What provisional registration will mean for the pharmacy profession

The COVID-19 pandemic has forced radical changes to how the 2020 class of preregistration trainees will transition into their careers.

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Trainee pharmacists in the class of 2020 are ending their preregistration year in a way that none of them could have imagined just a few months ago.

As the COVID-19 pandemic spread around the globe, and normality disappeared almost overnight, it soon became apparent that the path to becoming a fully fledged pharmacist for those at the end of their preregistration year was going to be even more complicated than usual.

The trainees were told, at the end of March 2020, that their registration assessment had been postponed, but were given little information on when, or how it might be held while maintaining social distancing. They now know it will take place online, but otherwise are still waiting for more details on how they will quality for the General Pharmaceutical Council’s (GPhC’s) registe­r.

On 21 May 2020, almost two months after the UK’s pandemic lockdown was declared, the regulator announced that it had agreed a form of provisional registration for current preregistration pharmacists who qualify (see Box).

This compares with medicine, where early provisional registration for final-year medical students was announced eight weeks earlier — on 26 March 2020 — and nursing, where those in the final six months of their preregistration year were able to complete their programmes in clinical placements.

Box: How will provisional registration work?

The General Pharmaceutical Council says further clarification will follow later in June 2020. But for now, the criteria to apply for provisional registration include individuals having passed the MPharm degree or Overseas Pharmacists’ Assessment Programme; successfully completed 52 weeks preregistration training in 2020; not previously have failed the registration assessment; and self-declaring that they are fit to practise as a pharmacist.

Applicants must also have a final declaration from their preregistration tutor confirming that they have met all 76 performance standards and that they are not subject to current fitness-to-practise proceedings. This declaration must include confirmation from a second registrant — or another healthcare professional who has been involved in the applicant’s training — that there is no reason why the applicant would not meet the standards for pharmacy professionals.

Provisionally registered pharmacists must practise under the guidance of a senior pharmacist, within an organisation which has either a superintendent pharmacist or a chief pharmacist or is owned by a pharmacist. They may not work as locums, but can act as the Responsible Pharmacist.

Understanding the new regulations

When the new regulations were eventually announced, they allowed those who graduated with an MPharm in 2020, having completed 52 weeks’ preregistration training and self-declared that they are fit to practise, to start practising as a provisionally-registered pharmacist from 1 August 2020.

Pharmacists on the provisional register cannot work as locums, but they are able to take the role of Responsible Pharmacist, and they must work under the “guidance and direction” of a senior pharmacist.

The proposed criteria require the newly qualified pharmacists to be supported, which is right

Khalid Khan, head of training and professional standards at Imaan Healthcare , a chain of more than 50 independent community pharmacies in England, says: “My three wishes were for the criteria to be safe for patients, not to put the newly qualified pharmacists in a vulnerable position and be equitable regardless of which sector the training was carried out in.

“Allowing them to locum could have put them in a very vulnerable position, which could have led to patient harm and situations they may have struggled to recover from psychologically. The proposed criteria require the newly qualified pharmacists to be supported, which is right”.

Employers hiring a provisionally registered pharmacist will be required to carry out a monthly risk assessment of both the employee and their role. Among other things, this should look at the pharmacist’s portfolio of evidence from their preregistration training. However, Gareth Nickless, lead clinical liaison tutor at Wirral University Teaching Hospitals NHS Foundation Trust and Liverpool John Moores University, notes that preregistration training undertaken in 2020 may have been impacted by the COVID-19 pandemic.

“What if the person who does the risk assessment looks at the portfolio and thinks ‘That’s quite thin on evidence, but yet, they’ve been signed off’? What tensions could that create?” he asks. And he suggests that, in the longer term, this may lead to a requirement for some kind of external quality assurance of preregistration portfolios.

Ensuring provisionally registered pharmacists are well supported

There is no assurance that our employers will be able to give us enough time off to study

Employers have also been told that they must ensure that sufficient study time is set aside for provisionally registered pharmacists who have not sat their assessment. Courtney Ella Preston, a preregistration trainee at Guy’s and St Thomas’ Hospitals and Evelina London Children’s Hospital, told The Pharmaceutical Journal that study time during the latter part of her preregistration year was cancelled throughout the COVID-19 pandemic.

“I was redeployed to maternity services, and while this was a great experience for me, my learning and experience over the past ten weeks has been very niche and has thus left me with lots to study in preparation for the [preregistration] exam. I have also been extremely busy and, frankly, rather tired while working through this challenging time, and revision has taken a backseat,” she says.

Nour Morjan, a preregistration trainee with Boots in Wellington, Shropshire, says that working a full-time job while studying for the registration assessment — whenever it happens — will be a huge challenge. She is also a parent, which adds an extra level of complexity.

“I know other parents in a similar position, facing difficulties with finding childcare while keeping our training on track so that we finish and qualify, after all the hard work we have put into this,” she says.

“There is no assurance that our employers will be able to give us enough time off to study. At the end of the day, employers also have businesses to run.”

Sitting an exam in 2020

A date has still not been set for their final exam. Speaking to The Pharmaceutical Journal on 26 May 2020, Mark Voce, director of education and standards at the GPhC, confirmed that the regulator was considering the possibility of an online registration examination and looking for a possible provider that could ensure a safe and fair assessment.

This will, he said, involve security matters and “other practical points, including the broadband facilities that people have”. It will also look at how to not disadvantage candidates with medical conditions, both temporary and permanent.

“That will all be part of the process in making sure that we get an assessment which is not only secure and robust, but is absolutely fair to all individuals who will need to take it,” he added.

Nickless warns that any online system must be able to “cope with more than 2,500 students accessing it at the same time” and be configured to ensure that no student is let down.

The online assessment must not only be secure and robust, but absolutely fair to all individuals who will need to take it

He recommends that candidates sit any mock exam in a location that mirrors where they will take the real thing. “If you are planning to sit the [real] exam at work, sit the mock there. If you will be at home, sit the mock there. Just to get assurance that at that time of day, bandwidth can cope with running the assessment from the venue that you’re sitting it in”.

However, as a failsafe, he says that the exam should have a “function that logs progress, so if the system did go down, it would capture where students had got to” during the assessment.

Those who have previously failed a preregistration assessment cannot apply for provisional registration. Voce said that he understood those people’s “frustration and disappointment”, but that the rationale was that there is a difference between those who “have had an opportunity to take the assessment, and haven’t yet been able to demonstrate their ability to pass that”, and the current cohort “who simply have had no opportunity whatsoever to take the assessment”.

He said the GPhC planned to work with the RPS, British Pharmaceutical Students’ Association (BPSA) and others on how best to support these trainees.

The GPhC has said that at least two months’ notice will be given of the date of the registration assessment. However, Morjan feels that this is not enough time to prepare. “It is not just the assessment itself that is worrying: starting a job as a newly qualified pharmacist is not a walk in the park, even if we had passed the exam.

“Any job comes with its challenges and difficulties. Adding the stress of the assessment and having a new role with a load of responsibilities makes it even a more challenging situation.”

Preston says that “time for trainees to prepare needs to be balanced against minimising the delay in us becoming fully registered and, in light of this, two months’ notice is reasonable.

“My hope is that this is a minimum notice period and that the GPhC are considerate of the fact that we are all eagerly awaiting an exam date, so as to plan and prepare for the coming months.”

Transitioning into the workforce

One concern for the provisionally registered pharmacists is how much they will be paid.

The Pharmacists’ Defence Association has said that in community pharmacy, provisionally registered pharmacists “should be paid no less than a newly qualified pharmacist would have been paid [in 2020] if the pandemic had not occurred”. And it announced on 4 June 2020 that Boots had begun to advertise for provisionally registered pharmacist jobs at the same rate of pay— £36,600 per annum — that had been negotiated for newly qualified pharmacists prior to the pandemic.

Those going into hospital pharmacy will begin as band 6 pharmacists, with pay starting at £32,365— something that Roisin O’Hare, president of the Guild of Healthcare Pharmacists (GHP), believes is the right move.

In a webinar hosted by the Royal Pharmaceutical Society (RPS) on 4 June 2020, Vilma Gilis Lay, past president of the GHP, said provisional registrants should “challenge” anyone who tries to pay them less.

One of the restraints on provisionally registered pharmacists is that they must practise under the guidance and direction of a senior pharmacist. The GPhC has set out criteria for who they must be, but Nickless asks whether there will be any training for this role.

The current cohort will not forget which organisations, bodies and individuals were there for them in their hour of need

“Some of them might not have been a preregistration tutor before. Some might have the next batch of preregistration trainees joining in August 2020, but now there’s this extra batch of work that’s required of the senior pharmacist for the provisionally registered pharmacists.”

But these are unchartered waters and, ultimately, Rhys Llewellyn, public relations officer of the British Pharmaceutical Students’ Association, says “support, support, support” is what is really needed.

“The current cohort will not forget which organisations, bodies and individuals were there for them in their hour of need,” he says.

Gail Fleming, director for education and professional development at the RPS, says the Society is “providing a suite of training resources dedicated to helping provisional registrants, not just in their studies, but to ensure they are supported in their new roles as pharmacists”. And it has set up a dedicated provisional registration email — provreg@rpharms.com— for those in need.

Speaking on 26 May 2020, Duncan Rudkin, chief executive of the GPhC, said his organisation understood that the situation for current trainees was “exceptionally stressful”, and he described their response as “hugely impressive”, “very professional” and “humbling”.

Wan Ting Tee, a preregistration pharmacist working in Peterborough City Hospital, agrees. “I would like to shout out to all the [preregistration trainees]: this [situation] shows how resilient we are. I am really proud that we all have made it this far — keep going.”

Last updated
The Pharmaceutical Journal, PJ, June 2020, Vol 304, No 7938;304(7938):DOI:10.1211/PJ.2020.20208057

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