I and the Pharmacists Defence Association
have serious concerns.
Recently, I was asked: “What if I leave the country, or resign
from the Register? Will it end then?” My answer was that the inquiry
would proceed in a pharmacist’s absence if he or she left the country
and that the Society had recently refused to remove various registrants
from the Register simply because they were under investigation. On hearing
this reply, the next question was: “What if I kill myself? Will
that end it?”
I have no doubt at all that the person asking that question did not intend
it as a joke, but saw it as the only way out of a situation that he could
not deal with. Sooner or later, a pharmacist who is under investigation
is going to take his or her own life as a result of the sheer anxiety
about that investigation process. I go on record here as saying that
I believe that it is just a question of time.
Protecting the health and safety of the public may be one duty of the
Society, but there are other ways in which it can be done without causing
this level of anguish and danger to registrants. What about protecting
the health and safety of members of the Society? Does the Society not
also owe them a duty of care? Graham Southall-Edwards
EPLS/Pharmacists’ Defence Association
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JEREMY HOLMES, Chief Executive and Registrar, Royal
Pharmaceutical Society, responds:
The Society welcomes the continuing
debate on regulatory
developments and the opportunity presented by responding to the letter
from Mr Southall-Edwards. It will be well known to readers that protecting
the public is the main objective of the regulatory function of the
Society. Article 4 of the Pharmacists and Pharmacy Technicians Order
2007 sets
this out in very clear terms.
We sympathise with the fact that fitness-to-practise proceedings can
be stressful for those undergoing them. However, the Society works
within a robust legislative
framework which includes detailed referral criteria for the Investigating Committee
and legal guidance which assists in the decision-making process to ensure fairness
and rigour.
Cases are handled in a consistent and transparent manner and in
accordance with predefined procedures; it is not risk-averse employees,
but the Registrar
who refers cases to the Investigating Committee. It is the role of the Investigating
Committee to decide when no further action is appropriate in a case and this
does not necessarily mean there was insufficient evidence, but will depend
on the circumstances of the particular case.
Many of the cases handled by the Society are recommendation cases.
This means that the Notices of Referral to the Investigating Committee
sent to registrants
contain a recommended course of action for the case. This can range from
a recommendation to dismiss the case to an advisory or a warning
letter. Under
Article 9 of the
Royal Pharmaceutical Society of Great Britain (Fitness to Practise and Disqualification
etc) Rules 2007, the Society’s Council can publish threshold criteria
for allegations of a type that should not be referred to the Investigating
Committee.
The Council has already taken the opportunity earlier this year
to consider the
appropriate threshold criteria for single dispensing errors. Since that
time a number of single dispensing errors have been dealt with via the
Society’s
inspectorate without referral to the Investigating Committee. Additional
criteria will be considered by the Council in the next few months and will
be the subject
of consultation. The need to balance the risks of adopting such an approach
with the Society’s duty to protect the public has to be carefully considered.
There are some very sad circumstances that come to the attention of the
Society through our health cases. Apart from the necessary fitness-to-practise
procedures
there is a comprehensive range of benevolent services, help and support
to assist pharmacists in these distressing situations. Every effort is
made
to discharge
our regulatory responsibilities in a proportionate, fair and transparent
way. We do not want to cause distress; we want to protect the public.
The Society is here for its members and I would encourage those in need
of further advice or support to contact the Benevolent Fund, Listening
Friends
or Pharmacists
Health Support Programme, details of which are available via the Society’s
website |
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The
Pharmaceutical Journal