The PSNI has met all of our Standards of Good Regulation for the second year in a row. However, the problems with the PSNI’s governing legislation are still ongoing but have not impacted on their ability to meet the Standards.
Guidance and Standards
We carried out a targeted review of three out of four of these Standards to understand how registrants were meeting and/or interpreting the requirements of The Code: Professional standards of conduct, ethics and performance for pharmacists in Northern Ireland, what additional guidance was being provided to registrants and how stakeholders had been consulted. We especially wanted to understand how registrants were interpreting wording around not providing a service requested (see our review of the General Pharmaceutical Council for more details). We also wanted to understand how the PSNI:
- considers if specialist guidance is needed to assist registrants in matters relating to religion, personal values and beliefs
- takes account of the views and experiences of stakeholders when it develops and/or revises its guidance and standards.
During a consultation, registrants had indicated their need for additional guidance on several topics, including duty of candour and the use of social media. The PSNI told us that since publishing The Code in March 2016, it has issued or revised guidance and supporting materials to help its registrants. The process for any new or revised guidance includes engaging with patient groups, pharmacists, pharmacy representative bodies and other regulators to get their feedback. The information provided to us during our targeted review means we are reassured and concluded that the PSNI met all four of the Standards under Guidance and Standards.
Education and Training: action is taken if any concerns are identified
The PSNI has demonstrated what action it takes if any concerns about education/training establishments come to light. In February 2017 evidence suggested that some organisations were not complying with its pre-registration training programme. These concerns were investigated – one organisation appeared not to be meeting the standards. The PSNI and the organisation involved resolved the concerns and the PSNI’s July 2017 newsletter included an article about how to comply with standards for pre-registration training as well as highlighting how to raise any concerns.
Registration: only those who meet the regulator's requirements are registered
We check a sample of registration entries. Usually these relate to fitness to practise register updates. As, the PSNI has so few fitness to practise cases, we broadened our check for registrants failing to comply with continuing professional development requirements/non-payment of registration fees. We found errors relating to six non-paying registrants who were still registered. We asked the PSNI to rectify the errors and explain how this had happened. They investigated and explained that, though all the paperwork was correct, the database had not been updated due to staff absence. The PSNI has updated its operating procedures and made staff aware of what needs to be done to make sure that the register is up-to-date. As immediate action was taken to rectify the errors, we considered that the Standard was met.
Fitness to Practise: process is transparent, fair, protects the public
We have not seen any evidence that the PSNI is not operating a fitness to practise process that ensures the public are protected. In this year, the PSNI has published guidance for its clinical advisors, as well as for its Statutory Committee. We note that the review of its indicative sanctions guidance is ongoing. We also noted that the PSNI has strengthened its quality assurance of the fitness to practise process, with reviews of all decisions to close cases at the initial stages of an investigation.