Of the five topics included in the document, registration pathways and prescribing are our key priorities, as these have the potential to help ease workforce pressures and support the continued development of the sector’s vital growing role.
Innovative practice
We support the concept of innovative practice and encouraging pharmacists to practice to the full extent of their competence.
Enabling pharmacists to expand their practice and develop new services is important for improving access to care and ensuring the profession continues to evolve in response to patient and system need.
However, a high-level statement alone is unlikely to shift practice across the sector or provide pharmacists with the confidence needed to develop and implement innovative services.
To enable pharmacists to adopt innovative approaches in a safe and consistent way, practical tools and clear guidance are required, including supporting pharmacists to upskill, ensuring re-certification expectations are clearly understood, and providing clarity on how innovative practice can occur within existing scopes and professional standards.
Registration pathways
We are keenly aware of the workforce issues impacting community pharmacy and support the Pharmacy Council of New Zealand, our regulator, exploring changes to registration pathways that could enable overseas trained pharmacists to enter the New Zealand workforce more easily and quickly.
We support broadening eligibility for the Recognised Equivalent Qualification Route (REQR) and removing the Competency Assessment of Overseas Pharmacists (CAOP) requirement, where this creates unnecessary cost and delay for applicants.
However, appropriate safeguards must remain in place to ensure patient safety and maintain confidence in the profession, including ensuring overseas trained pharmacists demonstrate cultural competence requirements for practice in New Zealand, as well as completing structured supervision and transparent competency assessment processes where appropriate.
Expanded roles
If implemented appropriately, endorsements could provide a pathway for pharmacists with additional training and competence to undertake expanded roles without requiring the creation of entirely new scopes of practice. It will be important that any endorsement framework is applied proportionately and only where there is a clear need for additional regulation.
Careful consideration will also be required to ensure that any endorsement framework doesn’t introduce unnecessary regulatory burden or additional costs for pharmacists or employers, and any ongoing competency, professional development and recertification requirements will need to be clearly defined.
This includes whether endorsements represent the most effective regulatory approach compared with other options such as accreditation, credentialling, or additional scopes of practice.
Prescribing
We strongly support enabling pharmacists to practice to the full extent of their competence, including prescribing. We are currently participating in a working group developing pharmacist prescribing scopes and look forward to ensuring that the development of prescribing roles appropriately considers the various prescribing functions community pharmacists could undertake.
We recognise the Pharmacy Council of New Zealand’s discussion of a prescribing continuum and the potential for pharmacist prescribing to occur at different levels, from protocol-based prescribing for minor ailments through to more advanced prescribing roles.
Expanding prescribing in a staged and structured way will improve timely access to medicines and better utilise pharmacists’ clinical expertise.
It will be important that any progression of prescribing roles is staged and supported by clear training requirements, clinical protocols, and appropriate governance frameworks to ensure patient safety and consistency of practice.
Technicians and PACTs
Regulation may improve visibility of the technician workforce, however, it is also likely to create additional financial and administrative burdens for technicians and employers, which could act as a barrier to entering or remaining in the workforce.
Importantly, regulating this workforce is unlikely to change the existing accountability framework, where pharmacists retain professional and legal responsibility for the safe supply of medicines. It is unclear whether regulating technicians would deliver additional safety benefits beyond the existing model.
Given the significant work and cost involved in establishing a regulatory framework, we question whether regulation is necessary or if alternative non regulatory mechanisms could better support workforce development, role clarity, and career progression for technicians and Pharmacy Accuracy Checking Technicians, or PACTs.
