Decisions taken at the Council meeting (Oct, Feb, May)
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Council dealt with a number of issues during its meetings on 12/13 October 2016, 15/16 February 2017 and 10/11 May 2017. Some of the matters were resolved directly with the affected parties, and others appear as separate articles in this edition of e-Pharmaciae.
Fees for a course or provider accreditation
Council often receives requests from Further Education and Training (FET) and Higher Education Training (HET) providers for changes to be made to their learning programmes. This involves adding to or amending specific modules of an already approved learning programme.
Council is required to evaluate all changes, and the process incurs the payment of a fee to recover the costs of the evaluation. Evaluating changes to specific modules demands the same resources that the evaluation of a full programme demands. For example, the BPharm programme is integrated and changes to a specific module may require evaluating the whole programme to ascertain that the credit load for each exit level outcome is still in accordance with the minimum standards. In October 2016, Council resolved that where changes to a learning programme involve more than 20% of the programme, the service provider must pay the same fee that is levied for the accreditation of a full course.
Misrepresentation of Council
Council was notified about a certain company whose advertisements carry the term ‘SAPC CPD for pharmacists’. This is misleading and may result in pharmacists unnecessarily subscribing to the company in the mistaken belief they are complying with a Council requirement. This company offers to upload the CPD activities on behalf of a pharmacist, who is therefore required to give their login details to the company. Registered persons providing their login details to service providers to upload CPD entries on their behalf will compromise the integrity of the register system.
All sites will be at risk if a third party that is not registered with Council has access to Council information. The Office of the Registrar has previously received similar complaints from the profession regarding the same company. Council resolved in October that pharmacists be informed that they may not give another person or company their SAPC website login details and that Council will take disciplinary action against them in terms of Chapter V of the Pharmacy Act, 53 of 1974. This action undermines the integrity of the register system.
Applicants with a qualification obtained outside South Africa
The Office of the Registrar received applications from candidates who wished to be registered as pharmacists or pharmacy support personnel. Council previously approved the Guidelines for persons who hold qualifications in pharmacy obtained outside the Republic and the criteria to be used in the evaluation of these applications. Council resolved in July 2016 that candidates with foreign qualifications be granted four attempts at each paper and a maximum of four years from the date of approval to pass the professional examinations.
- Council resolved the following during the October 2016 meeting:
- Mr B Sibuya and Mses AR Cairns and EO Agieyeh be registered as pharmacist interns after successfully completing the professional examinations and a minimum of six months internship at an institutional or community pharmacy. Prior to registration as pharmacists, the candidates are also required to successfully complete the preregistration evaluations, or provide documentary evidence of compliance with the CPD requirements in their country of origin, and each submit one progress report from their tutor.
- Messrs LB Mlalazi, MD Salemane, EL Motopi, P Moahloli and NAI Balera, and Ms NDM Defief be registered as pharmacist interns after successfully completing the professional examinations and a minimum of 12 months internship at an institutional or community pharmacy. The candidates are also required to successfully complete the preregistration evaluation.
- Subject to the verification of Mr VMH Patel’s IELTS score from the British Council, he be registered as a pharmacist intern after successfully completing the professional examinations and a minimum of 12 months internship at an institutional or community pharmacy. The candidate must also successfully complete the preregistration evaluation.
- Mr VB Yalamanchi’s application be declined due to the submission of a fraudulent IELTS certificate in 2015. The relevant stakeholders, being the Department of Health’s Foreign Workforce Management Programme (NDoH FWMP), the South African Qualifications Authority (SAQA), the Department of Home Affairs and the Indian Embassy, must be informed of this fraudulent action.
- Ms RB Chiwariro from Zimbabwe, who obtained her qualification from the Ministry of Higher and Tertiary Education in Zimbabwe, be allowed to register as a pharmacist’s assistant learner post basic for six months, and be required to complete a module on pharmacy law and ethics with an accredited provider.
Council further resolved to amend the Guidelines for persons who hold qualifications in pharmacy obtained outside the Republic to include a statement that reads “the SAPC has zero tolerance toward fraud and corruption”. If documents are found to be fraudulent, Council will retain the payment and the documents, and make the information about the suspicion known to all the relevant authorities, which are SAQA, NDoH FWMP, Home Affairs and the relevant embassies or consulates. Should Council receive information regarding the submission of fraudulent documents by foreign qualified applicants already registered, such candidates will be referred to the Committee of Preliminary Investigations.
