Health CommitteeWritten evidence from the General Pharmaceutical Council (ETWP 55)

1. Executive summary

Key themes in this submission:

1.1 The importance of the regulatory role in delivering high quality, contemporary healthcare.

1.2 The critical, statutory role of health professions regulators in setting educational and training standards and accrediting and appraising provision.

1.3 The importance of non-NHS education, training and healthcare.

1.4 The need for a balance between local, regional and national healthcare priorities in education and training.

1.5 The importance of effective structures for integrated, multi-disciplinary, postgraduate education and training.

1.6 Clarity on the roles and responsibilities of new bodies such as HEE and LETBs and how they will work with other stakeholders, including statutory professional regulators.

2. Introduction

2.1 The General Pharmaceutical Council (GPhC) is the statutory regulator for pharmacists, pharmacy technicians and registered pharmacy premises in Great Britain.

2.2 The principal purpose of the GPhC is to protect patients and the public. In part it does this by setting standards for education and training for pharmacists and pharmacy technicians, setting standards for contemporary practice, and ensuring pharmacy professions remain current in their practice through continuing professional development. In time, the GPhC will introduce a system for revalidation or continuing fitness to practise. A key theme in the education and training work of the GPhC is empowering professionals to develop and maintain their own practice and sense of professionalism.

2.3 The GPhC ensures that education and training standards are being maintained across Great Britain through a periodic professional and academic review process—accreditation—which supports providers in developing their education and training.

2.4 In addition the GPhC runs a national registration assessment. Passing the assessment is a requirement for initial registration.

2.5 We are pleased to be given the opportunity to submit evidence to the Select Committee. We have restricted our comments to regulatory matters.

3. The proposed role, structure, governance and status of Healthcare Education England...and its relationship to professional regulators and to the other parts of the new NHS system architecture

3.1 We are encouraged that the Committee intends to examine the role of HEE and have identified its relationship with professional regulators as being an important one. Our concern was that the regulatory role was significantly underplayed in Liberating the NHS: developing the healthcare workforce and did not recognise the important work regulators do with the professions and professionals they regulate. In the new system, HEE will have, clearly, a major role but it is not clear to us how that role will complement and work with the existing, statutory role of regulators.

3.2 Understanding the relationship between regulators and HEE is key. In particular, how will regulators be linked to HEE and its decision making? Will regulators advise HEE formally or will they be part of a looser advisory or consultative structure? We would request that clarity on the relationship is forthcoming at the earliest opportunity. It is difficult for us to be more specific about the nature of our concern given the current lack of detail about HEE’s relationships with other stakeholders. Whatever the envisaged relationship is, we hope that once the relationship is agreed, HEE will engage meaningfully with regulators on a regular basis.

3.3 We are concerned that the regulators have been grouped with “professional bodies” in illustrations of possible HEE advisory machinery when they are independent statutory organisations primarily concerned with patient and public safety.

4. How professional regulators, healthcare providers and commissioners, universities and other education providers, and researchers will all participate in the formulation and development of curricula

4.1 The independent statutory regulators exercise the vital role of protecting the public partly by setting and upholding the standards of education and training for entering and remaining within the health professions. The statutory regulators have long understood that they must take account of the needs and concerns of a wide range of stakeholders and partners when setting standards, including those who commission, fund and provide professional education and training. However, if the potential for conflict and confusion in the future is to be avoided, the precise relationship between regulators and other stakeholders in setting standards and curricula must be clarified in the new system architecture.

5. The role and content of the proposed National Education and Training outcomes Framework

5.1 In common with most other regulators, the GPhC has a statutory responsibility to set standards for education, training and practice for the professional groups it regulates. We have a statutory obligation to consult when setting standards and must ensure that the standards we set produce registrants who are fit for purpose. We are unclear how this statutory role articulates with the proposed Educational Outcomes Framework (EOF). The EOF is reasonably generic and does not conflict with our standards but we need clarity on the role of the EOF in relation to statutory standards setting by regulators and welcome the Committee’s inclusion of the EOF on its agenda.

5.2 There are some important issues at stake, such as whether the EOF as interpreted by HEE or a LETB could be used as leverage to encourage or indeed require a regulator to alter standards. We assume that the key players will be expected to work together to achieve the necessary outcomes but we do need to know who takes the lead in setting standards for regulated professional groups. Given their statutory role, we assume this will be regulators, in consultation with stakeholders.

6. How the workforce requirements of providers of NHS and non-NHS healthcare will be balanced

6.1 We note that the Committee will be exploring the provision of healthcare in NHS and non-NHS settings. From an education perspective, we have been concerned that non-NHS education and training did not feature prominently in the original proposals. In some health professions education and training at all stages is enmeshed with NHS structures and processes, but this is not true in all cases. For some professions, including pharmacy, private commercial education and training predominates, and this extends to pharmacy pre-registration training, much of which takes place outside NHS-managed and NHS-funded structures. For example, two major community pharmacy chains train a significant proportion of all GB pre-registration trainee pharmacists and they train far more pre-registrants than the NHS.

7. How funding will be protected and distributed in the new structures

7.1 A particular concern for pharmacy is how funding for pre-registration trainee pharmacists will be drawn down in both NHS and non-NHS contexts. As well as noting that parts of the current funding distribution chain are to be abolished (strategic health authorities, for example) we would like to know how key non-NHS providers will feed their views in about new funding mechanisms and at what level?

8. The future of postgraduate deaneries

8.1 We regard postgraduate deaneries—or rather structures for integrated, multi-professional postgraduate healthcare education and training—as vital. Liberating the NHS seems to call into doubt the future of deaneries without offering concrete proposals about how their work might be strengthened or taken over by other bodies. While we appreciate the localism agenda in Liberating the NHS, we feel that regional centres of excellence for postgraduate healthcare education and training (whatever they are called) should remain a feature of the new system architecture and should be strengthened.

8.2 One of the most positive features of deaneries is that they facilitate multi-disciplinary working, a central tenet of Liberating the NHS. It has been a frustration for pharmacy that to date it has been unable to join the deanery network for funding reasons. Joining the network is an aspiration for pharmacy and the Modernising Pharmacy Careers Programme Board has made this clear to Medical Education England. As with medical education, a new multi-professional deanery network could play a significant role in the QA of pharmacy postgraduate training.

9. How the new system will relate to healthcare, education, training and workforce planning in the other countries of the UK

9.1 This is of particular concern to national regulators. Our view is that the public have the right to expect that healthcare professionals will be educated to the same standard across the United Kingdom and that professionals must be enabled to practice in the four countries—ensuring this is a key role for regulators. We make this point because Liberating the NHS emphasises local service delivery and the needs of local populations, but we contend that this must be viewed in the context of national standards for education and training. (Perhaps it is the emphasis on the local which explains why the national role of regulators is not as prominent as it needs to be). Mobility of both patients and professionals within and between the different parts of the UK must be underpinned by quality-assured national standards. These need to take account of “local” priorities but cannot in the end be exclusively driven by them; the ultimate key driver for the regulators is public protection.

10. Role of the Centre for Workforce Intelligence

10.1 We support the principle of developing the healthcare workforce on the basis of the best available intelligence about workforce needs. While we think the role of the Centre for Workforce Intelligence needs to be clarified, it has the potential to be a powerful planning tool. We note that for the Centre to be effective, it will have to gather (commercially) sensitive information from NHS and non-NHS sources. The importance of providing this information on a confidential basis will have to be made clear to employers.

December 2011

Prepared 22nd May 2012