Nigel Clarke has completed his inquiry into what form the professional body for pharmacy should take after the Royal Pharmaceutical Society loses its regulatory functions to the General Pharmaceutical Council in 2010.
He stressed last week at the launch of his inquiry’s final report the importance of every member of a professional body feeling they are represented well.
“There are a very large proportion of the profession who see a need for support in various ways in their practice to come from the professional body — and that’s what we want to see happen.”
The professional body should provide strategic leadership and support for pharmacists, enabling them to meet their professional aspirations and deliver the best possible service to patients and the public. It should speak for the science and practice of pharmacy to the public, policy makers and stakeholders.
This is the inquiry’s first recommendation. Whether or not pharmacists — and other members of the pharmacy family — believe the Society has provided such leadership in the past, the Clarke Inquiry makes no bones about what it would expect from a professional body in future.
Indeed, Mr Clarke said last week that he believed many pharmacists currently felt distanced from the Society — but he acknowledged that one of the reasons for this was the Society’s role as a regulator, describing professionals’ relationship with the regulator as “never a cosy one”.
The report elaborates: “We were told by many respondents that communication with them by the Society had often been minimal and that this enhanced a feeling of separation and distance. This is in large part explained by the constraints that have developed over time as a result of the burgeoning regulatory function, which is often expressed in ‘communication by pronouncement’.”
In its report the inquiry says that it sees no fundamental conflict between a membership body that seeks to lead and support its members and one that provides a strong voice for pharmacy as a profession.
“Championing pharmacy and the effective use of medicines to all stakeholders would not merely be in the public interest. It would enhance the status of the profession generally and so be in the interest of members. The two objectives go hand in hand,” the report says.
The report restates the Company Chemists’ Association’s view: “Modern strategic leadership is by its nature aspirational; it celebrates the innovative and developmental, and does not pander to the lowest common denominator.”
The inquiry writes: “The concern underlying the frequent comment that the new professional body must ‘represent pharmacists’ was not, however, simply an abstract point. Rather there was a repeated demand that a new professional body, for which membership was both voluntary and an expense in addition to fees to the new regulator, must have a membership focus and must demonstrate that it could add value.
“It was a constant theme in the evidence — including that from the RPSGB itself — that the new professional body must have a culture radically different to the existing regulator.”
In another of the 64 recommendations listed in its report the Clarke Inquiry stresses the need for pharmacy leadership to be strong and visible:
The professional body should provide a strong single voice and vision for pharmacy. It should see effective communication, whether to its members or to the public, as a key task.
“At the public meetings many people picked up on the fact that when a medicines issue was discussed on radio or television it was never a pharmacist that the media turned to, but rather a doctor,” the inquiry reports.
“Many commentators believed that the profile of pharmacy and pharmacists was unacceptably low with the public and opinion formers. This was not merely a matter of status — it was professionally damaging. We were told of examples where doctors had been so unaware of the training received by pharmacists that they were unwilling to accept that pharmacists could perform roles well within their competence.”
The Association of the British Pharmaceutical Industry is quoted in the report. “There are numerous bodies seeking to represent pharmacy at a national level,” it says. “This in itself creates difficulties to those seeking to work with pharmacy. Thus, the pharmacy profession has struggled to effectively communicate its agenda clearly to other stakeholders.”
Mr Clarke’s report reveals that most commentators saw a professional body’s public affairs role as needing to be proactive rather than reactive. “They wanted the body to go to Government and other commissioners and clearly identify the problems to be addressed and the resources needed to deal with them.”
Nonetheless, the report adds that people who responded to the inquiry did not see negotiation of new services or fees as part of the body’s remit.
The Professional Body must be a trusted and influential source of advice for Government as well as being an effective lobbyist and champion for pharmacy and pharmacists. It must not simply react to the agenda of others but should lead the debate on all issues concerning the safe and effective use of medicines. It must be visibly independent of Government, willing to criticise as well as collaborate.
Discussing this recommendation, the report says: “Many commentators felt that the existing professional body had been influenced too much by Government. Our analysis is that this perception is very much a consequence of the rapidly developing public policy debate over regulation. A confident professional body would be resistant to pressures from whatever source in support of its members.”
Links with the new regulator will take time to develop as the two new organisations find their feet, the report says, stressing the importance of using the six months leading up to the start date to have as many decisions as possible made in advance.
The professional body must aspire to be the principal voice of the profession to the regulator, working as necessary with other stakeholders. It must establish early credibility to ensure that its contributions are given due weight.
