Mansi Shah, Clinical Pharmacist, elaborates on registration renewals of pharmacists and opines that they should be based on evaluating competence, skills and objective appraisals by continuous professional development appraisers of the regulatory authorities and not simply on employer opinions
Every responsible pharmacist in India and especially, qualified competent clinical pharmacists with necessary skills and a drive to contribute to and improve the eventual stage of pharmaceutical care delivery, that every pharmacist ideally works towards, would salute to these developments.
We still have a long way to go. There is immense need for improvement, creating opportunity for practising pharmacists and continued development. Continuing education (CE) and continuous professional development (CPD) ought to be introduced in education and training years. Registration to practice should make this mandatory for every pharmacist in every sector with each of the degrees acceptable towards registration. Education and training with CPD inculcated from the beginning would lead pharmacists in India to become responsible healthcare professionals. CPD standards and evaluation procedures should be laid down by the regulator and CPD should be made mandatory. Assessments and appraisals of CPD should be conducted at regular intervals by the regulatory authorities directly. Registration renewals should be based on evaluating competence, skills and objective appraisals by CPD appraisers of the regulatory authorities and not simply employer opinions.
Pharmacy Practice Regulations 20153 states that for renewal of registration, pharmacist shall attend a minimum of two refresher courses in pharmacy, having a minimum of one day duration each within a span of five years, organised by PCI, state pharmacy councils, central government/ state governments or a professional body recognised by the Council, and maintaining good pharmacy practice. The question remains on how state pharmacy councils will be reviewing attendance to these not just through certificates and learning. It is important that this additional learning, competence and skills gained are assessed appropriately. Procedures have to be standardised to evaluate objective and subjective learning skills, including critical appraisal skills for clinical evidence and competence. Pharmacists should be professionally competent to interpret evidence and as relevant support prescribing and therapeutic management towards medicines optimisation and improved healthcare. Thus, it is important that pharmacists are assessed appropriately and registration to license is sound.
There are awareness of issues regarding registration and its misuse. Adding to this, lack of one specific countrywide regulated subjects’ specific and pharmacy law (variability in case of state specific differences in pharmacy law) examination and pre-registration training towards pharmacist registration in our country.
A question thus arises about our assessment as competent health professionals to allow practice and registration rather than being told to surrender our registration when being registered elsewhere. A regular assessment or review of pharmacists’ practice and competence by regulatory bodies, at a set time of every specific few years, may be a better way for authorities to gauge competence, awareness of local regulations and legalities can ensure adequate practice for pharmacists within India and overseas.
Professional incompetence is said to be judged by peer group as per guidelines prescribed by the PCI. But, there is lack of practice or a clear process to evaluate experience or competence of a pharmacist requesting registration or renewal.
Introduction of internship with Pharm D4 is a major step and we hope every student who has the opportunity of this degree makes in to be a responsible pharmacist with hands on training. Significant initiatives have been taken by the PCI and state councils and academic pharmacy institutes to support bridging the gap between career and education, and refresher courses for pharmacists ‘in-service’. Examples include HK College of Pharmacy’s initiative ‘Involve to evolve’ to provide continuous practice-based guidance and support to students from such mentors, and Gujarat State Pharmacy Council sponsored refresher course organised by the SAL Institute of Pharmacy for ‘in-service’ pharmacists6. Learning in India is based on current health needs, demands and scenario, and practice is foremost to our healthcare and professional development. Further to this, we need a standardised process of assessing currently registered and practicing pharmacists. This would lead currently registered pharmacists being appropriately assessed prior to registration renewal.
With reference to the first of these two articles about pharmacists’ registrations and renewals
(See link: http://www.expressbpd.com/article/pharma/management-pharma/pharmacists-registrations-and-renewals/231356/), permanent move of pharmacists to other countries will predominantly lead those individuals to not renew their registration. These moves mostly remain ‘only on paper’ and the ‘unwritten’ regulations, drive people away from our country and lead us, other health professionals and the public to not take the profession seriously. The same individuals when in a different country with strict regulations, reviews and recognition as professionals either completely abide by the profession to be responsible registered and practicing pharmacists or leave the profession out of choice.
