Research in Social and Administrative Pharmacy
Volume 2, Issue 3 , Pages 408-419, September 2006

Governance and the pharmaceutical workforce in England

The Workforce Academy School of Pharmacy and Pharmaceutical Sciences, University of Manchester, Manchester, M13 9PL, UK

Article Outline

Abstract 

A key component of a commitment to patient safety is ensuring the fitness to practice of health professionals. This article uses the changing landscape of the regulation of the pharmaceutical workforce and the extended roles and responsibilities of pharmacy practitioners in England to explore the challenges for governance within contemporary pharmacy practice, and consider the powers and structures necessary for effective regulation. In England, it is recognised that the approach of the national regulatory body for pharmacy should be consistent with that of the regulators of other health professions, and focus on assuring the competence and performance of practitioners. Pharmacy employers will have complementary adjunct responsibilities. Attention is being concentrated on ensuring the continuing fitness to practice of health professionals, with regular revalidation certain to become a requirement for all. Particular challenges arise in the effective regulation of advanced practitioners, and in ensuring the continuing competence of prescribing practitioners, who in England may come from a range of health disciplines, including pharmacy, and practice in a variety of settings and circumstances. A separate professional register is to be established for pharmacy technicians, whereupon they will also have to demonstrate continuing competence to practice, and be subject to regulation in the same way as pharmacists. Significant change is also planned in the professional control of community pharmacies. In future the law will require a “responsible pharmacist” to be identified for each community pharmacy, rather than insisting on a pharmacist always being present to supervise the dispensing and sale of medicines.

Keywords: Governance, Regulation, Workforce, Pharmacy, Pharmacists, Fitness to practice, Competence, Revalidation, Skill-mix, Pharmacy technicians, Community pharmacy, Advanced practitioners, Policy

 

Given the scope for harm arising from incompetence or negligence of a health professional, most developed countries have public protection legislation that requires health professionals (including pharmacists) to be licensed or registered. This responsibility is commonly discharged by national or local governments, eg, State Boards of Pharmacy, or sometimes, as in England, through professional institutions.

The arrangements for national regulation of the pharmaceutical workforce have remained unaltered for a generation of pharmacists in England, despite large demographic changes in the profession1 resulting in the majority of pharmacists now being employees and female, and many working as locums. In 1986, the Nuffield Committee of Inquiry2 undertook a comprehensive review of pharmacy and made a series of significant recommendations, particularly concerned with the governance and operation of community pharmacies, where the majority of the workforce practice.

However, it was not until 2000 that the Government launched a major reform program for pharmacy within its modernization agenda for the state-funded and managed National Health Service (NHS).3 The agenda was unequivocally patient centered, of which patient safety was a key aspect. Strengthening professional regulation, ensuring continuing competence to practice of the pharmaceutical workforce, and quality assurance of NHS pharmaceutical services, were all important components of the national implementation plan.

In the last 5 years, 2 national inquiries—one involving medical incompetence4 and the other criminal intent5—have focused particularly on ensuring the fitness to practice of health professionals, and strengthening professional regulatory machinery.

By describing the main features of the contemporary changes to the legislative framework for pharmacy in England, the purpose of this article is to

(a)consider key aspects of modernizing the regulation of the pharmacy workforce, aided by the insights of 2 major inquiries;

(b)consider fitness to practice at different levels of practice, in different specialisms, and internationally; and

(c)describe the reengineering of the arrangements for discharging pharmaceutical accountability in community pharmacy.

Back to Article Outline

1. Orientation 

England has a national healthcare delivery system, the NHS, for which the Government Department of Health is responsible. Few individuals in England use private medical schemes, except elective surgery, assisted reproduction, and cosmetic procedures. Primary care services are provided by individual contractors operating within a national contract. In the case of community pharmacy, the contractors range from independent community pharmacists owning a single pharmacy to chains with over a 1000 pharmacies and employing many thousands of the pharmaceutical workforce.

A new national contract for community pharmacy was introduced in April 2005 with contractors being remunerated for a wide range of pharmaceutical services.6, 7, 8 From April 2006, accredited pharmacists (and nurses) will have full prescribing rights, ie, legally they will be able to prescribe any licensed medicine for any medical condition.9 These changes in roles and service provision by pharmacists are occurring against a background of shortages in the pharmacy workforce.

