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Welcome to the April edition of the Quality Care Pharmacy Program - News and Updates.
In this edition:
- QCPP @ APP2025
- Common Corrective Action Reviews: Education and Training
- Interpretations and Rulings: Consultation space
- Meet the QCPP Director
- Rescheduling and Extension Requests
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QCPP @ APP2025
It was wonderful to be able to attend APP2025 and gain valuable insights into how the pharmacy industry engages with QC2020 – Community Pharmacy Accreditation Program. Over the three days the QCPP stand was visited by a large volume of pharmacists and pharmacy owners, with questions ranging the full spectrum of engagement – from those sharing opportunities as to how they are embedding quality into everyday practice, through to those wondering what they should be doing to prepare for “QCPP” in their upcoming scheduled assessment.
As many of you are aware The Quality Care Pharmacy Program (QCPP) is a voluntary quality assurance program for community pharmacies. The accreditation program assesses community pharmacy compliance against Australian Standard - AS 85000 (the Standard) through the QC2020 Requirements. The program aims to ensure community pharmacies provide quality, safe and consistent pharmacy services and care to consumers and patients. Accreditation also provides pharmacies with a competitive edge in providing the community with a level of assurance related to the delivery of consistent, safe quality pharmacy care.
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As the new Director, I will be aiming to work with the industry to ensure the expectations of the QCPP are clear, that pharmacies are able to understand and commit to the level of engagement expected and provide practical guidance and support tools to drive safety, quality and consumer engagement through the QCPP website and Knowledge Hub.
Other suggestions for QCPP from APP include:
- A desire for education around common corrective actions – this will be incorporated within the eQIP monthly newsletter and possible webinars / video education;
- A need to update the Knowledge Hub – this will be reviewed and updated in the coming months;
- Review the QCPP Website to ensure elements such as the Registration process is clear and succinct.
Natalie Willis, Chair of the Clinical Governance Committee, delivered the last session for APP2025. Notwithstanding the late timeslot, the session on “Finding success in QCPP” was informative and well attended. The session included common Corrective Actions and possible solutions, changes between the 2017 and 2024 Australian Standards and an introduction to Clinical Governance.
I look forward to continuing to engage with the Pharmacy Sector, and ensuring the QCPP program continues to support the delivery of high, quality primary healthcare in the community.
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The team on the QCPP stand at APP2025. L-R: Nareena Bora Rawat (QCPP), Lauren Pfeiffer (EY), Jaqui Abboud (EY), and Lesley Jordan (QCPP).
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Common Corrective Action Reviews (CARs): Education and Training
The following represents a common CAR related to activities associated with employee training, development and management.
Common presenting issues at assessment include:
- First Aid and CPR training of staff has expired
- Training for pharmacy services is not recorded or may not have been completed e.g. DAA, Vaccination
- S2S3 Initial training has not been completed for all staff who are involved in the supply of S2 Pharmacy Medicines and S3 Pharmacist Only Medicines.
Requirements
The QC2020 Requirements clearly state that “Pharmacy owners and managers are responsible for ensuring employees are qualified, trained and adequately supervised to fulfil the requirements of their role”.
Specifically, QC2020 Requirement 3.3.1 requires pharmacies to "Ascertain and document details of relevant qualifications and/or training undertaken by all staff and contractors to ensure they operate within the scope of their role and expertise. Where necessary, develop a process of supervising staff who need assistance in performing their role."
Some suggested strategies:
- Regularly conduct staff reviews to ensure pharmacy staff training needs are appropriately identified in a learning plan, and align with their position description.
- Have a documented learning plan and education record available for all staff to record their education and learning opportunities.
- Keep note (set diary alerts) of when training will expire, and new certification will be required. Allowing for appropriate lead time to book in and complete training requirements.
What is the impact of non-conformance?
If staff have not received the appropriate education and training for the services being offered, they will be limited in the roles and functions they can perform within the community pharmacy.
For example: Staff who have not completed initial S2/S3 training are not able to be involved in the supply or sale (register processing) of S2 Pharmacy Medicines and S3 Pharmacist Only Medicines. This limits their role (which is to be reflected in their position description) to stocking shelves, back of house stock control etc.
Rule 28 states that “the pharmacy business has 60 days to remediate any non-conformances from the interim report date”. If Pharmacies are unable to provide the appropriate assessment evidence to demonstrate compliance within the specified timeframe a “Failure to Complete” may be issued, resulting in the pharmacy jeopardising their accreditation.
