Submission to: THE EUROPEAN UNION COMMITTEE: SUB-COMMITTEE ON SOCIAL POLICIES AND CONSUMER PROTECTION Call for Evidence: REVIEW OF THE PROFESSIONAL QUALIFICATIONS DIRECTIVE: MOBILITY OF HEALTHCARE PROFESSIONALS Response from the Royal Pharmaceutical Society The Royal Pharmaceutical Society welcomes the opportunity to contribute its views on the important implications of THE PROFESSIONAL QUALIFICATIONS DIRECTIVE. The Royal Pharmaceutical Society (RPS) is the professional body for every pharmacist in Great Britain. We are the only body that represents all sectors of pharmacy in Great Britain. The RPS leads and supports the development of the pharmacy profession within the context of the public benefit. This includes the advancement of science, practice, education and knowledge in pharmacy. In addition, it promotes the profession s policies and views to a range of external stakeholders in a number of different forums. Its functions and services include: Leadership, representation and advocacy: promoting the status of the pharmacy profession and ensuring that pharmacy s voice is heard by governments, the media and the public. Professional development, education and support: helping pharmacists to advance their careers through professional advancement, career advice and guidance on good practice. Professional networking and publications: creating a series of communication channels to enable pharmacists to discuss areas of common interest. The RPS s vision for pharmacy is that pharmacists should be the universally accessible frontline clinical provider of all aspects of pharmaceutical care and be responsible for all aspects of medicines use. Pharmacists aim to be the healthcare professional entrusted by patients to take care of their every pharmaceutical need. Pharmacists are the experts in medicines their management, their usage and information about them. Pharmacists can impact at different points on the patient pathway and lead to a reduction in medicines waste, a reduction in unplanned hospital admissions and better medicines adherence resulting in better patient outcomes. General comments The EU Professional Qualifications Directive has enabled pharmacy employers to recruit qualified pharmacists from across the EU to fill vacancies and to react to local supply and demand for pharmacy services. The experience from the employment of EU pharmacists working in GB is that the eligibility of professionals to practice in GB should be underpinned by developing safeguards in the system to ensure patient safety through sharing fitness to practice information Language and communication skills Need for adaption / in house training prior to becoming the responsible pharmacist Professional Qualifications Directive a response by Royal Pharmaceutical Society Page 1 of 5
Particular questions to which we invite you to respond are as follows: Background: fundamental principles 1. What benefits are derived by healthcare professionals and patients from mobility? 1.1 The ability to have a mobile European pharmacy workforce has opened up new opportunities to meet any local supply and demand problems within pharmacy. However with the accreditation of new schools of pharmacy this issue may well subside naturally with more GB qualified pharmacists being available for the internal GB markets. 2. What risks have you observed arising from mobility and to what do you attribute those risks? 2.1 Fitness to practice 2.1.1 Pharmacist entering from European states must be confident and competent to do so and be satisfied they have had enough exposure to the working practices within GB to have fully obtained that knowledge. The gaining of this knowledge is dependent on pharmacists own personal development and experience and not their primary qualification. 2.1.2 Basing a decision on fitness to practice in a host country purely on the recognition of professional qualification rather than on the skills they need to fulfil their professional requirements is not suitable for the continued development of a modern mobile pharmacy workforce. 2.1.3 Pharmacists registered with The General Pharmaceutical Council need to use their professional judgement and annually self declare that they have undertaken the necessary continue professional development (CPD) to ensure they are competent in the services and systems they are providing, this is checked by the General Pharmaceutical Council on a call and review basis. This level of CPD has been deemed necessary for patient safety and should be consistent across all pharmacists working in GB in addition to the requirements imposed by the Regulator of their country of registration. 2.1.4 A major factor in the working practise of a pharmacist is their ability to apply their professional judgement in the interest of patients and the public. Applying professional judgement can be difficult if not dangerous when your knowledge of a host country s policies and systems and services are not fully known prior to taking up employment in that country. 2.1.5 Professional judgement is underpinned by local knowledge of services, IT systems, enhanced services, local guidelines and organisations, these differ across GB and GB pharmacists have to undertake CPD to gain this supporting knowledge of pharmacy practice in addition to their primary qualification. The failure of the EU directive to acknowledge that this is needed to support a professional s primary qualification now needs to be addressed as a safeguard to the directive. 2.2 Sharing fitness to practice concerns 2.2.1 Patients and pharmacists must have confidence in the European Union to share data on professionals. Pharmacists need to access registration details of doctors, nurses etc, and this information must be accurate and trustworthy. Additionally pharmacy employers Professional Qualifications Directive a response by Royal Pharmaceutical Society Page 2 of 5
