National competency standards framework for pharmacists

Transcription

1 National competency standards framework for pharmacists The PPDC sought comment on specific issues through the following Consultation questions SHPA s response was made through the PPDC Consultation Survey this is a copy of the answers to each of the 10 questions. 1. Looking at the overall structure and content of the Draft 2016 Framework, do you think there are areas of practice that are not adequately covered? If so, please SHPA remains concerned that the content does not fully and accurately the contemporary practice of pharmacy across all sectors. The draft does not sufficiently reflect all of the functions described in Building upon pharmacists practice in Australia in particular most of function 6, some of functions 3, 8 and 10. In addition the medicines management activities performed by pharmacists for individual patients, pharmacist provide services to populations or patient cohorts; these are missing from the draft Standards. We believe that these activities are not hospital-specific as the scope of practice of many pharmacists currently includes providing services to residential care, Aboriginal Health Services, GP practices such as: Medicines Advisory Committee (MAC) or health services Drug and Therapeutics Committee (DTC), formulary management, Drug Utilisation Evaluation (DUE), Antimicrobial Stewardship (AMS), Medication Safety, Electronic medication Management (emm) and Medicines Information. These activities are key to a health service s governance for safety and quality (clinical governance) and will become more important and common as the National Safety and Quality Health Service Standards Version 2 published by the Australia Commission on Safety and Quality in Health Care (ACSQHC) come into effect in all health services in We suggest that the Standards could have an additional key competency related to medicines management supporting governance for safety and quality that would include activities related to DTC/MACs, AMS, Medication safety and emm. Some SHPA members participating in the Advanced Practice pilot raised that a considerable part of their scope of practice was not reflected in the APPF used. We suggest that the final version of the Standard needs to be tested against numerous examples of real of scopes of practice to ensure that: the key and enabling competencies adequately cover the range of knowledge and skills required to reflect contemporary practice to ensure the enabling competencies at the advanced level do not require the pharmacist to hold a position with a specific job description. The Society of Hospital Pharmacists of Australia PO Box 1774 Collingwood Victoria 3066 Australia shpa@shpa.org.au ABN:

2 2. Looking at the structure and content of Domain 1: Professionalism and ethics, do you think the Domain adequately captures this area of endeavour? If not, please 1.1 The tone of the evidence examples is not appropriate- sets up expectation that all pharmacists are expected to manage excessive workload and disruptions at foundation level and that is an expected condition of employment Suggest change in wording to: Integrates professional effort with that of other health professionals in a manner that streamlines optimises access to and use of professional expertise and services Should be expanded to include team based care and the notion of shared decision making / responsibility The tone of the evidence examples implies that pharmacist should manage and adopt to excessive workload, disruptions etc. the performance criteria should not reinforce unacceptable workplace health and safety situations Requires performance criteria at the consolidation level as the competency required to manage escalated issues / situations outside the competence of pharmacists at the registration / foundation level is not covered The terms of general knowledge, comprehensive, high level knowledge and advanced knowledge are meaningless The evidence example needs to include action taken to address problems identified The statements for third performance criteria are presented in the wrong level advanced level should include developing protocols 1.6 This enabling competency needs to include governance for safety and quality and the identification of an issue as an incident / escalation of incidents. For example with incident reporting and follow up an experienced pharmacist could be expected to take responsibility for reviews, a degree further than works with colleagues this applies equally to the community and hospital setting. 3. Looking at the structure and content of Domain 2: Communication and collaboration, do you think the Domain adequately captures this area of endeavour? If not, please Suggest remove the word opinion from the performance criteria at the advanced level This enabling competency should include documentation required e.g. providing expert advice to support team-work and consultation which is different to documentation of issues relating to the treatment of an individual 4. Looking at the structure and content of Domain 3: Medicines management and patient care, do you think the Domain adequately captures this area of endeavour? If not, please 3.1 The blurb should include the sharing of verified information to support the patient s care e.g. information received post-discharge or recording of information in patient s health record The performance criteria should refer to ADE not just ADR The Society of Hospital Pharmacists of Australia 2

3 3.1.1 The performance criteria needs to include checking patient consent not just gaining consent e.g. off label use, deviation from protocol The performance criteria should include assessment of patient s ability to selfmanage / self-administer medicines (if not here in 3.3.1) The performance criteria should include the curation of a current and complete medication list The performance criteria should include ability to compile medication management plan The performance criteria should include acting if an issue is identified There are five steps involved in managing a patient s medicines / MMP which need to be included in the Standard: patient interview and recording a medication history (including current and complete medicines list), medication reconciliation, assessment of current medication management, clinical review and TDM and documenting a medication management plan. Without this degree of detail the enabling competencies are too high level and lack meaning. (Refer to SHPA Clinical Pharmacy Standards of Practice Chapters The performance criteria should include notion of mental health first aid The evidence example should include that records include confirmation of consent, discussion with prescriber, issues or incidents The evidence example could include assessment for and use of administration aids The performance criteria should refer to ADE not just ADR 3.4 In principle what has been termed simple compounding should be presented as a registration / foundation level activity. All aspects of other types of compounding that have been detailed should be include at transition level, at a minimum. 3.4 The blurb needs to define terms prefer terms aseptically prepared and nonaseptically prepared (not non-sterile or sterile) All 2 statements in orange should be in transition level All 3 statements in orange should be in transition level All 3 statements in orange should be in transition level The performance criteria needs to include responsibility for facilities and that appropriate facilities used to compound medicines in consolidation level The enabling competency should be non-aseptically prepared products The enabling competency should be aseptically prepared products All 4 statements in orange should be in transition level All 4 statements in orange should be in transition level Needs performance criteria related to the management of cytotoxic spills and unintended exposure (e.g. needle stick injuries) The performance criteria should include the development of formulations / master worksheets etc. (which includes the identification of an appropriate expiry date, storage conditions, labelling etc.as described in the newly drafted PBA guidelines) in the consolidation level The statement in orange should be in transition level Needs performance criteria at the consolidation level related to acting in response to incidents to trigger review of the use of medicines / protocols The Society of Hospital Pharmacists of Australia 3