Back to Article Outline

2. Modernizing the regulation of the pharmacy workforce 

In 2001, a wide review of the competence and regulation of all health professionals, which had a national impact, was prompted by an investigation into a failing regional pediatric cardiac surgery unit.4 Two observations in the inquiry report are particularly important in a review of governance of the pharmacy workforce:

(a)“Acquiring and maintaining professional competence involves collaboration between the individual, the educational institutions, the employer, and those who set and enforce standards of professional competence” (para 6);

(b)“The arrangements to ensure that health care professionals maintain and develop their competence… are currently fragmentary and apply differentially to the various groups of professionals” (para 48).

These pose significant challenges for the regulatory bodies of healthcare professionals.

In England, each of the major healthcare professions, eg, medicine, nursing, pharmacy, has its own individual independent regulatory body that has been separately established in law. The regulatory body in England for pharmacy is the Royal Pharmaceutical Society of Great Britain (RPSGB). From 2003, an overarching body, now called the Council for Healthcare Regulatory Excellence has been established with a mission “to protect public interest, promote best practice and achieve excellence in relation to the regulation of health care professionals.”10 It is charged with reviewing the performance of the 9 separate health regulatory bodies that it oversees.

Currently, RPSGB has general powers to control entry to the pharmaceutical register through accrediting pharmacy undergraduate courses and is responsible for the 12-month period of preregistration practice training. Although it can impose the ultimate sanction of removing a pharmacist from the professional register, ie, terminating his/her right to practice, significantly, its powers do not presently extend to issues of competence or performance. Similarly, it currently has no legal basis for excluding a pharmacist from the professional register on health grounds—other than if he/she has committed an offence—or powers to supervise the rehabilitation of a lapsed pharmacist.

Encouraged by Government3 and the “Kennedy” report,4 RPSGB has begun a process of modernization from 2005 by

•restructuring its Council to include a significant lay minority;

•separating the components of policy making, investigation, and adjudication within its regulatory machinery;

•requiring registered pharmacists to make a declaration that they are either practicing or nonpracticing; and

•requiring practicing pharmacists, under the RPSGB Code of Ethics, to comply with the continuing professional development (CPD) framework.11

However, before the necessary statutory changes had been made to empower RPSGB to have the range of authority required for a modern health regulator, it was overtaken by a second medical inquiry.5 The Shipman Inquiry has resulted in the Department of Health establishing 2 reviews of health professional regulation: one medical and another nonmedical. The review of the regulation of nonmedical healthcare professions (The “Foster” Review) has included in its remit

•the demonstration of initial and continuing fitness to practice;

•fitness to practice investigations;

•new and extended professional roles; and

•the regulation of healthcare support workers.12

Each of these is important to the regulation of the pharmacy workforce and will influence the legal powers that could be invested in RPSGB as the pharmacy regulatory body.

2.1. Revalidation: ensuring continuing fitness to practice 

The Shipman Inquiry arose from a general medical practitioner who was found to have murdered many elderly patients, each with a single opioid analgesic injection. Not surprisingly, this Inquiry again focused interest on the detection and management of poorly performing doctors. Its conclusion was unequivocal: anything that fell short of a system of revalidation for medical practitioners, entailing “a summative evaluation of each individual doctor's fitness to practice,” would be unacceptable.5 In the wake of the Inquiry, strong arguments for reforming the regulation of health professionals are being made,13 and careful consideration being given to the practical issues of revalidation within the medical profession.14

The issue of revalidation as a process for determining continuing fitness to practice would present a challenge for the pharmacy regulator in England. Introducing a CPD requirement to remain on the RPSGB practicing register coincided with a significant number of pharmacists choosing to join the nonpracticing register in 2005.15 However, elsewhere, the Ontario College of Pharmacists has a well-established program of revalidation,16 and from 2006 the Pharmacy Council of New Zealand is introducing a process of assessed recertification prior to issuing practicing certificates.

Back to Article Outline

3. Ensuring fitness to practice: a multifaceted challenge 

3.1. Primary licensure 

The “Foster” Review is currently considering whether more rigor needs to be introduced to the process of demonstrating fitness to practice at first registration.12 Currently, admission to the pharmaceutical register requires candidates to have graduated from an accredited pharmacy undergraduate course, undertaken a 12-month supervised training program covering aspects of hospital and community practice, and passed the registration examination. They are also required to be of “good character” and in “good physical and mental health,” be over 21, and pay the registration fee.

