New GPhC threshold criteria to determine referrals for fitness to practise

Pharmacists’ conduct and performance, their health, and whether pursuing a case would be in the public interest will all be considered in determining fitness-to-practise referrals.


Six new threshold criteria are being used by the General Pharmaceutical Council (GPhC) to determine whether cases raise potential fitness-to-practise issues and thus should be investigated.

The criteria, which came into effect on 1 February 2018 and are set out in ‘Good decision-making: investigations and threshold criteria guidance’, take into account recent changes in pharmacy regulation: in particular, the new standards for pharmacy professionals introduced in 2017.

The six new criteria are listed under headings of conduct and performance, health, and public interest. They replace 15 criteria that were listed under the 7 principles of the previous standards for conduct, ethics and performance.

Under conduct and performance, the new threshold criteria say that the registrar should not refer a case to the investigating committee if: it does not present an actual or potential risk to patient or public safety; it has not undermined, and is unlikely to undermine, confidence in the pharmacy profession; there has not been a serious or persistent failure to meet any of the standards for pharmacy professionals; and it does not show that the honesty or integrity of the registrant can no longer be relied upon.

In terms of health, the criteria state that a case should not be referred unless there is evidence of adverse physical or mental health presenting a risk to the pharmacy professional’s ability to practise safely or effectively.

If any one of the above five criteria are met, registrants should only be referred for further investigation if it is in the public interest to do so, the final criterion emphasises.

When considering whether to refer, the registrar will also take into account whether the registrant acted recklessly or with intent; whether the incident is a recurring issue and whether the registrant has shown openness and honesty. The registrar may also take into account whether the pharmacy professional has learned from the incident; taken remedial action (such as having training or making changes to their practice) and whether guidance or advice has been issued to the pharmacy professional about the same or similar actions.

A consultation on the new criteria between December 2016 and March 2017 generated 68 responses from a range of stakeholders, and overall they were “received very positively”, the GPhC said.

Duncan Rudkin, chief executive of the GPhC, said the new threshold criteria “will help ensure that the public are properly protected by appropriate, consistent and proportionate decisions about whether or not to refer a concern to the investigating committee”.

Last updated
The Pharmaceutical Journal, New GPhC threshold criteria to determine referrals for fitness to practise;Online:DOI:10.1211/PJ.2018.20204359

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