4 The evidence example applies statistical analysis skills to collected data is above foundation level All 3 statements in orange should be in transition level All 2 statements in orange should be in transition level The evidence example should not include bone density screening All 3 statements in orange should be in transition level The final performance criteria should be re-worded to reflect the pharmacist s involvement in the program rather than the effectiveness of a health promotion program as a whole 5. Looking at the structure and content of Domain 4: Leadership and management, do you think the Domain adequately captures this area of endeavour? If not, please The medicines management activities performed by pharmacists for individual patients, pharmacist provide services to populations or patient cohorts; these are missing from the proposed Standards. We believe that these activities are not hospital-specific as the scope of practice of many pharmacists currently includes providing services to residential care, Aboriginal Health Services, GP practices such as: MAC or health services DTC, formulary management, DUE, AMS, Medication Safety, emm and Medicines Information. We suggest that the Standards could have an additional standard related to medicines management supporting governance for safety and quality that would include activities related to DTC/MACs, AMS, Medication safety and emm The performance criteria at registration / foundation level should refer to the vision of the pharmacist s workplace The third performance criteria should not include the word optimism. It would be better as Displays empathy, resilience, persistence The third performance criteria, consolidation level we are unsure how most pharmacists would interpret this statement The first performance criteria, consolidation level remove word effective, needs comma All 2 statements in orange should be in transition level All 2 statements in orange should be in transition level All 2 statements in orange should be in transition level All 2 statements in orange should be in transition level All 3 statements in orange should be in transition level All 3 statements in orange should be in transition level All 3 statements in orange should be in transition level All 3 statements in orange should be in transition level The first performance criteria in orange should be truncated to: own roles and responsibilities and be moved to registration level The last statement in orange should be in transition level All 2 statements in orange should be in transition level All of the performance criteria require clarity and the inclusion of concepts of innovation, quality improvement and governance for safety and quality The Society of Hospital Pharmacists of Australia 4

5 6. Looking at the structure and content of Domain 5: Education and research, do you think the Domain adequately captures this area of endeavor? If not, please provide detail. 5.1 Due to the wording used some readers may assume this standard is only applicable to those who work in academia, the evidence examples should give workplace examples or examples of practice area-specific educational activities All 2 statements in orange should be in transition level All 2 statements in orange should be in registration level The performance criteria and evidence examples need to include applying pharmacy practice research / translational research into your practice The evidence example for second performance criteria is above registration / foundation level The evidence example should include advice provided in medication review reports / medication action plans All 2 statements in orange should be in transition level The performance criteria in transition level should be in registration / foundation level Both performance criteria should be at the transition level. The evidence examples are too advanced for registration / foundation level All 2 statements in orange should be in transition level or they should be altered to state that the pharmacist should collaborate in these activities 7. The performance level descriptors used in the Draft 2016 Framework are registration, foundation, transition, consolidation, advanced. Are these labels clear and appropriate in describing the practice continuum for pharmacists? If not, please Yes they are clear. 8. As shown in the previous question, the performance level descriptors of Transition, Consolidation and Advanced are those used in the 2012 Advanced Pharmacy Practice Framework. These labels which apply to the advanced practice continuum were integrated unchanged into the Draft 2016 Framework. Which is your preferred terminology for the advanced practice continuum? Prefer the current labels of Transition, Consolidation and Advanced 9. As part of the current review, the PPDC is canvassing options around the development of additional resources to support the implementation and application of the revised competency standards framework for pharmacists. What type of tools would be useful for you and your role? The use of the five domains with one domain spilt into two conceptual groups is not intuitive and we believe most pharmacists will struggle with seeing a link between their day-to-day activities and the standards, enabling competencies and performance criteria. The The Society of Hospital Pharmacists of Australia 5

6 statements that make the most sense to pharmacists are the evidence examples therefore these need to be sufficiently descriptive and inclusive for pharmacists to be able to identify their scope of practice. Evidence examples for performance criteria at the transition, consolidation and advanced level would assist pharmacists in identifying their current performance level and therefore ideas for their individual learning plan. A video explaining the different performance levels and the new format would be helpful. As this is a master document that includes all statements related to all performance levels. Suggest final version has each performance level presented to assist with pharmacists understanding and identification of a personal learning plan. See format used in The Integrated Leadership System developed by the Australian Public Service Commission (available from where a high level summary of each performance level is presented (e.g. profile for the first executive level: If you have any other comments you wish to offer about the Draft 2016 Framework please detail them below. Merging two documents has resulted in the listing of statements considered foundation (shaded orange). Vast majority of these would be viewed as being at the transition level in contemporary practice. SHPA is unsure that the foundation level is required; it adds complexity but little practical value. It is confusing for the reader for the same statements to be presented in the registration / foundation level as well as the transition, consolidation or advanced level. Where the same performance criteria is applicable cross all practice levels it would be less confusing if the cells are merged or some other way found of graphically illustrating the principle that these performance are expected from the day of registration. The final version of the document needs to include preamble / explanatory notes similar to the current document, in particular comment on the requisite knowledge. Finally there needs to be consistent terminology e.g. use of the word medicine rather than drug. The Society of Hospital Pharmacists of Australia 6