In 2002, RPSGB commissioned an expert group to develop a research and development agenda for pharmacy education. This it did in its report, “Making Pharmacy Education Fit for the Future.”17 In considering preparation for initial registration, the report notes a relative lack of

(a)integration of education (related to underpinning knowledge) and training (related to the development of clinical skills and professional attitudes); and

(b)formal education, training, and assessment of key attitudes and behavior required of an autonomous clinical practitioner.

3.2. Specialist practitioners 

Generally, RPSGB does not restrict the professional area, or practice setting of registered pharmacists, so allowing practitioners considerable mobility within the profession.18 This contrasts with medicine and nursing, where registers are maintained for specialist practitioners, eg, in mental illness or obstetrics, who have demonstrated competence in their clinical specialty generally following a period of specialist clinical training and supervised practice.

However, the introduction of prescribing rights for pharmacists brought with it the first example of restricted practice for pharmacists in England. To secure the right to prescribe, pharmacists have to demonstrate competence following attendance at an accredited course of training and undertaking supervised prescribing practice.19 Prescribing rights of pharmacists are not further restricted by the regulatory body to specific clinical areas. Instead, the responsibility for limiting prescribing to his/her specific area(s) of competence lies with the individual prescribing pharmacist. These arrangements parallel those for the regulation and safe practice of nurse prescribers.

3.3. Advanced practitioners 

There are no existing arrangements in place to introduce any categories of “advanced practitioner” within the RPSGB register. However, the NHS in optimizing the use of its multidisciplinary clinical workforce has introduced 2 “advanced” grades of clinical practitioner.

Guidelines for implementing a scheme for “General Practitioners with Special Interests” were launched as the first of a series introducing a range of “Practitioners with Special Interests”.20, 21 The latter are seen as pivotal in transferring care in such areas as dermatology, ENT, gynecology, and routine minor surgery from hospital-based services to community settings.22 Criteria are currently being developed for a national framework for “Pharmacists with Special Interests” to be published in 2006.23

At a more senior level, “consultant pharmacist” posts were introduced in 2005 to parallel the consultant posts created in other disciplines.24 The competency framework for consultant pharmacists consists of 34 competencies in 6 clusters: expert professional practice; building working relationships; leadership; management; education, training, and development; and research and evaluation.25 Candidates for consultant posts need to be able to demonstrate competence at the highest level (mastery) for the first 3 competency clusters, and at the intermediate level (excellence) for the latter 3.

3.4. International mobility of pharmacists 

There is free movement of licensed health professionals across the 25 member states of the European Union (EU). This means that pharmacists registered in England have the right to practice in other EU countries, and vice versa. In 2002, around 600 pharmacists who originally qualified in other EU countries were registered to practice in England.26 For free movement of pharmacists across EU, all undergraduate courses in pharmacy have to comply with the European Directive27 and EC Advisory Committee on Pharmaceutical Training,28 which require completion of a minimum 4-year full-time university course.

Given the similarity of practice, particularly in community pharmacy, and the dominance of English as the professional language of pharmacy in the developed countries, it is ironic that the barriers to licensure in countries outside the EU are so high. Eleven percent of pharmacists registered by RPSGB are located abroad.26 The largest group is in the United States where most remained unlicensed. There are currently large numbers of qualified pharmacists from Australia and New Zealand practicing in United Kingdom based on historical reciprocal arrangements, but these ended in June 2006. This is a step in the wrong direction. Overall 6% of practicing pharmacists in England originally qualified abroad.

The evolution of competency-based frameworks for determining fitness to practice should make the assessment and accreditation of pharmacy qualifications easier internationally. This would then allow pharmacists to be as mobile as medical and nursing practitioners.

Back to Article Outline

4. Professional accountability in community pharmacy 

Underpinning the development of NHS pharmaceutical services3, 29 is the process for optimizing efficiency in the community pharmacy workforce, of which one fifth are pharmacists. At the heart of the issue are 2 of the shibboleths of community pharmacy practice: personal control and pharmacist supervision. Legislation controlling the supply of medicines provides a legal requirement for both, but defines neither. However, they have been universally interpreted as together requiring the pharmacist in charge to be always physically present during the operation of the pharmacy, aware of any transactions involving the sale or supply of medicines, and in a position to intervene.

Twenty years ago, The Nuffield Inquiry into Pharmacy questioned the justification for the “personal control” and “supervision” requirements, recognizing that pharmacy technicians could be more effectively used in community pharmacy.2 In Denmark and the Netherlands for example, qualified “pharmaconomists” and pharmacists' assistants can dispense prescriptions without the requirement for a pharmacist to be present in the pharmacy to supervise them.30, 31 So in these countries community pharmacists have the flexibility to provide a range of pharmaceutical services unconnected with dispensing, both inside and away from the pharmacy. Currently, in England, they do not.

