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Letters to the Editor
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Retention fees
Avoiding the retention fee
From Mr A. Matalia, MRPharmS
For locums and part-time pharmacists there may be a way to avoid paying
a retention fee to the Royal Pharmaceutical Society and undertaking continuing
professional development. They should attempt to register within the
European Economic Area on a full-time basis on a similar footing as a
pharmacist national. Once approved, they should resign their current
British registration and then ask for free registration under the EU
directive 2005/36/EC.
They may then work part-time or as a locum and, hey presto, no CPD to
do in the UK and no exorbitant Society fee to pay.
This begs the question: if an EEA pharmacist does not have to pay a fee
to work as a pharmacist in Britain, why should British pharmacists have
to pay? The only solution is that all pharmacists should be able to register
for free. Come on Mr Gush, surely this is fair.
A. Matalia
Coventry,
West Midlands
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MARTHA PAWLUCZYK, adjudication manager, education and preregistration,
at the Royal Pharmaceutical Society, responds: What Mr Matalia refers
to is EU Directive 2005/36/EC on the recognition of professional qualifications.
The Directive covers all professions not just health care.
There is a provision in this Directive that enables a European Economic Area
national who lives in another relevant European state and works as a pharmacist
there to move to the UK to provide the same pharmacy services that he provides
in his home country on a “temporary and occasional” basis.
The Directive does not define “temporary and occasional” because
it is not possible to provide a definition that can apply to all professions
in every country. It is for each profession in each country to provide advice
on this. This means that there may be different interpretations in different
countries for the same profession.
The following services for example could be regarded as temporary and occasional:
• A pharmacist who wishes to provide pharmacy services in another relevant European
state following a disaster or state of emergency
• A pharmacist who wishes to provide pharmacy services during an international
conference or sporting event in another relevant European state
The Directive requires the temporary and occasional nature of the provision
of services to be assessed case by case in relation to its “duration,
its frequency, its regularity and its continuity”. It is therefore
highly unlikely that regular part-time locum work would be regarded
as “temporary and occasional”.
In its response to the Department of Health’s consultation on legislation
implementing this Directive, the Society urged the DoH to extend the CPD requirements
to include temporary service providers. A press release regarding the Society’s
response
to this consultation can be found on the Society’s website.
The Society awaits the outcome of this consultation and the new legislation
amending the Pharmacists and Pharmacy Technicians Order, which we understand
is imminent.
No registration fee is payable by persons wishing to provide temporary services
because the service is of a temporary and occasional nature and the provider
pays the fees to his home regulator to maintain his practising status in that
country.
I can assure members that the Society is aware of the issue of temporary service
provision and in its response to the DoH consultation has urged that in the
interests of public and patient safety the regulatory system for temporary
service providers is not weakened. The issue of temporary service provision
will be monitored and matters raised with Government and the EU Commission
as appropriate. |
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