Health CommitteeWritten evidence from the Faculty of Pharmaceutical Medicine (ETWP 93)


The transition to a new system must occur carefully and gradually.

Healthcare providers have a duty to consult patients, local communities, staff and commissioners of services about how they plan to develop the healthcare workforce.

Educational supervision must be prioritised, with ES roles recognised in job plans.

Experienced professionals must be re-incentivised and encouraged to engage in innovative medicines research and development.

The Medical Royal Colleges and Faculties can play a pivotal role in the quality assurance of education and training.

Due attention must be paid to education and training occurring outside the NHS.

Under a levy system, there should be no distinction between NHS and non-NHS providers.


1. The Faculty of Pharmaceutical Medicine (“the Faculty”) welcomes the opportunity to submit evidence to the Select Committee’s inquiry into Education, Training and Workforce Planning. The Faculty is a registered charity and exists to advance knowledge and promote the science of pharmaceutical medicine by working to develop and maintain competence, ethics, integrity and the highest professional standards of practice in the specialty for the benefit of the public. In short it concerns itself with postgraduate education of pharmaceutical physicians and with standards of practice of pharmaceutical medicine in medicines development. Hence, the Faculty has a strong interest in ensuring that the integrity and rigour of medical education and training continues through the proposed structural transformations.

2. Pharmaceutical medicine practitioners in the UK are approximately 1,500 doctors (approx. 1.5% of the medical workforce) who are employed in pharmaceutical companies, regulatory authorities and contract research organisations, and in independent consultative roles. After completing at least four years of post-graduate clinical training and reaching the competences of S2, further training & education is undertaken outside the NHS through a four-year workplace-centred, competency-based programme of Pharmaceutical Medicine Specialty Training (PMST). Successful completion of PMST leads to specialist registration (in Pharmaceutical Medicine) with the GMC.

3 The Faculty understands that the changes at the heart of the Government’s proposals concern the devolution of planning and development of the healthcare workforce from the centre (DH) to healthcare providers, with responsibility for education & training and development to be delivered locally by multi-professional Skills Networks (legal entities), replacing postgraduate deaneries. Skills Networks, accountable to, funded and audited by healthcare providers, will in turn manage local workforce data and planning as well as the funding for training. A new board, Health Education England (HEE) will replace all current bodies to focus on workforce matters (coordination, harmonisation) at the national level.

The Transition

4 Whilst the Faculty broadly agrees with the Government’s proposals we do have concerns about the organisational challenges inherent in such an upheaval. Postgraduate medical education and training linked to workforce planning and effective implementation has been in flux for the last six-seven years, and perhaps only now is beginning to settle again. Now this fundamental reorganisation of the structures and processes of education and workforce planning through devolution to local healthcare providers is a major upheaval on top of the content changes. This will be compounded by the financial considerations, and the change of fiscal arrangements (from top-slicing to tariffs and levies). At best this will all take a long time to work through, and it is to be hoped that during this time, the standards and quality of PG E&T are not diminished. We are concerned that there must be an appropriate transition plan between systems and a defined period before launch rather than a sudden change.

5 During the transition to a new system the Government must ensure that there is effective dialogue between Skills Networks and HEE. If HEE is not established before Skills Networks are implemented, then it will be up to the Skills Networks to help develop the relationships, roles and responsibilities, framework for joint working and accountabilities with and for HEE. In turn this will be an opportunity for Skills Networks to have an oversight body that they can work with and that delivers for them the benefits of a national advisory body without the bureaucracy and lack of local involvement which could eventually weigh on them adversely.

6 The Faculty believes that all healthcare providers have a duty to consult patients, local communities, staff and commissioners of services about how they plan to develop the healthcare workforce. Whilst this process might impact on the duration and complexity of the reorganisation, in addition to the issues raised in paragraph 4, we believe that this is a vital step in the process.