It is unlikely that a pharmacist registered and working in a different country will attempt misuse of his pharmacist registration in India. This may only lead to him/ her being stuck of his registrations elsewhere too. It is essential that pharmacies in India are inspected appropriately, regularly and on ad hoc basis to gauge the presence of the said registered pharmacist. This may lead to a better review of practising pharmacists in India and those working intermittently in different regions. As already mentioned in the first article on pharmacists’ registrations and renewals, pharmacists with registrations in more than one country may be better, may be more appropriately placed on a different register for such pharmacists and registration details in brief on their certificate rather than striking off practising pharmacists off the register in India.
One should be aware of the competence and skills of some pharmacists who may have maintained practising licenses in more than one country. In addition to self-appraisal, wider practice exposure and skill mix contribute to development in training and practice. CE and CPD requirements and strict assessments for registration and appraisals by licensing authorities every few years towards renewal demand and contribute to sound foundation and competence. In the current healthcare scenario and globalization in every aspect, why is a clinical pharmacist not allowed to work globally in different countries and develop skills to enhance development of better patient care world-wide?
As an example, the US has stringent requirements for professionals to undertake CE, continuing professional education (CPE) and continuing medical education (CME) with differences in requirements in different states laid down and monitored by professional organisations and regulators7.
Like the PCI with state pharmacy councils, General Pharmaceutical Council (GPhC) in the UK, The PEBC in Canada and NABP in the US with boards of pharmacy in each state, are responsible for pharmacy registration/ licensure to practice. The GPhC, the regulator for pharmacists in the UK, has a statutory duty to ensure that pharmacy professionals practice safely and effectively. For this, CPD standards, framework, rules have been laid to enable pharmacists to demonstrate skills and knowledge update and their competence towards continuously improving practice. To support this, GPhC has approved a format of recording CPD and make this possible through an online system or as hard copies. To complete this cycle and enable professionals restarting the process, pharmacists’ CPD records are reviewed at least once every five years8. CPD within Australia and New Zealand follows a model similar to the UK7.
National Pharmaceutical Association (NPA) in the UK supports CPD through a web-based learning service and provision of training courses9. The Centre for Pharmacy Postgraduate Education (CPPE) also supports pharmacists through professional development and CPD10. With PEBC as the regulator in Canada, CE in pharmacy is coordinated by the Canadian Council on Continuing Education in Pharmacy (CCCEP)11.
In the US, NABP supports pharmacists to ensure high standards of pharmacy practice and state pharmacy boards are responsible for licensure12. The Accreditation Council for Pharmacy Education (ACPE) sets standards for the education of pharmacists to prepare them for the delivery of pharmacist-provided patient care. According to a 2015 Survey of Pharmacy Law, 53 boards of pharmacy require pharmacists to participate in CPE activities as a prerequisite for license renewal. NABP, ACPE and ACPE providers have developed a CPE monitor (online system) as a format and mode for pharmacists to record and submit their CPE from accredited providers which can then be submitted when pharmacy boards request reports on licensees12, 13.
In India, PCI and a percentage of the pharmacy fraternity realise the need, implications and benefits of these requirements and may work slowly towards the same goal. But it takes each one of us to work towards this professionalism and our regulators to set professional and CPD standards, framework and rules and assess each of us pharmacists to become responsible and true professionals. Stringent assessments should be mandatory for pharmacy registrations and renewals.
Our President (2015)1 has highlighted that the council continues to put its efforts to address difficulties faced by pharmacists. Thus, with our professionalism in stride and responsibility to pharma care provision, I request our President to allow opportunities to our competent, skilled, ‘responsible’ practice pharmacists striving to make a difference clinically and develop professionally continuously.
In his message (2010)2 which is even today available as the President’s message on the PCI website, he mentions ‘updating knowledge bank of our pharmacists’ through refresher courses and material from Commonwealth Pharmaceutical Association, London, and talks about promoting continuing education and exchange programmes between countries. This clearly indicates that Council and office bearers are all aware of the need for our profession to learn from each other within the country and globally. Then why do we take a step back and not allow this. Our own pharmacists from within the country and elsewhere could contribute significantly and that registration in more than one country leading to a wider range of professional experience would enhance our competence, skills and understanding of world health scenarios and present a better approach to healthcare management.