In line with this recommendation the inquiry makes the following points: “First, that it will often be best in approaching the regulator to have the other stakeholder bodies onside. (Though we can also envisage rare occasions when a professional body may take a different stand from employer or employee interests.) Second, that it is a duty of a professional body to ensure that regulation is sensible and realistic. Third, that a professional body has to establish its credibility before it will be listened to by a regulator. One way of doing that is by having a high proportion of the profession as members and so being seen to be broadly representative.”
It goes on: “The point goes deeper. A regulator would only accept the professional body’s view on a technical or clinical issue if it were confident that the professional body had access to the latest expertise available in the profession. Otherwise it would go elsewhere. This is an important argument for inclusiveness and bringing into the new structure some of the smaller bodies where an essential part of that expertise now lies.”
The inquiry believes that the professional body ought to be visibly separate from the regulator but capable of informing, influencing, contributing to and reassuring it as necessary. In terms of physical separation, Mr Clarke said last week: “We think in the medium to long term it is not desirable for the professional body and the regulator to cohabit … but it may be sensible not to be too radical too early.”
The inquiry also suggests fostering closer links with other healthcare professionals and providing support for pharmacists to better engage with primary care organisations locally.
The inquiry report says that it is clearly the role of the regulator to own the standards by which individual members of the profession will be assessed. However, it points out that there is a range of roles that the professional body could take on to support this.
Although, it says, some respondents saw the regulator involved primarily with setting minimum standards, many saw the new professional body developing higher, aspirational standards.
It should be an early priority for the professional body, when working in ‘shadow’ form, to establish dialogue with the team working to form GPhC so as to establish an understanding of each other’s role in the setting of professional and ethical standards. Once established, the professional body should seek to ensure that the GPhC has sufficient confidence in it to enable it to play a full role in setting standards at all levels.
According to the report, all inquiry respondents recognised that the ultimate decision on professional standards would be made by the regulator but most of them hoped that the professional body would have substantial involvement in the development and specification of these standards, particularly those for ethics and practice.
“No regulator can perform effectively without the consent and buy-in of the regulated,” the inquiry states. “ Nevertheless this will only happen once the professional body has established such credibility that the regulator can have confidence in its judgements. It will only happen if it can call upon the expertise, from staff or members, to inform this work.”
The inquiry warns against the future professional body relying on providing “specific technical standard setting”, contracted by the regulator, as a potential stream of income. It views the professional body’s role here as “central” rather than a possible add-on.
“It would be misconceived to see income from this sort of work, which is in any event likely to be slight, infrequent and unreliable, as the main justification for the professional body’s involvement in standard setting,” it argues.
On undergraduate education Mr Clarke’s report says that there are roles for both the regulator and the professional body. The inquiry believes the professional body’s job here should involve working with universities on broad issues and assuring itself and the profession that the future needs of pharmacy are addressed.
The Professional Body should have sufficient capacity and expertise on educational issues to engage with the higher education sector to ensure that the undergraduate curriculum meets the aspirations of the profession. It should work in partnership with the GPhC on setting educational standards at that level.
The Council of University Heads of Pharmacy Schools is quoted in the report: “The new body should have a major role in confirming that university schools have met or continue to meet appropriate explicit standards for or relating to the curriculum; a very different role from ‘policing’.”
Any new professional body should develop a cohesive view and exert influence on issues surrounding preregistration training, the report also says. It recommends that the organisation should provide practical support for both preregistration trainees and their tutors.
Continuing professional development (CPD) is also discussed. The inquiry believes that the professional body should be involved in accrediting, but not necessarily providing, CPD activities, and in offering support for members to achieve positive outcomes from their CPD.
“The professional body should also have a role in identifying gaps in CPD provision and, if necessary, in encouraging others to provide material to fill them,” it adds.
“The position on revalidation is less clear,” the inquiry admits. “Plainly, when it happens, revalidation has the potential to be far more challenging for the profession than mandatory CPD. Since it will be a new hurdle members will require more support to surmount it.”
The professional body should play a part in developing standards for revalidation in support of GPhC but should have no role in policing the system. Rather it should develop systems (including peer support) and materials to give confidence and assistance to members.
The aforementioned recommendations cover only part of what the Clarke Inquiry expects the future professional body to do — the structures needed to support these functions are also given plenty of thought.
As Mr Clarke said last week: “The new professional body has to be able to support changes in the way that the profession works, so there must be sufficient flexibility in the structure to allow that to happen.”