Pharmacies are beginning to report on their experiences of the new style inspections from the regulator. An outcomes-based approach means that pharmacies now need to demonstrate to an inspector how standards are being met, rather than showing that a standard operating procedure is complete, has been read and is in a file. The inspector may discuss areas of patient care and pharmacy operations with any member of the team – routinely involving pharmacy staff with the inspection process for the first time.
It’s all very different for pharmacy teams, says Numark’s pharmacy services director Mimi Lau. And because the new inspections are unannounced, this gives independents in particular a challenge to be ready and prepared, she tells P3.
Numark has invited any members that have had an new-style inspection in recent months to share their result with them, so they can monitor trends and offer advice and support if needed. Inspectors can award a pharmacy a ‘Poor’, ‘Satisfactory’, ‘Good’ or ‘Excellent’ grade. Ms Lau says that most of the pharmacies that have been in touch have been given the same grade – Satisfactory.
‘From the feedback that we’ve had some have been ‘Good’, but most have been ‘Satisfactory’ and a few borderline Satisfactory to Good. This doesn’t surprise me, because a lot of the trial inspections over last summer also came out as Satisfactory. I’d say don’t be too hard on yourself if that’s what you get.’
Although everything has changed with inspection in many respects, she wants to reassure independent pharmacies that they can be successful, as long as they prepare beforehand.
‘Don’t be concerned. A lot of it is about planning and preparation before the inspector calls. But if you do have an inspection that doesn’t meet the requirements then come and talk to us.’
She says she has not had any members reporting that they’ve been graded as Poor, so far. But the team is ready to offer support and advice for making any changes that GPhC may ask for, should that happen.
However, she has detected some disappointment from pharmacies that consider themselves Good, yet received a Satisfactory rating. This is going to raise questions. ‘It could be demotivating. I can see people saying, ‘I believe that I’m a good pharmacist. I’ve put everything in place, yet you’ve marked me Satisfactory. Why is that?’
There is perhaps added pressure to achieve a good result on inspection, because GPhC has plans to publish pharmacy gradings and make them available to the public. What will this mean to pharmacies, and how might customers respond?
Ms Lau says that it is difficult to look ahead, but pharmacies that receive a Satisfactory grade have nothing to fear.
‘One member said to me that he felt Satisfactory bordering on Good was actually fine for him. He felt that his customers like his pharmacy and that they receive a good service. He didn’t feel that people will stop coming to him if he’s not an Excellent. I think that’s a really good point – although you will need to think differently if you were given a Poor grade.
Will pharmacies even strive for Excellent, she asks? So far, she says that she hasn’t seen an aspiration for an Excellent top grade from the people that she’s spoken to. But she says that’s not surprising, as GPhC hasn’t yet outlined what will define the grading.
While being the best is always the right thing to do, attaining the top grade may not be achievable for everyone. ‘Do you really need an Excellent grade, anyway?,’ she comments. ‘I’d say the benchmark is that you want to be Good. At the end of the day you as a patient want to go to a pharmacy that is safe, is good quality and is consistent. And if the pharmacy has been rated Good rather than Excellent, would you a patient really change pharmacy?’
On the downside, in the case of a Poor graded pharmacy that continues to not meet the required criteria, will GPhC use their powers in terms of sanctions and suspensions?, asks Ms Lau. Are there many poor quality pharmacies? ‘There are some I would say. I expect we’ve all been to some in the past.’
Similar to other support organsations, Numark has been running events with members to help them prepare.
Most concerns raised by members have been around staff matters, she says. ‘I think what concerned most of our members, was, oh my goodness, they are going to talk to my staff. What are they going to ask, and are my staff going to be able to answer?’ Staff do need to get involved and be aware of what the inspections are all about, says Ms Lau. In response to this Numark has produced a guide for staff.
‘One of our members trialled the new inspection and their staff were asked ‘Do you have a whistle-blowing policy’? They then needed to explain that more fully because the term wasn’t familiar. ‘I think the inspector needs to consider how they talk to staff, how they ask questions and what they are looking to elicit,’ she suggests.
Another pharmacy has fed back that staff were asked about targets for services and if they felt their views would be heard if they had concerns.
Some pharmacies have enjoyed the experience. ‘We have also had positive feedback from pharmacies – saying that they felt it was a lot more engaging than previous visits, it was nice that they came and talked to the staff and that the approach was inclusive.’
Pharmacies are advised to do some work around gathering the evidence, ready for an inspection, she suggests.
‘Look at the five principles and gather your ideas about what fits around each principle.’ Advice along these lines in the form of events and materials has had ‘really good uptake with pharmacies,’ she says.
‘Some pharmacies don’t have staff appraisals for example. And obviously have your SOPs up-to-date.’ Recognise that the inspector is looking at your pharmacy with the patient’s perspective in mind, she says. ‘Think about your patient satisfaction survey and how you engage with patients: do you ask what their needs and wants are?’
The front of shop is also a key area of focus from the customer’s perspective. ‘Principle five of the standards is around premises and this is an opportunity to look at your shop – to think about some of the principles of retailing, customer service, signposting, merchandising, planograming and layout. Does your pharmacy look inviting to customers?’
Numark is launching a retail strategy to support members update this side of their business. ‘When the customer comes into the pharmacy, what do they see? They see the front of shop, and if it doesn’t look professional, modern, friendly or clean they may think ‘I don’t want to be coming here for my prescriptions’. Is the environment inviting; is there good service? It’s the first thing they see.’
A renewed focus on patient safety and customer satisfaction through the new inspection approach means that many pharmacies may want to look again at advice offered to customers by the whole pharmacy team. With the Which? report still ringing in pharmacy’s ears, Ms Lau says that a future focus could be on medicines counter assistants in particular.
‘I do believe there needs to be some kind of framework for healthcare assistants to work towards,’ she says. How do pharmacies ensure that medicines counter assistants are up to date and are giving the best advice? she asks. ‘What is it that you are doing to continuously train and educate yourself to remain competent? We are demanding a lot of MCAs, but where is that check and measure?
Generally, the multiples have been better at supporting staff in ongoing training. ‘They have a resource and they produce materials that every team member has got to complete for continuous learning. In independent pharmacy this is much more variable. I’m sure that there are independents out there who don’t have this structure set up,’ she says.
She suggests Numark’s Counter Excellence module as a useful resource for pharmacists to help support staff. ‘MCAs can sign up, do the monthly assessment online and receive a training record and portfolio they can use when it comes to their appraisal.’
Could a pharmacy have all procedures right and still not do well based on company culture or similar? ‘Yes, it’s absolutely not about ticking boxes any more. The focus is on patient safety and continuous learning and review. How do you learn from a complaint or a mistake and how do you share that? What would you do if this sort of situation occurred? It’s a real step-change to previous inspections.’ Ultimately, is the new approach to inspection good for pharmacy, and good for independents? ‘If it raises the quality of pharmacies and it maximises patient care and safety, yes absolutely,’ says Ms Lau.