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President addresses historical anomalies in Fees Regulations

Following the meeting of the Council of the Pharmaceutical Society of Northern Ireland, held on 14 September 2015, President of the Council, Dr. Jim Livingstone said:   “Each year we raise money through fees to fund operations and services in pursuit of our statutory duties. In doing so we seek to maintain and uphold the high standards expected from the profession of pharmacy and to act in the public interest as regulator. These fees are required to be included in Regulations which are approved by the Department of Health Social Services and Public Safety (DHSSPS) and the Northern Ireland Assembly.

In the course of the 2014/15 review of these fees, which was the subject of public consultation, the DHSSPS was requested, under Articles 5 and 25A of the Pharmacy Northern Ireland (Order) 1976, as amended, to approve our proposed amendments to some of the fees levied.

During this approval process it became clear that, in the last round of substantive amendments to fees in 2009, some of the changes we had requested at that time had for some reason not in fact been incorporated in new Regulations as we had expected.

The Council initiated an immediate and comprehensive review of fees charged and their historic legislative basis. As a result, it became clear that a number of anomalies had arisen over a period of twenty years such that some registrants and prospective registrants were charged fees for services provided on the basis of a fee structure that was not consistent with Regulations. In particular, this affected the registration of students and those taking pre-registration examinations.

Following exhaustive enquiries, the Council is satisfied that at all times we have acted in good faith and at no time did we deliberately or knowingly authorise the charging of a fee in excess of its statutory authority. The fee structure has always been openly published and Council has always consulted with registrants about any proposals to amend fees, setting out the details of the proposed amendment, the rationale behind any such change, and why funds were needed.

The Council is also satisfied that all fees charged were commensurate with services provided in the interest of public safety, development of the profession and upholding the reputation of the profession.

In order to address this situation the Council of the Pharmaceutical Society has taken a number of clear steps. Firstly, we have written to all registrants detailing those groups of registrants which may be affected by the historical anomalies in the fee structures. Secondly, we will imminently be launching a consultation document on proposals to set out a revised statutory basis for all future fees which is more coherent and integrated, with the objective of avoiding any reoccurrence of the current development. Further information regarding this situation can also be found in our Annual Report 2014/15.

This is for all concerned, undoubtedly an unwelcome situation and one which the Council sincerely regrets. We have taken immediate and robust steps to ensure that a sensible and comprehensive solution is put in place that will prevent any future reoccurrence and at the same time maintain the effective operation of the Pharmaceutical Society NI in accordance with its statutory duties”.

Further information can be found here: