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  • Rp and rs

    What is the difference between responsible pharmacist and Remote supervision, are they not both the same thing (the pharmacist won't be in the shop. Will this impact Hospital?

    Secondly, a PCT is a primary care trust but what exactly do they do.
    3rd yr pharmacy student - bath

  • #2
    Re: Rp and rs

    I am sure you asked me these questions about RP and RS in a "pm".

    The Responsible pharmacist concept is a change in the supervision regulations to bring us in line with many other professions eg accountants and lawyers where we don't have to do the work but take responsibility for it. The closest parallel is dispensing doctors who take responsibility for the dispensed medicine but don't dispense it. Pharmacists will be expected to be on the premises for all but 2 hours per day and dispensing, at the discretion of the pharmacist who will be responsible for such terms and conditions, may take place then when it currently can't. The aim is to allow a pharmacist to pursue a more clinical role, probably spending more time in a consultation room but doing less of the routine work in a pharmacy.

    It is fraught with danger which I am sure many here will discuss!

    Remote supervision, which was first offered by a Bristol pharmacy company 10 years ago seeks to have a pharmacist supervising dispensing and OTC sales from a remote location. The example first submitted was a pharmacist supervising 3 locations. As the supervision regulations were drawn up before the advent of webcams and electronics that enable sales/prescriptions can be remotely aborted, the DOH lawyers concluded that remote supervision is not illegal now. The new consultation will provide an opportunity to outlaw it. However there are many who see it as an opportunity to cut the cost of having a pharmacist in the dispensing process.

    I can't see how it WON'T have an impact on hospital pharmacy but only with regards to the dispensary.

    A PCT is the local organ of the NHS responsible for primary care within a defined locality. Doctors, dentists etc hold contracts in the area in which they work with a PCT. The PCT is relatively autonomous and able to operate in a manner that takes cognescence of it's local population peculiarities and has the resources to address these peculaiarities. As different PCTs have dealt with similar challenges differently across the country, many services are different in different areas. It has meant, for example, that accreditation for pharmacy enhanced services is different in different areas.

    PCTs are essential as local populations need local delivery of services and local people to hold accountable.
    Last edited by Tony Schofield; 27, October 2008, 08:08 AM. Reason: Conclusive proof of my illiteracy
    http://uk.youtube.com/watch?v=Hmbyj0XFUhA

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    • #3
      Re: Rp and rs

      The Responsible pharmacist legislation allows the 'responsible pharmacists' to be absent from the pharmacy for UP TO 2 hours in any 24 hours period. This allows the pharmacists to actually have a lunch break, and gives the opportunity to carry out clinical roles outside the pharmacy. While the pharmacist may not be on the premises they are responsible for everything that happens within the pharmacy, therefore this new legislation allows for the sale of GSL medicines when the pharmacist is not there - something that is not meant to happen at the minute, even though supermarkets, etc, sell GSLs with no pharmacists presence.

      It was thought that the legislation would allow a pharmacist to be responsible for more than one pharmacy. However, the DoH has confirmed that a repsonsible pharmacist was only be responsible for ONE pharmacy at any one time. This may be increased to a maximum of two pharmacies, for a limited time period, but only in exceptional circumstances such as a terror attack or a pandemic - but these circumstances are still to be laid out as far as i am aware. If there is more than one pharmacist on the premesis this does not affect the time of absence allowed - not cumulative.

      Yes, the pharmacist will be responsible for their staff's actions when they are not there. Their performance is to be ensured through training and easy to follow guidelines and SOPs. Correct me if i am wrong, but this is no different to how it is at the minute is it? It is the pharmacists job to ensure all staff are competently trained and SOPs are in place. It is part of the RP legislation to ensure the RP is contactable at all times and is able to return to the pharmacy in a timely (ie. prompt) manner. If the RP cannot be contacted then there needs to be procedures in place so that another pharmacist can be contacted.

      All in all the RPSGB and CCA have realised its not a bad thing after all as many of the things outlined are part everyday practice anyway, apart from the whole absence thing of course. The RPSGB are going to produce guidance for pharmacists and pharmacy students and this should be ready by June/July 2009 - as the RP becomes active from October 1st 2009. I think they are planning a consultation also.

      The CCA could not agree on the time of absence but have accepted the outcome, they do like the idea of having a notice of whom the RP is for the day as it can be confusing for patients when they see a long list of certificates. The CCA also liked the idea of the RP register in each pharmacy, that the RP would have to sign to accept responsibility for that pharmacy for the day - they thought this would remind the RP of their responsibilities.

      The PDA want to see some form of competency assessment to become a RP to ensure patient safety through experience and knowledge. They also thing having a strict time limit may allow people to abuse this and take the full time when they don't need it - also, what if you do clinical for 2 hours then something else crops up that really requires your absence? The PDA hope the RP legislation will allow more autonomy for pharmacists and allow them to decide what services the pharmacist offers and what clinical roles they undertake - though they are worried the RP will still be answerable to the managers and superintendents at large chains.

      -----------------
      All the above was based on notes i made from the RP talk and debate at BPC 2008.

