I will address
the most glaring errors of fact:
Pharmacy Fridge sales
Rollex have never had a monopoly on 'compliant fridges' - they
were (and are) the only Guild-endorsed vaccine fridge.
Others brands are certainly able to meet the standard, but the
Guild's commercial division, Gold Cross, gets a small commission
on this brand, just like they do for promoting any Guild-endorsed
product (see the middle pages of your 'Pharmacy Review').
A proportion of this money is paid back to the Guild for the benefit
of it's members.
The commission is paid out of the existing RRP not, on top of
it.
The price of the fridges reflects the small market, and the specialised
nature of the equipment - any artificial inflation of the price
would quickly lead to competitors (and we list the other QCPP
compliant fridges on the QCPP website) getting all the sales.
Independent refrigerator tests are important to the integrity
of the cold chain and the cold chain standards in the Program.
The QCP Division has no involvement in this service, other than
requiring it for accreditation.
The NSW branch of the Guild provides the service, and any meagre
profits generated are used to fund services that benefit NSW members.
More importantly, every accredited pharmacy having a specific
purpose vaccine refrigerator, three-yearly external testing and
regular in-pharmacy monitoring of temperatures will help the Guild
to argue that vaccine distribution should not take place in less
rigorous circumstances (eg, at doctor's surgeries not possessing
a vaccine fridge).
Accreditation assessment fees
The Guild does not receive a portion of the assessor's accreditation
fee.
The only financial transaction between the QCPP division and QCP
assessors is the assessors' payment of an annual fee (currently
$50) to the QCP Division.
Shopfitters
The QCPP is not specific at all in it's standards for pharmacy
appearance and layout, but has guidelines for professional services
areas, dispensing areas, unpacking areas, retail floor plan and
entrances. These guidelines reflect Occupational Health &
Safety concerns, Dispensary regulations, Pharmacy Acts, and the
common sense ideal that a perhaps a refit every decade is not
such a bad idea.
To say that most pharmacies need to make expensive alterations
to be accreditable is a wild generalisation unsupported by any
data that I am aware of.
That some may need to update a decade-old fitout is self-evident,
and quite proper.
·QCPP Revenue
QCPP revenue is used to fund the costs of operating, maintaining
and promoting the program.
Roughly half of the expenditure is on the salaries of the people
who work in the QCP Division.
As Chair, any expenses I incur attending meetings are re-imbursed,
and I am paid the equivalent of about $35 per week as recompense
for phone calls, and the time I take from running my accredited
(and re-accredited!) pharmacy to monitor, and occasionally collaborate
in, the running of the Division. To imply that the rigour of the
program is designed to keep me in a job that pays $35 per week
is risible!
There is a saying to the effect that the aim of any good manager
should be to make himself redundant ('cos the system runs so smoothly,
management isn't needed!).
I would certainly be delighted if I could achieve this aim in
the Division.
The funding
shortfall between annual membership fees and annual QCPP operating
costs is being met from charging a fee that is payable on re-accreditation.
The QCPP has to be self funding, and when the Guild realised that
further revenue was required to cover essential operating costs,
it persuaded the Federal Government to introduce a re-accreditation
incentive to offset the re-accreditation fee.
And not only that, the Guild managed to ensure that the level
of the incentive covers not only the re-accreditation fee but
also the assessment fee and the next three annual membership fees.
Without recognition of the burden of these costs on pharmacy owners,
the re-accreditation incentive would not have been introduced!
I would also
point out that any changes made by committees of which I am a
part have to be implemented in my own pharmacy at the expense
of my own time and money.
I have a vested interest in making the system as easy to implement
and maintain as possible, while maintaining the integrity of the
program.
This philosophy was the basis for the decision to do away with
the eight-hour rule, about which Mr Skyllas complained in his
article.
He argues that it created extra work for pharmacists.
However, the opposite can also be the case, eg a naturopath or
beautician working in a pharmacy for two days a week, but who
does not handle prescriptions or money, or assist the pharmacist,
previously had to complete the whole Staff Certification workbook
and be competent in every Team Standard . Under the new rule,
they only have to be certified against the Standards which are
RELEVANT TO THEIR WORK.
This actually reduces the workload on that staff member.
As far as this rule is concerned, from the point of view of the
integrity of the Program, it was possible, under the old rules,
for an accredited pharmacy to be completely staffed at certain
times by people who had not had any auditable exposure to the
Standards (ie, a locum on a Saturday morning, with two Saturday
juniors assisting them).
To any reasonable person, this clearly makes a mockery of that
business holding itself out as having Quality Assurance in place
at that particular moment.
So I make no apology for that tweak to the rules of the Program.
As to a locum who refuses to complete the staff certification
process, why not require them to do it in the time for which you
are paying them?
Are they so obdurate that they will not follow a lawful request
from their employer to carry out a paid task?
Mr Skyllas
is wrong again when he asserts that staff who had been assessed
with the old workbooks have to be complete the new books.
This is not the case: it is only new staff members who are obliged
to use the new workbook.
Part of a
Quality assurance process is the maintenance and refining of protocols.
I can only assume that this is what Mr Skyllas refers to when
he complains of the QCP Division 'raising the bar'.
This process consists of having a regular look at the way tasks
are carried out in the pharmacy, to consider whether it can be
done better/more efficiently/more economically.
Some people call it 'sharpening the saw', ie, that if you don't
make and take the time to improve or maintain a process, wear
and tear will make the process less efficient, and the job will
take longer/be more exhausting than taking and making the time
to do 'running repairs' would have added.
Of course, I am well aware of the corollary to this, which states
that: "It's hard to think of Draining the Swamp when you're
up to your Arse in Alligators!"
Let there be no misunderstanding: the QCP Division firmly believes
that any process, including the QCPP in particular, can be improved
from the point of view of all stakeholders.
We would not have had reviews in 2000 and 2001 if we were labouring
under the delusion that the Program was perfect and beyond improvement
or repair.
We aim to balance a robust quality assurance program that has
credibility in the eyes of our customers (and the regulators and
third part payers) with one that can be implemented with an appropriate
amount of sweat, time and money.
It is the policy of the Division to only consider new Standards
if pharmacists are going to be paid for providing the service
(especially with new initiatives from the Government, or within
our own profession), or if the issue has strategic value to the
Community Pharmacy industry in general, and pharmacy owners in
particular.
We will not overburden pharmacy owners with frequent, multiple
changes to the Program, but we will conduct a major review in
the future, in association with the development of the Fourth
Agreement between the Federal Government and the Guild (on behalf
of it's members).
This review will aim to streamline the operation of the Program
for the duration of the Fourth Agreement, make sure its administration
is efficient and represents value to it's clients, and reflects
the views of stakeholders, especially those who have to implement
it.
Informed feedback
will be called for and used to make improvements.
I would like to repeat my invitation to persons who can make constructive
comments to feel welcome to share their thoughts with the QCP
Division.
All I ask is that the issues raised be factual, specific, and
be accompanied by ideas as to how the desired outcome could be
achieved in a different way.
If I see opinion
pieces published based on sloppy research and factual inaccuracy,
I will always respond vigorously (not defensively) to set the
record straight.
I really hope that we will soon see an article from John Skyllas
that contains no factual errors, absurd generalisations, or slanderous
allegations; but that contains practical ideas and solutions that
can be used productively in furthering the interests of our profession.
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