7 The Faculty believes that many healthcare providers do not have a great record for prioritising education & training against service provision and healthcare research; so, investing them with all the high principles and high expectations of devolved responsibility for E&T without many safeguards built into the plan may at best see many delays to implementation, and at worst see the whole plan falter irretrievably.

Education and Training under the New Framework

8 The Faculty wishes to ensure that, in a new system, both local and national requirements for recognition of trainees’ needs for workplace-centred opportunities for E&T, training time, and fulfilment of the new specialty-based curricula and assessments, including the many general and transferable skills and medical leadership, are coordinated. We are keen that educational supervision (ES) to be prioritised, with ES roles recognised in job plans. It is also vital that accurate workforce planning is carried out to avoid under—or over-supply; this might be better done at local level than national and avoid the traumas of eg MTAS.

9 The Faculty believes that education and training must meet designated standards, which must be adhered to and compliance assured. Whilst healthcare providers themselves have a responsibility for this (QC), there must also be external bodies to bring fair assessment of adverse findings, remediation and compliance to bear. The first stop for this will be the Skills Networks (QM). Oversight of the whole, as mentioned in the consultation, will be through regulators (eg GMC for medical education matters), CQC and Monitor. It is also believed that Colleges and Faculties can play a role in this matter through early intelligence and identification of problems; this information must then be routed appropriately and responsibility for the necessary action taken.

10 We are concerned that there does not appear to be enough mention of information technology (IT) in the proposals. Particularly, increasing effective use of IT represents automation of activity and often can reduce the numbers of people needed in a workforce. IT also provides continuity of knowledge and care in the NHS, which is value to the workforce. IT also allows monitoring of performance.

11 Healthcare provider Skills Networks and HEE can best secure clinical leadership by encouraging clinicians to be engaged in leadership matters at all stages and their participation shown to relate to improved outcomes in both care and, if possible, the economics of care. In turn Medical Leadership is now embedded in specialty training curricula. The Faculty, through its specialty training programmes, now PMST, has fostered Interpersonal and Management Skills as part of the training, and this has now been enhanced by the addition of the Medical Leadership “curriculum” as part of this. It is worth highlighting that there are many aspects of training and education and that they can be beyond the traditionally accepted ones as they are role specific and relate to skills updates, knowledge acquisition/generation and behaviours amongst others. Medical leadership training (via Medical Leadership Forum and continued through new initiatives such as the Faculty of Medical Leadership & Management) and its demonstration through acquisition of competency and assessment must be actively encouraged. Both HEE and Skills Networks will have to play a part in bringing this about.

12 The Faculty would recommend that through the new system E&T and workforce planning and deployment are used to re-incentivise and encourage experienced and expert professionals to engage in innovative medicines R&D (especially development), by allowing time for this activity which does not conflict with service requirements.

The Levy

13 The Faculty takes the view that the doctors (and other healthcare professionals) working within the pharmaceutical industry, whilst operating wholly outside the NHS, are nevertheless part of the medical workforce that is delivering healthcare for the benefit of patients and the public health. The postgraduate training of these doctors, through the four-year CCT programme, PMST, is paid for largely by the employer, and thus indirectly through the taxpayer (public purse) through sale of the industry’s medicines. The collaborative work between these non-NHS doctors and NHS healthcare professionals brings great benefits, through the provision of new medicines and other treatments, to the NHS and patients in the UK, as well as to the nation through a net exporting industry. There should be no consideration of a levy on those UK-trained doctors working outside the NHS but in the interests of the NHS, patients and the nation.

Flexible Career Paths

14 We believe that medical students and foundation doctors should be made aware of the full range of medical careers available to them. PMST is undertaken outside the traditional training structures of the NHS and this and other training programmes must be given the same acknowledgement and priority as more mainstream career choices. The new proposals must reflect the importance of flexibility between careers in industry, NHS and academia, and secondments as learning opportunities and as such that the groups cannot be silo’ed.

December 2011

Prepared 22nd May 2012