      RS is still a hotly debated topic that i shan't go into as i don't have all the facts and can't really make my mind up on RS at the moment. However, i do quite like what has been done with RP.

      Remote supervision will allow Ps and POMs to be supplied from a pharmacy whilst the RP is absent and that the pharmacist should be contactable at all times to answer queries and 'remotely supervise' the process. This is the part i have a problem with, as the tech could give out a Rx and the RP be responsible for any problems - whether they have been contacted or not. Who is to say the tech won't say they contacted you (even though they didn't) to ensure they don't get disciplined and all the blame is put on the poor pharmacist? I think a lot of work needs to be done on RS for it to be accepted by ANYONE who is slightly sane.
      Last edited by TigerSwift; 29, October 2008, 12:29 AM. Reason: didn't answer original poster's last question
      I like beef and i like liver, meow mix meow mix please deliver.

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      • #4
        Re: Rp and rs

        Superb summary of RS Tigerperson. The difference with how things are now is that currently, despite being able to sell GSL products anywhere, if a pharmacy sells them and the pharmacist absents him/herself it is illegal to offer them for sale. That was an unintended anomaly and will be addressed in the new legislation. The really tricky bit is that a lot more responsibility that is currently the domain of the superintendent will be devolved to the pharmacist in charge making them responsible for things like training and SOPs. That is a real problem for a locum who is in for the day and doesn't know anyone never mind their competency but may well be held professionally accountable.

        At the moment, I insist that the pharmacist has a lunch break and don't pay locums for the break. Under the RS legislation I would expect to have to pay as the pharmacist is responsible even though away from the premises for up to 2 hours.

        Remote supervision would allow a pharmacy to operate without a pharmacist at all so long as he/she could intervene in dispensing or OTC sales. They would monitor remotely using technology. Any pharmacist supporting it would be a turkey voting for Christmas but obviously employers can see the benefit to saving the cost of a pharmacist. It is currently legal so make sure you oppose it when given the chance!
        http://uk.youtube.com/watch?v=Hmbyj0XFUhA

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        • #5
          Re: Rp and rs

          I disagree about the RP legislation providing the opportunity for the pharmacist to have a break.

          As mentioned at BPC the pharmacist will have to remain contactable at all times during the 2 hour absence and undertake to return as soon as possible if needed to do so.

          This is contrary to guidance and common acceptance of rest break criteria in that it is a TOTAL break. If you have to remain at the end of a mobile phone or a pager on alert that you may have to return then it is not a break.

          I wish the RP guidance had provided properly for rest breaks but by rushing it through in the format that they have the DH and RPSGB are not removing the anomoloy of GSL meds that they claim to be. We are going to end up with GSL meds being allowed to be sold whilst the pharmacist is not on the premises but not if they are on a break but still on the premises.

          As Tony said the situation for locums is going to be very tricky and if RP goes ahead as proposed at BPC then I do not believe I will be locuming after 1st October next year.
          Titch

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          • #6
            Re: Rp and rs

            Originally posted by Titch View Post
            I disagree about the RP legislation providing the opportunity for the pharmacist to have a break...This is contrary to guidance and common acceptance of rest break criteria in that it is a TOTAL break. If you have to remain at the end of a mobile phone or a pager on alert that you may have to return then it is not a break...
            Surely the pharmacist would feel more comfortable that their staff can contact them about a query or problem, and aren't just going off their own judgment. Also, imagine telling a patient that they can't have a product because the pharmacist is upstairs on their break. I feel there is a difference between taking a break and putting the running of the pharmacy at risk.
            I like beef and i like liver, meow mix meow mix please deliver.

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            • #7
              Re: Rp and rs

              Originally posted by TigerSwift View Post
              Surely the pharmacist would feel more comfortable that their staff can contact them about a query or problem, and aren't just going off their own judgment. Also, imagine telling a patient that they can't have a product because the pharmacist is upstairs on their break. I feel there is a difference between taking a break and putting the running of the pharmacy at risk.
              A break where you remain contactable and able to return to the pharmacy at short notice is NOT a break - it is being on call. A break has to be taken completely without work intruding.... and this could be for your defense in the event of an error...

              Many places already tell customers that they willl have to wait for the pharmacist to come off lunch - they often have a little sign to that effect for the counter.

              As for staff just going off on their own judgment - this is a big problem for locums as you have had no part in their training. If working as a manager, I hope my staff would be VERY aware of their limits. BUT you should not be denied proper legal breaks just because the owners of the pharmacy have taken a commercial choice to remain open during pharmacist's breaks.


              I think the recent Which and Daily Wail surveys (whilst small and biased?) should give pause to anyone who thinks introducing a new system based on the idea that SOPs and sale protocols are working now is a goer.
              Employed again... paid holidays! Yipee

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              • #8
                Re: Rp and rs

                Originally posted by Tony Schofield View Post

                Remote supervision would allow a pharmacy to operate without a pharmacist at all so long as he/she could intervene in dispensing or OTC sales. They would monitor remotely using technology. Any pharmacist supporting it would be a turkey voting for Christmas but obviously employers can see the benefit to saving the cost of a pharmacist. It is currently legal so make sure you oppose it when given the chance!

