We highlighted the lack of formal consultation process for the recertification framework. We requested that the implementation date is postponed until 1 April 2022. We highlighted member concerns around the verifier role. We highlighted concerns around increased costs for pharmacists completing CPD requirements.
13/12/2019. We supported the intention to increase visibility of decision making by health regulatory authorities. We believe the council has sufficient existing mechanisms to implement their naming policy and we do not support the use of social media platforms for these purposes. We requested that the council further inform the pharmacy sector to provide assurances over what will be the impact of the new naming policy.
14/10/2019. We wrote a letter to acknowledge our follow up meeting to discuss our response to their APC consultation. We agreed on the following: their retained surplus would be reduced to around $272K, we discussed and were satisfied with our original concerns around their proposed workplan, we still remained concerned around the unquantified costs supporting emerging policy work, we both agreed in principle that these costs should be met from separate Crown funding, and our views are unchanged that proposed budge increases are excessive and hence a proposed APC fee increase is not necessary.
20/09/2019. We raised our member's concerns over the Council's sixth consecutive proposed APC fee increase. We anticipated no need for a fee increase next year due to a sufficient aggregated net surplus. As previously highlighted, we questioned the appropriateness of the sector paying for emerging policy work. We also queried the allocation of funding for the Council's workplan. We voiced our members frustration over the inability of our members to bulk pay for APC fees.
19/10/2018. We supported the proposal to discontinue the written examination. We did not see reasonable justification for the written examination to continue to assess intern pharmacists as part of their registration process. We felt comfortable that the discontinuation of the written examination would not present any increased patient safety risk to the public. We supported the further recommendation to look at appropriate mechanisms to strengthen calculation skills and to ensure the existence of satisfactory English language requirements.
31/08/2018. On behalf of our members we raised significant concerns around the Pharmacy Council’s proposed increase in APC fees for the fifth consecutive year, and the $321,000 increase in annual project costs. We are concerned that the Pharmacy Council is getting involved in project work outside of its regulatory roles and responsibilities and is charging the sector for work that should either not be done by the Council and/or be paid for by the sector.
18/8/2017. We were supportive of the changes to the Code of Ethics.
23/12/2016. We noted members concern at the Pharmacy Council’s proposed increase in APC fees for the third consecutive year. We reviewed this proposed funding increase alongside the retained earnings within the Pharmacy Council’s General Fund and stated that we see no justifiable grounds for the proposed fee increase.
We responded to the Pharmacy Council’s proposal to increase the APC Fee and Disciplinary Levy from $550 to $648.90 (incl. GST) for the 2016-17 year. We believe that any fee increase should be limited to CPI, or indeed the CCP that is passed through to the pharmacy profession by the DHBs. We would also like to see a differential fee to recognise those pharmacists working less than 30 hours per week. We appreciate that the Council has moved to a shared resources model with some of the other health profession regulatory bodies and our members hoped that this would enable more manageable cost increases. We passed on the individual comments from our members – all were opposed to the proposed fee increase.
We supported the Council’s intentions of the proposed changes to clause 6.9 of the Code of Ethics 2011. We agreed that it is reasonable to continue to allow pharmacists to supply complementary therapies and other healthcare products that are of suitable quality and safety, however we also agreed that these products should not be promoted by pharmacists if there is evidence to suggest that these medicines lack efficacy. We believe that if pharmacists were prevented from selling natural products then patients wanting these products would continue to source them from somewhere. We consider that it is far safer for consumers to approach pharmacists for advice and that they purchase supplies of complementary medicines from a pharmacy rather than over the internet for instance, where the quality and safety of a product cannot always be guaranteed.
We considered that the eight standards for providing care to patients outlined in the Statement of Telehealth provided sufficient support and guidance to pharmacists on how to safely provide telehealth services to patients. We noted that the intention of the Statement on Telehealth was that it will replace the Protocol for the Sale and Supply of Pharmacist Only Medicines for Chronic Conditions (POMCC). We recommended that the POMCC be updated and retained as a stand-alone document, in addition to the Statement on Telehealth.
We requested that the Pharmacy Council consider the impact that an increase to the APC Fee will have on the retention of part-time pharmacists within the pharmacy profession. We asked that the Council consider a reduction in the APC for part-time pharmacists (i.e. those pharmacists who work less than 20 hours per week). We suggested a reduced fee for young pharmacists in their first five years of practice, as those new to the profession are likely to be paying off student debt and be on a reduced income.
We supported the draft Advertising Guidelines. We suggested wording to ensure it was clearer that these advertising guidelines applied to all forms of advertising or promotion within the pharmacy environment.
These guidelines clarify the expectation that pharmacists must maintain the professional image of pharmacy when they are promoting or advertising on the internet, regardless of whether it is their own pharmacy website or by other online media. The finalised Guidelines were published in January 2014.
The Guild agrees that non-assessed learning should be integrated into the recertification framework and recommends that the proposed learning peer relationship be optional.