Table 4 Principles of better regulation framework analysis—illustrative quotes
Principle of better regulation | Related categories/themes | Illustrative quotes |
|---|---|---|
a. Necessity | Implementation | “The Act was necessary…Its interpretation is excessive & costly.’’ |
b. Effectiveness/targeted | Targeted approach to enforcement | “Approach to enforcing the act has been to publish and report on all negative aspects of pharmacy and pharmacists…..pharmacists are constantly trying to “watch their backs”” “Currently enforcement takes a "gotcha" approach, looking for the undotted i or uncrossed t, instead of focusing on…..delivering safe and effective care to patients’’ |
c. Proportionality | Enforcement proportional to risk posed to public health | “There is little evidence of a serious risk to public health from the actions of community pharmacies…Yet the Act is enforced as if community pharmacy poses a serious danger to those who use it” |
Assessment of risk | ‘’I am not aware of any such published risk assessment carried out by PSI’’ | |
d. Transparency | Stakeholder consultation | “I find the flow of consultations completed online are directed towards the ideal response as espoused by PSI—and it seems that they are only an exercise that needs to be done and that outcomes feel predetermined’’ |
e. Accountability | Accountable to whom and for what? Accountability of non-pharmacist owners of pharmacies | “Don’t answer to anyone….” “The PSI need to target and take on the Owners of Pharmacies where the owners are not Pharmacists. The Owners have the power to change whereas the Pharmacists don't, e.g., supply of resources’’ |
f. Consistency | Areas of inconsistency | “Chain pharmacies are given a light touch as they have bigger legal firms defending them” “I've seen a variance first hand with authorised officers depending on the pharmacy in particular rather than the legislation” |
g. Agility | Scope of Practice | “The lack of increased scope of practice has caused many patients to be left without essential services, e.g., treating other minor ailments” “Colleagues in the UK laugh when I compare services we can and cannot supply in comparison to care that is 10 years in action elsewhere’’ |
IT Advances | “Not keeping pace with desire from profession to innovate. Not keeping pace with technological advances—electronic prescribing” |