The college has objected to euphemisms like ‘clinical reasoning’ for ‘diagnosis’ in draft pharmacist education standards.
A diagnosis by any other name certainly does not smell as sweet, the RACGP has informed the Australian Pharmacy Council this week.
On Tuesday, the college issued its response to the APC’s new draft accreditation standards for pharmacist prescriber education programs as part of the council’s second round of consultations on the standards.
As many readers may have guessed, the RACGP is not keen on many of the proposals put forward in the draft standards.
One particular item that sparked criticism was the language used in the document, which appeared to describe a diagnostic process when pharmacists are only meant to supply medicines for symptom management.
Various stand-ins are used in the place of the word “diagnosis” throughout the report, including “clinical reasoning”, “assess the consumer” and “establish or review, and understand, the diagnosis”.
The college says the APC has failed to properly differentiate diagnosis and prescribing skills.
“The RACGP reiterates its concerns about the conflation of diagnosing and prescribing skills and that prescribing is not an individual construct that can be allocated like an administrative task,” the submission says.
While the college supports pharmacist prescribing in a multidisciplinary care setting, it says, the lack of training and the retail model makes community pharmacy a wholly unsuitable setting.
“The APC states that they are seeking collaborative practice, however pharmacist prescribing in a retail pharmacy setting will fragment care and duplicate services while directing patients away from the essential coordinated medical care provided by their general practice,” the RACGP says.
Flowcharts, the college says, cannot replace a decade of medical training.
The submission also details a curious incident at an APC forum in mid-September, where an RACGP representative was told that the terms “autonomous prescribing” and “independent prescribing” were no longer relevant, despite being used frequently during the first round of consultation.
While it’s true that the draft accreditation standards and performance outcome framework do not use these terms, the college says it was not made aware during the consultation process that these updates had been made.
“As consultation of the accreditation standards continues and content is altered to reflect feedback, there is a risk that organisations and professionals’ feedback will not reflect their initial intent and engagement,” it says.
The standards themselves are designed to be applicable to pharmacist prescriber programs as needed by individual jurisdictions.
So far each state that has announced or implemented a pharmacy prescribing program has independently set its own education requirements for pharmacists.
“The cart’s been put before the horse,” RACGP vice president Dr Bruce Willett told The Medical Republic.
“The states have gone off and basically set up independent pharmacist diagnosing and prescribing before the pharmacy council was even halfway through its work on deciding how that looks.”
To add to the matter, he said, is the fact that the federal government has now started a formal inquiry into allied health scope of practice, a process which would typically happen before every single state went ahead and implemented a change like pharmacist-led prescribing.
“There is a concern that what we’re doing is literally completely backwards,” Dr Willett said.
While the accreditation standards can control certain things, like what level of training or study has to be completed, the form that pharmacist prescribing takes is out of their scope.
“APC accreditation standards are outcome-based … they do not dictate how education providers should meet the standards, rather they define the standard and allow education providers to determine their preferred method/s for meeting the standard, consistent with program philosophy and pedagogy,” the council says.
It does, however, set the requirement for level of training at a graduate certificate equivalent, a higher level than what is needed for podiatrist prescribing but a lower level than nurse practitioner qualifications.
There’s no set date for the publication of the final standard, but the second round of consultation is now closed.