The Department of Health, following careful consideration and consultation, is planning to change the law for controlling the operation of community pharmacies'30, 31, 32 policy to maintain the safe and effective future operation of community pharmacies has essentially 3 strands

•redefining the role of community pharmacists, in terms of responsibility rather than location;

•empowering pharmacy technicians; and

•documenting procedures and maintaining records.

4.1. Redefining the role of the community pharmacist 

The new Health Bill proposes a new requirement for each community pharmacy to have a “responsible pharmacist” in charge of the business of the retail sale and supply of medicines.32 Specific requirements will be placed on the responsible pharmacists to ensure that they achieve their statutory duty of “securing the safe and effective running of the pharmacy.” This is important, given the recent study, which indicates that the perceived clinical autonomy of community pharmacists varies significantly between practitioners.33 In particular, it is considered important that the “responsible pharmacist” personally undertakes the clinical assessment of each new prescription and approves the formulation and specification of any medicine that has to be prepared in the pharmacy.

4.2. Empowering pharmacy technicians 

RPSGB—as the regulatory body for the pharmacy workforce—plans to establish a separate register for pharmacy technicians from January 2007. The RPSGB is currently awaiting the legal powers for this, but in May 2005 restructured its Council to include qualified pharmacy technicians. Registered pharmacy technicians would then become independently licensed health professionals, with professional roles and responsibilities of their own and have to meet certain criteria, eg, evidence of CPD participation, to remain licensed.

Several studies have explored skill-mix in community pharmacy34, 35 and the emergence of the concept of a dispensary-based “checking technician.”36 The new Health Bill would allow the delegation of supervision of certain pharmaceutical activities including much of the dispensing workload, to suitably trained and registered health professionals, which in the future will include registered pharmacy technicians.32

4.3. Documentation procedures and maintaining records 

Since January 2005, RPSGB have required pharmacists to implement written standard operating procedures (SOPs) within individual community pharmacies to cover various pharmaceutical operations, including dispensing. SOPs are seen as key instruments in defining procedures and securing the “safe and effective running of a pharmacy.” Ensuring that SOPs are kept up to date will be an important role for the responsible pharmacist. The Health Bill would also introduce the requirement for a “pharmacy record” to identify “the responsible pharmacist” on duty on any day at any time.

4.4. Governance in community pharmacy 

Also enshrined in new NHS legislation covering community pharmacy services is a range of clinical governance requirements, including the power to require community pharmacy contractors to provide information on the fitness to practice of pharmacists providing NHS services.7

Each community pharmacy has to appoint a named clinical governance lead, who does not necessarily need to be a pharmacist. Under the clinical governance framework, each pharmacy has to undertake a patient satisfaction survey and 2 clinical audits annually as well as implement an approved incident reporting system. Analysis of critical incidents is seen as important in informing both individual and organizational learning to enhance patient safety, but recent evidence suggests a reluctance to report adverse events amongst the community pharmacy workforce.37

Under the new NHS pharmacy contract,6, 7 local health authorities will undertake regular inspections of community pharmacies at which contractors will need to present documented evidence demonstrating that they are meeting service specifications and clinical governance requirements.38

Back to Article Outline

5. Governance in perspective: the current situation 

This paper explores the important aspects of the regulation of pharmacists and other members of the pharmacy workforce. At the heart of these, are the creation of robust arrangements for ensuring fitness to practice and appropriate accountability and performance in practice. These are vital to securing public confidence in the pharmacy workforce and optimizing patient safety in pharmaceutical care.

Legislation is now pending on the detail of the regulatory arrangements for the pharmacy profession in England, following the process of statutory consultation on the Government's proposals39 and awaiting the publication of the Foster review.12∗ The enactment of this legislation is fundamental to the regulation of the pharmaceutical workforce, because it will determine the future powers and processes of the regulatory body, currently the RPSGB. These cover (a) control of education and training, and recognition of qualifications, of pharmacists and pharmacy technicians; (b) maintenance of accurate registers of individuals licensed to practice as either pharmacists or pharmacy technicians; (c) determination of professional standards; (d) establishment requirements for maintaining and demonstrating fitness to practice; and (e) undertaking assessments of professional performance.

Local NHS authorities, as either employers of pharmacists or pharmacy technicians, or as commissioners of NHS services, will also have a role in the governance of pharmacy practitioners.

The new health legislation emanating from the Health Bill32 has been approved and awaits implementation.† It will introduce the notion of a “responsible pharmacist” for each community pharmacy and reengineer the discharge of professional accountability to allow the more flexible operation of community pharmacies. It will be interesting to observe how this new legislation is operationalized, and its impact on skill-mix in the pharmacy workforce and the development of pharmaceutical services in primary care.

It is important to reiterate that patient safety is the primary goal for governance of the health professions. Therefore, it needs to be effective, transparent, reflect current practice, and be proportionate to the risk. Kennedy4 has already drawn attention to the need for a collaborative approach to ensuring professional competence and consistency across all the health professions. Now pharmacy regulators need to consider how competent pharmacy practitioners might be allowed to practice internationally, without compromising patient safety.

Back to Article Outline

References 

  1. Hassell K, Fisher R, Nichols L, Shann P. Contemporary workforce patterns and historical trends: the pharmacy labour market over the past 40 years. Pharm J. 2002;269:291–296
  2. Committee of Inquiry . Pharmacy—A Report to the Nuffield Foundation. London: The Nuffield Foundation; 1986;
  3. Department of Health . Pharmacy in the Future—Implementing the NHS Plan. London: Department of Health; 2000;Available at: http://www.dh.gov.uk/assetRoot/04/06/82/04/04068204.pdf
  4. Learning from Bristol: the report of the public inquiry into children's heart surgery at the Bristol Royal Infirmary 1984-1995 (Chair: Professor Ian Kennedy). Chapter 25: Competent health professionals. Cm 5207. London: Stationery Office; 2001.
  5. The Shipman Inquiry (Chairman: Dame Janet Smith) Fifth Report—Safeguarding Patients: Lessons from the Past—Proposals for the Future. Chapter 26: Revalidation. Cm 6394. London: Stationery Office; 2004.
  6. Pharmaceutical Services Negotiating Committee . The New Contract for Community Pharmacy. Aylesbury: Pharmaceutical Services Negotiating Committee; 2004;
  7. The National Health Service (Pharmaceutical Services) Regulations 2005. No 641 Schedule 1: Terms of Service of Pharmacists. London: Stationery Office; 2005.
  8. The National Health Service Act 1977. The Pharmaceutical Services (Advanced and Enhanced Services) (England) Directions; 2005.
  9. Avery AJ, Pringle M. Extended prescribing by UK nurses and pharmacists. BMJ. 2005;331:1154–1155
  10. Council for Healthcare Regulatory Excellence . Annual Report and Accounts 2004/2005. London: Stationery Office; 2005;p. 4; Available at: http://www.chre.org.uk/
  11. Royal Pharmaceutical Society of Great Britain . Medicines, Ethics & Practice—A Guide for Pharmacists and Pharmacy technicians. 30th ed.. London: Royal Pharmaceutical Society of Great Britain; 2006;p. 106
  12. http://www.publications.parliament.uk/pa/cm200405/cmhansrd/cm050317/wmstext/50317m02.htm.
  13. Walshe K, Benson L. GMC and the future of revalidation: time for radical reform. BMJ. 2005;330:1504–1506
  14. Lakhani M. GMC and the future of revalidation: a way forward. BMJ. 2005;330:1326–1328
  15. Hassell K, Eden M. Workforce update—joiners, leavers and practising and non-practising pharmacists on the 2005 register. Pharm J. 2006;276:40–42
  16. Austin Z, Croteau D, Marini A, Violato C. Continuous professional development: the Ontario experience in professional self-regulation through quality assurance and peer review. Am J Pharm Educ. 2003;67:Article 56
  17. Pharmacy Education R&D Reference Group (Chair: Professor Peter Noyce) . Making Pharmacy Education Fit for the Future. London: Royal Pharmaceutical Society of Great Britain; 2004;Available at: http://www.rpsgb.org.uk/pdfs/maphedfitforfuture.pdf
  18. Mullen R, Hassell K, Noyce P. Primary care pharmacist workforce mobility: why do pharmacists want to work in primary care and how do these reasons differ for community and hospital pharmacists?. Int J Pharm Pract. 2005;13:281–288
  19. National Prescribing Centre . Maintaining Competency in Prescribing—An Outline Framework To Help Pharmacist Supplementary Prescribers. Liverpool: National Prescribing Centre; 2003;