                I can see the future:

                Patient: "Is this place a Pharmacy? I'd like to speak to the Pharmacist please"

                Tech/Multiple dogsbody - "Yes, It's a Pharmacy, but the Pharmacist isn't available at present.
                Can we help?
                if you have any questions we can ask the Pharmacist who is available on webcam"

                Patient: "What, so you're saying there is no Pharmacist here?"

                Tech/Multiple dogsbody: "Um ,yeah the Pharmacist isn't here physically, but he can answer your questions via webcam if you wish"

                Patient: If I wanted to speak to someone via a webcam I'd be at home on my laptop, this is ridiculous A Pharmacy without a Pharmacist!!!

                Patient: Proceeds to tell everyone he/she meets that day
                "I wouldn't go into that Pharmacy, there's no Pharmacist in there"

                Area Manager wonders Why patients (customers to him) are not returning to the Pharmacy
                Last edited by openmind; 30, October 2008, 12:01 AM.

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                • #9
                  Re: Rp and rs

                  Good analogy... I think the NPA mentioned that situation in reflection of their one of their campaigns: "Soon it will be 'ask where your pharmacist is week' not 'ask your pharmacist week' "
                  I like beef and i like liver, meow mix meow mix please deliver.

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                  • #10
                    Re: Rp and rs

                    The first time a serious error occurs under remote supervision - the Lawyers will rip it apart.

                    Comment


                    • #11
                      Re: Rp and rs

                      Originally posted by openmind View Post
                      The first time a serious error occurs under remote supervision - the Lawyers will rip it apart.

                      How does that differ from now?

                      No-one is currently using remote supervision but it is legal now. The consultation will give the opportunity to ditch it.


                      <<Patient: If I wanted to speak to someone via a webcam I'd be at home on my laptop, this is ridiculous A Pharmacy without a Pharmacist!!!

                      Patient: Proceeds to tell everyone he/she meets that day
                      "I wouldn't go into that Pharmacy, there's no Pharmacist in there"

                      Area Manager wonders Why patients (customers to him) are not returning to the Pharmacy >>


                      Nice try. Imagine the scenario in an internet pharmacy?
                      http://uk.youtube.com/watch?v=Hmbyj0XFUhA

                      Comment


                      • #12
                        Re: Rp and rs

                        Originally posted by TigerSwift View Post
                        Surely the pharmacist would feel more comfortable that their staff can contact them about a query or problem, and aren't just going off their own judgment. Also, imagine telling a patient that they can't have a product because the pharmacist is upstairs on their break. I feel there is a difference between taking a break and putting the running of the pharmacy at risk.
                        I would always prefer the staff to contact me if they had a query or a problem.

                        The problem is the 2 hr per 24 hours absence that RP is going to allow is being sold to pharmacists as the answer they have been waiting for in that GSL sales can still happen in the absence of a pharmacist. Many people are interpreting this as during a break and assuming that the 2hr absence will be used to cover break times.

                        Three points:
                        1. The 2 hour absence is a permissibile absence not a necessary absence so the pharmacist does not have to be absent for 2 hours in every day
                        2. Only GSL meds can continue to be sold during that absence so you are sitll going to have to tell patients to come back later for P meds and collecting scripts
                        3. I stand be what I said and Defblade supported, being on call is not the same as having a break

                        The RP legislation had the potential to be so good for pharmacy and yet all it is going to do is cause more confusion and more red tape on a daily basis. I can think of very few pharmacies where I am so confident in the training and quality of the staff and the procedures that are in place that I will accept responsibility for what we are going to be asked to accept responsibility for.

                        It is diferent to what we currently do as at the moment we supervise what happens within the pharmacy and have personal control whilst we are the incumbent pharmacist. Under RP we are going to be responsible and yet, if you are a locum or an employee within a multiple, have very little say in staff training, SOPs etc.
                        Titch

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                        • #13
                          Re: Rp and rs

                          Originally posted by Tony Schofield View Post

                          Nice try. Imagine the scenario in an internet pharmacy?
                          Yep those Counterfeit Viagras have me rattled allright

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                          • #14
                            Re: Rp and rs

                            What are you talking about?

                            Internet pharmacies are exempt from control of entry regulations. Pharmacy2u is one and there are many others. They carry the RPSGB "crest" as proof of their validation. They dispense NHS prescriptions and will increase in number dramatically if they can be remotely supervised.

                            Do try and keep up!!
                            http://uk.youtube.com/watch?v=Hmbyj0XFUhA

                            Comment


                            • #15
                              Re: Rp and rs

                              Originally posted by Tony Schofield View Post
                              What are you talking about?

                              Internet pharmacies are exempt from control of entry regulations. Pharmacy2u is one and there are many others. They carry the RPSGB "crest" as proof of their validation. They dispense NHS prescriptions and will increase in number dramatically if they can be remotely supervised.

                              Do try and keep up!!
                              You mean this Pharmacy2U?

                              What?s new

                              Why did the MRHA act - or perhaps it should be why didn't the RPSGB?

                              Jeff

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