Annual Report of the Preliminary Proceedings Committee of the Pharmaceutical Society of Ireland - Complaints Statistics
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The Pharmaceutical Society of Ireland ('PSI') has published the most recent Annual Report of its Preliminary Proceedings Committee ('PPC').
The PPC is the committee tasked with preliminary review of all complaints received by the PSI regarding registered pharmacists and pharmacies in Ireland. The PPC considers complaints and advises the Council on whether there is sufficient cause to warrant further action being taken. Further action takes the form of either an Inquiry before its Professional Conduct Committee or Health Committee, or mediation.
The Annual Report for 2020 details the actions of the PPC during its eleventh full year in operation – a year in which the management of complaints moved to a completely remote environment due to the unprecedented national and global health crisis.
Background
When deciding whether or not to refer a complaint for further action, the PPC considers a number of factors. These include:
- Whether the complaint is trivial, vexatious or made in bad faith;
- Whether there is sufficient information to process the complaint;
- Whether there is sufficient cause to warrant further action, including assessing whether the complaint meets the threshold of seriousness as set out by the Supreme Court in the case of Corbally v Medical Council & Ors [2015] IESC 9.
2020 – A Broad Overview
In 2020, the PPC considered a total of 37 complaints against pharmacists and pharmacies across six Committee meetings throughout the year, four of which were held remotely. The 37 complaints consisted of complaints made by members of the public, pharmacists, other organisations and the Registrar of the PSI.
Of the 37 complaints, 15 were sent forward for further action. This represents a slight increase in the percentage of complaints sent forward over previous years – 42% of complaints were deemed to warrant further action in 2020 as opposed to 34% in 2019 and 29% in both 2018 and 2017.
- 13 complaints were referred to the Professional Conduct Committee ('PCC') for Inquiry.
- 2 complaints were referred for resolution by mediation, but these subsequently were referred to the PCC for Inquiry due to a refusal of consent to mediate in one instance and a failure of mediation to achieve an acceptable outcome in the other.
- No complaints were referred to the Health Committee for Inquiry in 2020.
The PPC advised the Council that the other 22 complaints warranted no further action. This advice was followed by the Council in relation to all 22 of these complaints.
Nature of Complaints
The largest category of complaints considered by the PPC related to pharmacy practice issues. These made up 27% of the total number of complaints considered. Pharmacy practice issues that were the subject of complaints include:
Nature of Complaints
The largest category of complaints considered by the PPC related to pharmacy practice issues. These made up 27% of the total number of complaints considered. Pharmacy practice issues that were the subject of complaints include:
- The supply of a non-prescription medicine to a minor;
- The supply of methadone otherwise than in accordance with PSI 'Guidance for Pharmacists on the Safe Supply of Methadone'; and
- The supply of a pharmacy-only medicine without a pharmacist being on duty in the pharmacy at the time of supply;
The second largest category of complaints related to the behaviour of pharmacists in terms of manner or attitude. Complaints relating to behaviour amounted to 19% of all complaints considered by the Committee in 2020. It is noted that complaints under this category frequently related to the manner in which they were spoken to by a pharmacist.
Complaints in relation to dispensing errors amounted to the third largest category of complaint considered by the Committee in 2020. However, there was a considerable decrease in the percentage of complaints relating to dispensing errors between 2020 (13%) and 2019 (23%).
There were two main types of dispensing errors complained of:
- Incorrect medication: In its report, the PPC highlighted the importance of pharmacists reviewing prescriptions to ensure that they are legally valid and therapeutically appropriate for the patient, as well as reviewing the original prescription against the label and dispensed products prior to supply to the patient; and
- Incorrect strength of correct medication: In its report, the PPC notes concerns relating to potential errors occurring when dispensing prescriptions for infants and children.
Covid-19
The outbreak of Covid-19 resulted in a number of novel complaints being considered by the PPC. These complaints included:
- Refusals by pharmacists to provide an early supply or further medication in the absence of a prescription and;
- Issues relating to whether or not the validity of a prescription for a particular medicine could be extended.
The PPC notes that although such novel situations can be a challenge, it is important that pharmacists communicate the reasons for their decision clearly and respectfully to the patient while at all times being guided by the Statutory Code of Conduct for Pharmacists.
Written by Zoe Richardson and Matthew McGarry.