EU Professional Qualifications Directive:
a consultation by DG Internal Market and Services
A response by Alliance Boots
Alliance Boots is a leading international pharmacy-led health and beauty group, which owns and operates pharmacies and full-line pharmaceutical wholesaling businesses in a number of EU and EEA countries.
Our Health & Beauty Division operates community pharmacies in the UK, Republic of Ireland, Italy and the Netherlands, as well as in Norway and Russia. These predominantly trade under the Boots brand. We are the largest pharmacy owner in the UK, with over 2,400 pharmacies situated were people live, work, shop and travel. As well as dispensing medicines, our pharmacies increasingly provide added-value services to the communities they serve, particularly in public health and supporting better use of medicines.
Our Pharmaceutical Wholesaling Division operates full-line wholesale businesses serving community pharmacies, medical practices and hospitals in the UK, France, Spain, Italy, the Netherlands, Czech Republic and Germany, as well as Norway and Russia. We also have joint ventures in Switzerland, Turkey and Egypt.
Alphega Pharmacy is a leading network of independent pharmacists in Europe. Launched in 2001, today it supports more than 3,000 pharmacies across six countries – the Czech Republic, France, Italy, Russia, Spain and the UK. The central aim of Alphega Pharmacy is to help improve the quality of health in communities across Europe by developing a benchmark independent community pharmacy model.
Central Homecare is a high quality provider of clinical homecare services throughout the UK. Its aim is to make the administration of medicines at home as simple and stress-free as possible for patients and their carers, and to meet the goals of healthcare clinical teams.
We actively recruit qualified professionals, predominantly pharmacists, from across the EU for our business making use of the free movement principles of the Single Market and the Professional Qualifications Directive.
Executive summary
o “In market” training The European Commission should make it a requirement for any healthcare professional moving to work in another Member State to undertake a period of supervised training in that Member State before starting to practise unsupervised. [p3-4]
o Language testing Healthcare professionals should be required to demonstrate a high level of fluency in a relevant language before practising in another Member State. [p3]
o Professional cards The introduction of professional cards may enhance free movement. Using the term “professional passport” would give a clearer indication of the purpose of the document. [p4]
o Temporary services There should be a clearer definition of the phrase “temporary provision of services”. [p4]
o CPD The continuing professional development undertaken by healthcare professionals should be relevant to the territory they are operating in as well as to their field of practise. It should be equivalent to the CPD undertaken by registrants in the Member State they are working in. [p5]
Response to consultation questions
NOTE: Not all of the questions posed are relevant to the businesses operated by Alliance Boots. We have supplied general answers to topics where we feel we have appropriate experience and understanding.
Compensation measures and “in market” training
The professional training for pharmacists can be divided into two elements:
o The basic training on the physiology of diseases and the pharmacology of treatments which is broadly harmonised across Europe, through the Professional Qualification Directive and the licensing requirements for medicines, which are also underpinned by European Directives.
o The second element is market specific. It relates to the practice of pharmacy in each Member State, along with the remuneration model and the legal and ethical requirements for each country.
Thus, in the interests of public health and safety, we feel that it is appropriate that pharmacists operating in another Member State should receive appropriate “in market” training on legal and practice matters before they are allowed to work in an unsupervised capacity in that country. In addition, we also believe that pharmacists should be required to demonstrate a high level of fluency in the relevant Member State language (see “Language testing” below).
When Boots recruits pharmacists from other EEA countries to work in our UK pharmacies, we require them to be able to show a high level of fluency in English [ILTS-7 or UBELT-3]. Assessing English language competency is extremely important for the candidate to be assured that they can communicate effectively with customers, patients, staff and other healthcare professionals. As an employer, we have a duty of care towards our customers in this respect.
As a responsible employer, we require EEA pharmacists who pass the language testing, and who satisfy the other requirements of our recruitment process, then undertake supervised practice for up to 12 weeks within one of our pharmacies.
This supervised period is based on a process similar to that required as part of the one-year “preregistration training” undertaken by UK pharmacy graduates wishing to join the Register of Pharmacists maintained by either the General Pharmaceutical Council (GPhC), the competent authority for Great Britain, or the Pharmaceutical Society of Northern Ireland.
The supervised period concentrates on the differences in pharmacy practice in the UK, both legal and ethical, and on how to avoid the most common dispensing errors (such as those caused by medicines with similar product names). At the end of the nine-week period, the supervising pharmacist signs a declaration that the recruit is competent to practice unsupervised in the UK.
We believe that it would be in the public interest for the European Commission to introduce the requirement for a similar period of “in market” supervised training for all healthcare professionals moving to work in another Member State. This would protect public safety by ensuring that these professionals were fully aware of the healthcare environment they intended to practise in, and where this might differ from regulations or customs within their own countries.
A European “professional card”
In general terms, we would find a “professional card” helpful, but we would require further information about how the process would work and where the costs of acquiring such a card might lie.
We suggest that the term “professional passport” gives a better indication of its use, and might allay fears among professionals in Member States that they would have to acquire such a card – at personal expense – simply to remain registered in their own country.
It is also unclear whether this card would be used by those seeking temporary rather than permanent work in another Member State.
Temporary movement for professionals
At present, there are few opportunities for pharmacists to provide professional services in the UK outside of the context of being employed by a contractor to the National Health Service (NHS) or by an NHS body. Hence, we do not have much experience in this area.
However, we share the concerns expressed by the public, professional and regulatory bodies about the potential for healthcare professionals using “temporary” service provision as a way of escaping restrictions placed on their practise by competent authorities in another Member State.
We also share the concerns about making a distinction in practice between “temporary” and continuous service provision in the absence of any formal definition of “temporary”. We feel that this needs to be addressed.
Continuing professional development
Continuing professional development is now a mandatory requirement for registered pharmacists (and pharmacy technicians) wishing to remain on the GPhC register. It is something that the public expect.
We share the concern felt by the public that an EU healthcare professional operating temporarily or permanently in the UK might not be required to undertake the same level of CPD as fully-registered UK professionals. CPD should be relevant to the field of practise, including the territory of practise. We feel that this should also be addressed.
Alerting mechanisms for professional malpractice
Where restrictions have been placed on a healthcare professional’s practise by a competent authority, it is right that other authorities should be able to request or see this information.
However, this information will not be of practical value unless it can be cascaded to known or potential employers, either directly or on request.
In addition, there may be problems in directly replicating specific restrictions on practise, depending on the nature of local legislation or pharmacy operations. For example, narcotics and other medicines subject to abuse may have different levels of legal control in different Member States.
Language skills
Healthcare decision making requires that the patient and professional are able to exchange information clearly and freely. Misinterpretations and misunderstandings can have serious consequences.
As mentioned above, we believe that it is reasonable on grounds of public health and safety that healthcare professionals who wish to work in another Member State should be able to demonstrate advanced-level fluency in an appropriate language. We believe that healthcare regulatory bodies and competent authorities should be in a position to request suitable proof of such fluency before registering them.
Response prepared by:
Jonathan Buisson, MRPharmS
Healthcare Policy Manager
Alliance Boots
Boots UK Support Office
Fern House
53-55 High Street
Feltham, Middlesex TW13 4HU
United Kingdom
15 March 2011
Professional Qualifications Directive – a response by Alliance Boots 1