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Interpretations and Rulings: Consultation space
This is a new regular section for the eQIP Newsletter which will look at matters presented to the Interpretations and Ruling Committee. The role of the Interpretations and Rulings Panel is to make timely decisions on queries relating to the application of the Quality Care Pharmacy Program (QCPP) Requirements. The presentation of deidentified matters considered by the committee aim to increase the overall awareness of the QC2020 Requirements, and provide an opportunity for pharmacies to proactively comply and reduce their number of corrective actions.
Domain 4: Premises and Infrastructure
Sub-Domain 1: Premises and Infrastructure
Number 4: Ensure there is an area which allows for private conversations with consumers.
Domain 5: Pharmacy Services
Sub-Domain 4: Additional Requirements for Medicine Management Services
Number 5: There is an appropriate consultation area available within the pharmacy to conduct in-pharmacy medicines reviews.
At the onsite assessment during sections 4.1.4 and 5.4.5 the Assessor did not observe a private space which enabled private conversations with consumers.
The pharmacy provided follow up evidence for this Corrective Action which consisted of images of the “consultation area”. The images identified an area with a table and 2 chairs, surrounded by temporary pull up banners, within a retail area of the shop front.
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Graphical representation of the original photography has been distorted to protect the pharmacy identity.
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The committee considered the photographs provided by the pharmacy. The committee considered the area inadequate as a private consultation area for the following reasons:
- The consultation area is set up within one of the aisles within a commercial space,
- The area afforded no privacy,
- The consultation space impacted egress within the commercial area, which would result in a high risk of interruptions.
The decision of the Assessor in this instance was upheld, and the evidence provided demonstrated a deficient consultation area.
The QC2020 Requirements Assessment evidence:
- 4.1.4: “Observation there is a consultation area that allows for private conversations with consumers (eg., a separate room or area with barriers)”.
- 5.4.5: “Observation there is a consultation area that allows for confidential seated consultation between the pharmacist and consumer”.
Compliant pharmacies have either had capital work undertaken to build a separate consultation room, or have an identified private permanently screened area within the pharmacy that enable a private seated conversation to undertake private conversations, for example medication reviews.
Impact of the panel’s decision for the pharmacy
In this case the pharmacy is deemed to have not met the QCPP rules to provide in-pharmacy medicine reviews, resulting in this service unable to be delivered until the consulting area is deemed appropriate.
Further information and resources relating to the above QC2020 Requirements can be found via the Knowledge Hub.
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Rescheduling and Extension Requests
QCPP currently accredits approximately 3500 pharmacies annually. The scheduling of assessments requires careful planning and management. Many factors are taken into consideration during the scheduling process, including compliance with program rules and requirements, assessor health and safety and travel efficiencies. Where possible, pharmacies who are due for assessment at similar times, in similar geographical regions, are grouped together to streamline assessment efficiencies and minimise program costs.
Failure to group pharmacies in geographical areas puts a strain on assessor resources within the region and can impact the completion of other QCPP assessments scheduled within the same period.
At the moment, QCPP is experiencing a high demand for requests to reschedule assessments. The current high volume of requests is making the rescheduling or extension requests particularly challenging. In many instances the proposed date may not be feasible within the current assessment trip planned, necessitating an additional trip which also requires the mobilisation of additional resources. At times of high assessment volumes, accommodating numerous requests to reschedule are difficult to coordinate, alongside compliance with QCPP program requirements.
As per QCPP Terms & Conditions, a pharmacy must be meeting QCPP requirements at all times throughout their accreditation cycle (T&C’s Clause 8) and be ready for an assessment at any point throughout that cycle (T&C’s Clause 6).
Additionally, QCPP RULE 7 states “All re-accreditation assessments must occur within the period three calendar months preceding the second anniversary of the accreditation date, unless otherwise agreed between QCPP and the pharmacy owner. An assessment after the re-accreditation date must be requested in writing prior to the second anniversary date, illustrating exceptional circumstances that necessitate the request”.
Applications for extension or rescheduling will be assessed on their merits and the decision to grant the extension is entirely at the discretion of the QCPP. While all reasonable efforts will be made to find a mutually agreeable assessment date, should the pharmacy be unable to accommodate the most cost-effective date proposed by the assessment scheduling team, any additional expenses incurred in assessing the pharmacy will be invoiced to the pharmacy as an ‘Additional Assessment Expenses Invoice’ after the assessment, unless exceptional circumstances can be demonstrated.
Further information on the scheduling and booking process, along with links to the QCPP program rules and service agreement can be found below:
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Support available
If you have any questions, the QCPP Support Team is here to help — please email help@qcpp.com or phone the QCPP Helpline on 1300 363 340 (9am-5pm AEST).
To stay informed about Quality Care 2020, visit the Quality Care 2020 website. |
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