  20. Department of Health/Royal College of General Practitioners . Implementing a Scheme for General Practitioners with Special Interests. London: Department of Health; 2002;Available at: http://www.dh.gov.uk/assetRoot/04/07/00/05/04070005.pdf
  21. Department of Health/Royal College of General Practitioners . Guidelines for the Appointment of General Practitioners with Special Interests in the Delivery of Clinical Services—Drug Misuse. London: Department of Health; 2006;
  22. Department of Health . Our Health, Our Care, Our Say: A New Direction for Community Services. Cm 6737. p. 132-135 London: Stationery Office; 2006;Available at: http://www.dh.gov.uk/assetRoot/04/12/74/59/04127459.pdf
  23. http://www.primarycarecontracting.nhs.uk/119.php.
  24. Department of Health . Guidance for the Development of Consultant Pharmacist Posts. London: Department of Health; 2005;Available at: http://www.dh.gov.uk/assetRoot/04/10/74/95/04107495.pdf
  25. Meadows N, Webb DG, McRobbie D, Antoniou S, Bates I, Davies JG. Developing and validating a competency framework for advanced pharmacy practice. Pharm J. 2004;273:789–792
  26. Hassell K, Nichols LA. The national workforce census: (4) Overseas pharmacists—does the “globalisation” of pharmacy affect workforce supply?. Pharm J. 2003;271:183–185
  27. EEC Council Directive: concerning the coordination of provisions laid down by law, regulation or administrative action in respect of certain activities in the field of pharmacy. (85/432/EEC). Off J Eur Comm. 1985; L253/34.
  28. EC Advisory Committee on Pharmaceutical Training. Report and recommendations on pharmaceutical education undergone at higher-education institutions. (XV/E/8341/5/93-EN); 1994.
  29. Department of Health . A Vision for Pharmacy in the New NHS. London: Department of Health; 2003;Available at: http://www.dh.gov.uk/assetRoot/04/07/00/99/04070099.pdf
  30. Department of Health . Pharmacy Workforce in the New NHS. London: Department of Health; 2002;Available at: http://www.dh.gov.uk/assetRoot/04/06/83/54/04068354.pdf
  31. Department of Health . Making the Best Use of the Pharmacy Workforce: A Consultation Paper. London: Department of Health; 2004;
  32. Department of Health . Health Bill Information Paper: Medicines and pharmacies: Making the best use of the pharmacy workforce. Available at: http://www.dh.gov.uk/assetRoot/04/12/62/15/04126215.pdf2006;
  33. Magirr P, Grimsley M, Ottewill R, Noyce P. The clinical autonomy of community pharmacists in England. 1) designing and testing a survey instrument. Int J Pharm Pract. 2004;12:223–229The clinical autonomy of community pharmacists in England. 2) Key findings. Int J Pharm Pract 2004;12:231-238
  34. Hassell K, Shann P, Noyce PR. The complexities of skill mix in community pharmacy. Pharm J. 2002;269:851–854
  35. Mullen R. Skill mix in community pharmacy: exploring and defining the role of dispensary support staff. Sir Hugh Linstead community pharmacy practice research fellowship, 2002. Manchester: University of Manchester; 2004.
  36. Jones W, Rutter PM. The introduction of a checking technician programme in community pharmacy and its impact on pharmacist activities. Int J Pharm Pract. 2002;10(Suppl):R90
  37. Ashcroft DM, Morecroft C, Parker D, Noyce PR. Likelihood of reporting adverse events in community pharmacy: an experimental study. Qual Saf Health Care. 2006;15:48–52
  38. Community Pharmacy Assurance Framework. NHS Primary Care Contracting 2005. Available at: http://www.primarycarecontracting.nhs.uk/114.php.
  39. Department of Health . Pharmacists and Pharmacy Technicians Order 2006—A Paper for Consultation. London: Department of Health; 2006;
  • ∗ The Foster Review has been published since the submission of this manuscript citation details, Department of Health. The regulation of non-medical healthcare professions - A review by the Department of Health London: Department of Health; 2006 http://www.dh.gov.uk/assetRoot/04/13/72/94/04137294.pdf
  • † This new legislation has now been enacted under the Health Act 2006 since the submission of this manuscript. Citation details; Health Act 2006 (c.28); Part 3, Drugs, Medicines and Pharmacies; sections 26-33.

PII: S1551-7411(06)00068-4

doi:10.1016/j.sapharm.2006.07.005

Research in Social and Administrative Pharmacy
Volume 2, Issue 3 , Pages 408-419, September 2006

Article Tools