- Council resolved the following during the February 2017 meeting:
- (i) Mses MC Molefe and M Mahomo be registered as pharmacist interns after successfully completing the professional examinations and a minimum of six months internship at an institutional or community pharmacy. The candidates must also successfully complete the preregistration evaluation, or provide documentary evidence of compliance with the CPD requirements in their country of origin, and each submit one progress report from their tutor prior to registration as pharmacists.
- (ii) Mr RK Neredumelli be registered as a pharmacist intern after successfully completing the professional examinations and a minimum of 12 months internship at an institutional or community pharmacy, and the preregistration evaluation prior to registration as a pharmacist.
- (iii) Ms N Sibanda and Mr J Dube be registered as learner post basic pharmacist’s assistants and be required to complete a module in pharmacy law and ethics with an accredited provider. The candidates are also required to complete a minimum of six months in-service training at a registered training facility under the supervision of an approved tutor who must submit a four-month progress report.
- (iv) The application by Mr Manthan Bharatkumar Patel be held in abeyance until the investigation of the IELTS certificate results, which were found to be inconsistent with the results on the British Council website during the online verification process, is completed.
- Council resolved the following during the May 2017 meeting:
- Mses MT Mazanhanga, V Zingwari and J Ncube be registered as pharmacist interns after successfully completing the professional examinations and a minimum of six months internship at an institutional or community pharmacy. The candidates are also required to complete the preregistration evaluations, or provide documentary evidence of compliance with the CPD requirements in their country of origin, and submit one progress report each prior to registration as pharmacists.
- Ms T Makenke and Mr ST Guadie be registered as pharmacist interns after successfully completing the professional examinations and a minimum of 12 months internship at an institutional or community pharmacy. The candidates are also required to complete the preregistration evaluations, or provide documentary evidence of compliance with the CPD requirements in their country of origin, and submit all progress reports prior to registration as pharmacists.
- Ms FN Mejang’s application not be approved until such time as the Office of the Registrar has received the official translation of the curriculum into English with the duration of the training clearly specified, and a transcript of the courses the candidate has completed.
- Ms J Wafawanaka be registered as a learner post basic pharmacist’s assistant and be required to complete a module on pharmacy law and ethics with an accredited provider. The candidate is also required to complete a minimum of six months in-service training at a registered training facility under the supervision of an approved tutor who must submit a four-month progress report.
Control of access to pharmacy premises
The Office of the Registrar reviews the inspection questionnaire on an annual basis based on feedback from: the Council inspectors meeting; Council’s interaction with the pharmacy profession of various forums, including but not limited to the annual consultative meeting held with the heads of pharmaceutical services; and assessment of inspection reports by the Office of the Registrar. Often the following questions or statements under ‘premises and layout’ are subject to different interpretations by inspectors:
- Key, key card or other device, or the combination of any device which allows access to the pharmacy when it is locked, is kept on the person of the responsible pharmacist or the person of another pharmacist at all times.
- Control of access to pharmacy premises, which includes the design and layout of the pharmacy, is of such a nature that only registered pharmacy personnel have direct access to medicine.
- Only the pharmacist(s) to have keys to the pharmacy area where Schedule 1 to 6 items are kept.
In the case of a lay owner, the pharmacist may not be the only person in possession of the keys to the pharmacy. The keys to the pharmacy might be required in the event of a disaster, for example flood, theft.
Rule 1.2.4 of the GPP regarding the control of access to pharmacy premises states: “The responsible pharmacist of a pharmacy must ensure that every key, key card or other device, or the combination of any device, which allows access to a pharmacy when it is locked, is kept only on his/her person or the person of another pharmacist at all times.” The implication of this rule is that access to the pharmacy is restricted to registered persons only, which will prevent access in the event of a disaster.
In October 2016, Council resolved that Rule 1.2.4 be amended to read: “The responsible pharmacist of a pharmacy must ensure that every key, key card or other device, or the combination of any device which allows access to a pharmacy when it is locked, is kept only on his/her person, the person of another pharmacist and/or the person of the owner/delegated person.” The inspection questionnaires are to be amended appropriately.
Requirements and conditions for the evaluation of alternative models for the delivery of chronic medication to patients
The Office of the Registrar has been approached by numerous stakeholders presenting various business models for the delivery of medicines to patients. In the absence of a standard, the Office was unable to advise. In February 2017, Council approved a document titled “Requirements and conditions for the evaluation of alternative models for the delivery of chronic medication to patients.”
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