Ask the expert: Locum pharmacists and PGD services, where does responsibility sit?

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As a consequence of the expansion of community pharmacy services, the role of locum pharmacists has become more complex. Meanwhile, pharmacy technicians now play a greater role in delivering clinical services, including supplying or administering medicines under patient group directions (PGDs).

This raises an important practical question: when a locum pharmacist is acting as the Responsible Pharmacist (RP), where does their responsibility begin and end when a pharmacy technician is delivering a PGD service?

Changes to the Human Medicines Regulations 2012 mean that registered pharmacy technicians in Great Britain can supply and/or administer medicines under a PGD, provided both the individual pharmacy technician and the service meet the requirements of the relevant PGD.

Where the PGD allows it, a suitably trained and authorised pharmacy technician can assess whether a patient meets the inclusion and exclusion criteria, and supply or administer the medicine themselves.

The presence of a pharmacist does not mean that the pharmacist automatically takes over responsibility for the pharmacy technician’s clinical decisions.

Pharmacy technicians remain accountable for their practice

A registered pharmacy technician remains professionally accountable for the decisions they make and the care they provide. They must work within their competence, follow the PGD and relevant service specification, keep appropriate records and recognise when a patient falls outside the PGD and needs to be referred or escalated.

NHS England takes the same general approach with community pharmacy services: pharmacists and pharmacy technicians are registered clinical professionals and remain responsible for the appropriateness of the consultations they carry out and the medicines they supply.

That does not, however, mean that locum pharmacists have no responsibility for what is happening in the pharmacy.

Locums as RPs

When a locum pharmacist is signed in as the Responsible Pharmacist, they take on the statutory and professional responsibilities that come with the safe and effective running of the registered pharmacy.

The key distinction is between responsibility for another registered professional’s individual clinical decisions and responsibility for ensuring that the pharmacy is operating safely.

A locum should therefore satisfy themselves that any services being provided during their period as RP can be delivered safely. They should know what services are running, who is providing them and what arrangements are in place if something needs to be escalated.

Where a pharmacy technician is providing a service under a PGD, a locum RP should consider questions such as:

• Is the pharmacy technician registered, appropriately trained, competent and authorised under the current PGD?
• Is the PGD current and applicable to that pharmacy and service?
• Are suitable consultation facilities, medicines, equipment and emergency arrangements available?
• Are records being completed properly?
• Does the pharmacy technician understand when a patient needs to be referred?
• Are appropriate SOPs and governance arrangements in place?

The RP should not simply assume that a service is safe to run because the pharmacy owner has commissioned it.

What if the locum has concerns?

This is where professional judgement is particularly important.

If a locum pharmacist identifies a genuine patient safety concern, they should raise it and take appropriate action. Unsafe practice should not be allowed to continue simply because it was already in place before the locum started work.

Equally, an RP should not unnecessarily prevent a competent, registered pharmacy technician from working within their lawful scope of practice simply because the RP might personally have approached the consultation differently.

The sensible approach is to seek assurance that the service is safe and properly governed, rather than automatically repeating or taking over the pharmacy technician’s clinical assessment.

Clear accountability essential

Modern community pharmacy practice increasingly relies on effective skill mix. Enabling pharmacy technicians to work under PGDs can free pharmacists to focus on other clinical responsibilities, but only where roles, responsibilities and governance arrangements are clear.

For locums, the practical position is straightforward: pharmacy technicians are accountable for their own professional and clinical decisions, while the locum RP remains accountable for their own responsibilities in relation to the safe and effective operation of the pharmacy.

Responsibility does not simply transfer from one registered professional to another.

Before accepting responsibility for a pharmacy that provides PGD services, locums should understand how the services operate, satisfy themselves that the relevant governance arrangements are in place and be clear about where their own responsibilities begin and end.