need access to registration details and confidence that fitness to practice issues are being dealt with in a constant manner across the EU, as there is presently a risk that some health professionals may seek registration in other parts of Europe when they have been erased or suspended from the register or in order to avoid disciplinary action in their home country. 2.3 Language and communication skills - see response to language competency 3. Where do you think the balance should lie between a regime covering the mobility of all workers, including non healthcare workers, with the objective of maintaining high standards of patient safety? 3.1 Need for adaption / in house training prior to becoming the responsible pharmacist 3.1.1 Patient safety must be the focus of pharmaceutical care and not free movement of professionals. The issues of language/communication and professional competence to practise must be assessed before a pharmacist is allowed to fully register and practise in the GB. This assessment should be through a period of supervised working and not a formal exam type assessment. 3.1.2 All health professionals operating in another member state should undergo a period on adaption to the host country s health care systems. This should include legal, ethical and practice matters, national policies and procedures and supervised learning to understand the nuances of practising as a pharmacist in that country. Automatic recognition 4. How content are you with the system of automatic recognition as currently applied to doctors, general care nurses, dentists, midwives and pharmacists? What suggestions do you have for improvements? Should it be extended at all to any other healthcare professionals? 4.1 To date we are unaware of any issues with the current system that have not been covered in our response to the other questions, namely: adaption/in house training fitness to practise concerns CPD to be undertaken in the host country communication/language skills to be assessed 4.2 The current pharmacy education framework is in the process of being reviewed and it is anticipated that the GB undergraduate curriculum will change to encompass more counselling and communication skills, these changes need to be reflective when cross recognising pharmacy degrees from other EU states Administrative cooperation 5. To what extent do you consider that appropriate systems are in place for administrative cooperation between Member States, particularly as regards the fitness to practise? Professional Qualifications Directive a response by Royal Pharmaceutical Society Page 3 of 5
Language competence 6. Article 53 of Directive 2005/36/EC requires those benefiting from mobility under the Directive to have knowledge of languages necessary for practising the profession in the host Member State. Are you content that this requirement has been applied satisfactorily as regards healthcare professionals and ought it to be strengthened? 6.1 The issue of language competence is of utmost importance for the pharmacy profession and all healthcare professionals working in the European Union. Within the pharmacy profession there is concern around language standards and professional mobility. The ability of the patient, pharmacist, doctor, nurse, to understand one another and to communicate effectively is integral to the delivery of safe and effective care. Pharmacist must be able to communicate with both technical vocabulary, and with language in the context of patient care, this includes the various colloquialisms and expressions with which many migrant health professionals can be unfamiliar. Within the context of pharmacy this is particularly important as pharmacist now undertake more clinical roles and are responsible for counselling and advising patients on their medicines. 6.2 Many medicines are sold over the counter for minor ailments and pharmacist are required to have communication skills that include both everyday expressions and health- related expressions such as euphemisms for part of the body and different words for expressing particular types of pain. These language competencies are difficult to assess in a formal manner and require communication skills in addition to language fluency. 6.3 Healthcare decision making requires that the patient and professional are able to exchange information clearly and freely. Misinterpretations and misunderstandings can have serious consequences and as such we strongly recommend that following recognition of a healthcare primary qualification there should be assurance or evidence of their language, counselling and communication competency. European Professional Card 7. The Commission refers in its consultation paper to the possible introduction of a European Professional Card. What is your response to this suggestion? Under what conditions would it be helpful for healthcare professionals and patients? 7.1 In principle the European Professional Card could be viewed as a good way forward; however there are several practicalities that would have to be addressed to ensure that the bureaucracy involved in producing, checking and updating the card produces benefits by improving safeguards in the current system. 7.2 The Royal Pharmaceutical Society would only support the use of the European Professional Card, if the information exchanged could be reliably authenticated. At present it is unclear in EU member states where regulators do not have the means to electronically share information how the card would be issued and updated, and what use an electronic card would be. 7.3 Data sharing especially around fitness to practice judgments and pending cases is paramount to patient safety. Effort and resources would be best placed in developing solutions to increase patient safety through effective data sharing than in producing a card that may be costly and offer little safeguard to patient safety. Professional Qualifications Directive a response by Royal Pharmaceutical Society Page 4 of 5
Conclusion With changes to Pharmacists professional roles and proposed changes to the undergraduate curriculum it is timely to review the Professional Qualifications Directive. In general we are supportive of the appropriate recognition of qualifications and the rights of professionals to move across the EU; however the system would benefit from safeguards to ensure that professionals are appropriately equipped to work in another health system and patient safety is not compromised. Response prepared by: Paul Gimson, MRPharmS 16 June 2011 Director for Wales On behalf of Royal Pharmaceutical Society 1 Lambeth High Street London SE1 7JN United Kingdom Professional Qualifications Directive a response by Royal Pharmaceutical Society Page 5 of 5