India is a vast country and reading this article may lead my peers, officials, regulators, council members, inspectors and other healthcare professionals, patients and the public to believe this to be one more write up with no action. But it takes each one of us to work towards achieving this goal. Pharmacists are healthcare professionals and it is high time that they take this as a business start realising otherwise. It is for our council and regulatory bodies to enable this to happen with us being professional and responsible pharmacists. I contribute individually and create this awareness as an independent clinical pharmacist and work on a one-to one basis. There is a need for all of us to act responsibly and our regulators to demand, review and assess competence, skills and knowledge base to be registered pharmacists (practicing register). Pharmacy premises should be permitted with registration only with specifics of the registered pharmacist present on site stated and requirement for the council to be informed with each change.
Individuals need to realise that pharmacy is a healthcare profession and ones responsibility in choosing and pursuing pharmacy. It is high time regulatory bodies start taking registration of pharmacists and premises more seriously as professionals and premises proving professional services, respectively. Regulatory bodies also should look into the registrations because an application has the said ‘documents’ and pharmacists have ‘degrees’ and the required ‘said training thereafter ‘from the endless pharmacy colleges and courses that have sprouted in our country’.
1. Market. Interview: Dr B Suresh (Vice Chancellor, JSS University, Mysore and President, PCI) (2015) We expect as many as 8000 delegates to participate in the event’ Express Pharma (Usha Sharma), Nov 16-30.
2. Pharmacy Council of India (2010) President’s message. Accessed via: http://www.pci.nic.in/PresidentsMessage.aspx (accessed 21.04.2015)
3. Pharmacy Practice Regulations (2015) http://www.pci.nic.in/Circulars/Pharmacy%20Practice%20Regulations.pdf (accessed 02.12.2015)
4. Pharm.D. Regulations 2008. Published in The Gazette of India, No.19, PART III, SECTION 4] Ministry of Health and Family Welfare (Pharmacy Council of India) May 10, 2008. Accessed via: http://pci.nic.in/PDF-Files/PharmD-Revised-A.pdf (accessed 02.12.2015)
Notification of Pharm D Regulations framed under section 10 of the Pharmacy Act, 1948. Accessed via: http://www.pci.nic.in/PDF-Files/14-126circular.pdf (accessed 02.12.2015)
Guidelines for Pharm D Internship. Accessed via: http://www.pci.nic.in/PDF Files/Guideline%20for%20Pharm.D.PDF (accessed 02.12.2015)
5. The Pharmacy Act, 1948 (http://www.ipapharma.org/pdf/Pharmacy_act_1948.pdf) The Pharmacy Act, 1948 is meant to regulate the profession of Pharmacy in India. Accessed via: The Indian Pharmaceutical Association website under Regulations and Guidelines http://www.ipapharma.org/Regulations.aspx (accessed 02.12.2015)
6. Mukne A (2015) Campus News. Pharma Times 47(10), 34-5.
7. The CPD Standards Office (2016). CPD Accross the Globe. Accessed via: https://www.cpdstandards.com/cpd-across-the-globe/ (accessed 01.01.2016)
8. General Pharmaceutical Council (GPhC) (2015) Continuing professional development. Accessed via: https://www.pharmacyregulation.org/education/continuing-professional-development (accessed 21.12.2015)
9. The CPD Standards Office (2016). CPD Sector Requirement. Accessed via: https://www.cpdstandards.com/sector-requirements/sector-requirement-search/?_sft_category=medical-healthcare; www.npa.co.uk (accessed 01.01.2016)
10. CPPE (2016) Crown Copyright. Accessed via: https://www.cppe.ac.uk/support/support (accessed 02.01.2016)
11. PEBC (2015) Accessed via: www.pebc.ca/index.php/ci_id/3149/la_id/1.htm#Information about Continuing Education (CE) Learning: (accessed 30.12.15)
12. National Association of Boards of Pharmacy (NABP) (2016) Pharmacists. Accessed via: www.nabp.net/pharmacists (accessed 02.01.2016)
13. National Association of Boards of Pharmacy (NABP) (2016) Pharmacists: CPE and License Renewal. Accessed via: www.nabp.net/programs/cpe-monitor/cpe-monitor-service/pharmacists (accessed on: 02.01.2016)