Is there a pragmatic way through the provisional registration problem?


In response to the following article:


Dropping the pre-reg exam – an overview of arguments


Dear PIP editor,


Thank you, Greg Lawton, for providing structured arguments to this debate.


I would like to provide some counter-arguments or clarify a few things provisionally registered pharmacists (provregs) are asking for. These are my opinions and I can’t speak for every provisionally registered pharmacist but as a Pharmacist Defence Association (PDA) representative and Royal Pharmaceutical Society (RPS) South London committee member, I may have some idea.


Firstly, let us not confuse the calls for the exam with the key issue of communication from the General Pharmaceutical Council (GPhC). Regardless of what you think about the exam, they have handled this poorly compared to universities and other professions. We want clarity which they have not given in six months. We wanted to raise awareness and force the GPhC to at least push this issue higher up their priority list for everyone’s, including the public and employers, sake. I believe we have done that.


Hopefully, I have expressed myself well. One thing I would like to make clear is the difference between the clinical and calculations exam. I completely support the need to sit the latter. It is the former I have an issue with. The skills and knowledge required for the calculations exam are reflective of practice. The memorising of information is not.


Below I have responded to Greg’s points. Greg’s points are in bold blue writing.


1. In employment law, you’re a pharmacist if you’ve worked as one.


Answer: In employment law, if you’ve had certain arrangements for a period of time, you can acquire the status of ’employee’ or ‘worker’. It doesn’t change your profession and has nothing to do with regulation.


I personally agree with Greg for the first one. Regulation is different and it should be.


2. There’s a global pandemic.


Answer: This is unrelated to the need for an exam. Other professions are not campaigning for their exams to be scrapped. They have sat them and understand why they’re needed.


Greg’s argument is factually incorrect. Other professions, particularly healthcare professionals, have had their exams scrapped due to Covid.


3. Provregs will have practised for months, so surely it would be safe.


Answer: Absence of evidence of risk is not evidence of absence of risk. You’d have also been practising to be a pharmacist for 12 months as a pre-reg, but still, some 25% fail the exam.


Medicine related incidents in hospital increase every year when the new FY1s and Pharmacists start regardless of being qualified. Unfortunately, it’s never going to be completely safe. One of the reasons for this is that the clinical aspect of the exam does not reflect practice. The calculations exam does in my view. But that’s not the point, is it? It’s about reducing risk. See the next argument.


4. Provregs will have practised for months so surely they’d be competent.


Answer: In that case, the exam shouldn’t be a problem, and if they completed it, it would give the public the assurance that it deserves.


The majority aren’t saying ‘scrap the exam and leave us be’. Instead, we are asking is there a different way to prove that we are competent in these exceptional circumstances. Do you [Greg] believe that the exam is the only way to prove knowledge and competence? Perhaps agree to disagree but I certainly don’t think so. In fact, I don’t even think it’s the best way.


5. It’s been really challenging during Covid.


Answer: Everyone understands that, and they sympathise and empathise. But it’s not about you, it’s about patients and the public. The public.


I agree this shouldn’t influence the need to ensure patient safety but again is the exam the only way to do this and is it the best way during a pandemic? Online has many issues, cheating being foremost and therefore the integrity of the register is not protected. Doing it in person would be counterproductive considering the risk to patients. I would sit with 1000’s of students then see my patients the next day? Not smart. There is definitely a logistical issue which cannot be ignored and therefore we are asking, is the exam the best way to prove we are competent during a pandemic?  If so, then so be it.


6. The exam is just parroting the BNF, so it’s not required.


Answer: The content of the exam is a separate discussion. But if it was really just parroting the BNF, it shouldn’t be a problem as all you have to do is demonstrate that you can use the reference source.


See point above about the difference between exams. At the moment, the exam is the gatekeeper to becoming a pharmacist. Perhaps I am not experienced enough to even comment but speaking to pharmacists who are experienced educators, all of them (yes, every single one so far) has told me that the ones they worry about aren’t necessarily the ones who pass and vice versa.


7. Pharmacists are saying “we had to do an exam, so should you.”


Answer: Have any really said that, or is that what you think they think? If they have, they’re missing the point. It’s about the public, not what they had to do.


Don’t belittle us. Pharmacists are definitely saying that. Just see @ThePharmacist35. But I agree we shouldn’t waste our time with this as you rightly say later, practice evolves maybe its time to evolve again.


8. Pharmacists won’t treat us the same if we don’t sit the exam.


Answer: See the last sentence in no. 7. 


This is sadly true and my biggest reason for wanting to sit the exam. I don’t like people thinking I have been given a handout. But as you have said, it’s about the public, not pharmacists’ opinions.


9. There are pharmacists on the register who didn’t sit an exam.


Answer: Practice evolves. Before 1868, people didn’t need to be pharmacists or have a degree to sell dangerous drugs. So by extension of your logic – if it was once okay then it must be now – we could do away with the degree and the profession too.


Again, evolving and patient safety should be the only concern. So I will ask again, is the exam the only and best way to prove competence, and thus ensure patient safety, during a pandemic? If so, can it logistically be done? If not, what is option 2? This also answers 13, 14 and 16.


10. I’m busy, I don’t have time to sit it.


Answer: Working life do be like that, but it’s not about you. It’s about the public. The public. The people you’re joining a profession to care for and protect.


The issue here is that the exam requires study which requires time. Not only will we be working full time, but we will also be working during the second wave and won’t get the same support. People will fail who would otherwise have passed and this proves that it will not reflect competence or practice.


11. They shouldn’t have put us on the register in the first place if they were going to insist on an exam!


Answer: Necessary or not, it was always provisional, a balance of risks in a global pandemic. You accepted this, along with other conditions, when you voluntarily applied to join the register, and have been paid for your role.


The GPhC are to blame for this, not provregs. Perhaps we shouldn’t have gone on the register but we are here now. We did sign up for it and we have no choice in the decisions made. The biggest issue is the lack of clarity from the GPhC.


12. There haven’t been any FtP issues to date, so what’s the problem?


Answer: Evidence of this? FtP cases can take two years to progress. Also, it’s not about immediate FtP issues being apparent, but risk.


I don’t think this proves or disproves the need for the exam or a different method of proving competence. Is there a link between no exam and FtP? I don’t know.


13. Employers would support this too! They’d sign off the provregs!


Answer: I’m sure they would, they’d have a vested interest in it.


14. Provregs have done a stellar job during the pandemic.


Answer: Notwithstanding their commendable efforts during the pandemic, this is unrelated to the need for an exam.


15. I’ve worked in hospital, I’m confident I’ll pass.


Answer: Think beyond yourself. The discussion is about the entire cohort.


I am guilty of this but I did work in community pharmacy for three years. I don’t think any of my arguments are specific to hospital or community pharmacy. Correct me if I’m wrong.


16. I’ve had pharmacists telling me I’m right. In fact, they’ve even liked and retweeted what I said!


Answer: Welcome to pharmacy Twitter, where some people’s self-interest, self-promotion and narcissism know no bounds!


Thank you for this opportunity to express my views and reply to some of Greg’s points. Let’s all hope we see a swift resolution to the current situation.


Yours etc.


Jonny Blatchford


Provisional pharmacist



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