ASAIPA objects to proposed legislation broadening pharmacists’ Scope of practice

Surely this is NOT in the best interests of patient-centred care…


ASAIPA together with the Unity Forum of Family Practitioners banner have joined other concerned practitioner bodies such SAMA, IPAF, African Viral Care Society (AVCS) and the SA Society of Obstetricians and Gynaecologists with formal objections to
the proposed Pharmacy Act amendments being tabled to broaden the scope of pharmacy practice,
The amendments in question are the Board Notice 17 of2021 – Pharmacists who provide Pharmacist-Initiated Management of Antiretroviral Therapy (PIMART) services in South Africa (Board Notice 17); Board Notice 71 of2021 – Rules Relating to Good Pharmacy Practice (Board Notice 71); and Board Notice 102 of 2021.

Objection against PIMART


In our correspondence and formal submissions to the Department of Health, HPCSA and SA Pharmacy Council, we have drawn their attention to the inappropriateness and potentially dangerous consequences of increasing a pharmacist’s scope of practice. As a collective, we believe this will undoubtedly compromise the quality of care that patients are entitled to and, frankly, will not be in the best interests of any patient.

“scope of practice” cannot exceed the scope of the professional

SAMA CPD Accreditation committee rejecting to accredit the SA HIV Clinicians Society’s Pharmacy Initiated Management of Antiretroviral Treatment(PIMART) online course.
Board Notices 17 & 71 are in conflict with the Current Legislative Framework. Schedule 4, Schedule 5 and Schedule 6of the Medicine and Related Substances Act, 1965 require the prescription by a medical practitioner.

The Health Professions Act, 1974 also states that no person may examine, diagnose or treat another person with in the Republic unless registered with aboard under the HPCSA (or nursing council). The Act also requires that a practitioner must undergo training that is approved by the HPCSA. Thus any person not registered with the HPCSA/SANC that practices medicine is guilty of an offence.

Whilst we appreciate the initiative to improve patient access to care as well as the response time between HIV treatment and the time of diagnoses, we cannot favor speed over the safety, morbidity and mortality of the patient. The diagnosis, treatment and management of HIV cannot be oversimplified to an over-the counter transaction. It requires a conductive and confidential environment, careful history taking, exploration of potential risks and contact tracing.

The concerns of the ACVS are very similar to ours. The ACVS referred to the Pharmacy Council’s proposed 160 hours/7days course for pharmacists and wrote in their letter to the president of the HPCSA: “We submit that the proposal and its conduct amount to a simplistic papering over of the health issues it seeks to address, with the effect of putting patients’ health at an unwarranted risk. Pharmacists are not primarily trained to treat patients and the PIMART proposal is therefore tantamount to the hijacking of the medical profession/practice for an objectionable purpose.”
We concur!

Dr. Unben Pillay

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