Council agrees new guidance on supervision during consultations

The Council of the Royal Pharmaceutical Society has agreed guidance on supervision that will allow the sale and supply of pharmacy and prescription-only medicines while a pharmacist is involved in a private consultation with a patient.

The guidance was approved at the December Council meetingon the recommendation of the Law and Ethics Committee. It appears as a Law and Ethics Bulletin item in the panel overleaf and is also available through the ethics section of the Society’s website (www.rpsgb.org/ethics).

The guidance was drawn up in response to enquiries from community pharmacists about how they should conduct their pharmacies while carrying out medicine use reviews (MUR). The new contract for community pharmacy in England and Wales requires that an MUR is normally carried out by the pharmacist face to face with the patient in a part of the pharmacy premises that is clearly signed as a private consultation area and allows them to sit down and talk at normal speaking volumes without being overheard.

Because a pharmacist in such a consultation is unlikely to be aware of medicine sales or supplies being made, or of conversations between staff and patients, pharmacists have asked how the supervision requirements can still be met and, in particular, whether dispensed prescriptions can be handed out and pharmacy medicines sold while the pharmacist is undertaking a private consultation.

The Council was reminded that the Society’s interpretation of supervision has insisted on a higher level of supervision than necessarily required by the Medicines Act. It has traditionally advised that when a pharmacist is not present in the area of the registered premises where the medicine sale or supply is taking place, the sale cannot be said to be supervised. The introduction of the medicines sales protocols in the mid-1990s recognised that medicines sales could be carried out by suitably trained and competent members of staff acting in accordance with agreed protocols, but did not take away the need for the pharmacist’s physical presence.

The Law and Ethics Committee therefore proposed that while a pharmacist is undertaking a private consultation trained staff should be able to sell pharmacy medicines in accordance with a standard operating procedure that would forbid any sale that the pharmacist would not want to take place. Furthermore, staff should be able to hand out dispensed medicines that have had a clinical check and are ready for collection.

The committee believes that such an approach will be in the spirit of the policy developed by the Society in its response to the consultation document “Making the best use of the pharmacy workforce”and will be within the spirit of the way Government policy is moving,as seen in the Health Act 1999.

Asked whether the easing of the restriction applied also to other circumstances in which the pharmacist was otherwise occupied, Douglas Simpson,chairman of the Law and Ethics Committee,said that the guidance applied only to the situation where an MUR was taking place because that was the circumstance that members had asked the Society to address.

After the Council meeting, Lynsey Balmer, the Society’s head of professional ethics, said: “The new guidance will help the Society ensure the safe and effective supply of medicines as more pharmacists start to undertake private consultations. In light of the proposals to change the current supervision and personal control requirements of the Medicines Act, the Society has adopted a pragmatic approach to its guidance,while taking into consideration the existing legal and ethical framework.”

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Citation
The Pharmaceutical Journal, PJ, December 2005;()::DOI:10.1211/PJ.2024.1.300193

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