Provisional Registration for Pharmacists

August 17th, 2020 General Pharmacy | Pre-reg No Comments

August sees the first applicants join the GPhC’s newly-introduced provisional registration for pharmacists.

The 2020 pandemic presented pharmacy with many challenges to overcome, for example, sourcing PPE, dealing with frustrated or fearful customers and avoiding burnout.

Likewise, one of these challenges was the uncertainty faced by pre-reg pharmacists about whether they will get to qualify in 2020. Because of social distancing, taking the assessment is currently unfeasible and this puts trainee pharmacists in limbo.

So, the GPhC’s provisional register is the compromise to get trainees into jobs as qualified pharmacists.

Why are pre-reg trainees receiving provisional registration?

Normally, the registration assessments for pharmacist trainees happen in June and September. But for 2020, the coronavirus pandemic will disrupt both of these intakes.

So, instead, the GPhC has created a provisional register that allows pre-reg trainees to work as qualified pharmacists before passing the exam.

The GPhC acknowledges the hard work of trainees and tutors. The council hopes that this policy will balance the risks to patient safety with the need for bringing new pharmacists into the profession during a time of increased healthcare pressures.

What is the eligibility criteria for provisional registration?

The register is now open, however, only for candidates who meet certain criteria. The criteria for joining the register include:

  • – Successfully completing 52 weeks of pre-reg training.
  • – Not having previously failed the registration assessment.
  • – Receiving a final declaration from their tutor that they have met all the 76 performance standards.
  • – Self-declaring that they are fit to work as a pharmacist.

Once on the provisional register, there will be limitations on the new registrant, however:

  • – Provisionally-registered pharmacists will only be able to work as employees.
  • – Prov-reg means you can’t yet work as locum pharmacists, either as a self-employed locum or through a locum agency
  • – Will need to work under the supervision of a senior pharmacist but can operate as the responsible pharmacist.
MLC Provisional Register Pharmacists 2020

Is the provisional registration temporary?

Yes. Passing the registration assessment is still a requirement for becoming a fully-registered pharmacist. And until the assessment is taken, candidates remain on the provisional register and have to abide by its limitations.

The GPhC expects all provisionally-registered pharmacists to take the assessment as soon as it is possible. Either when the easing of lockdown or social distancing measures allows for testing at universities or assessment centres. Also, the assessment will be available as an online exam that the council is currently working towards producing.

In addition, the status granted by the provisional register plus the register itself is temporary. In other words, the register will close for new applicants on 1 July 2021.

How will this affect businesses that employ provisionally-registered pharmacists?

Employers will need to complete a risk assessment before the provisionally-registered pharmacist starts work. The risk assessment will need to consider:

  • – The registrant’s experience and the sectors in which they took there pre-reg training.
  • – The volume and nature of services carried out where the registrant will work.
  • – The numbers and qualifications of other members of the pharmacy team.

The employer will also need to ensure that the registrant will work under the guidance and direction of a senior pharmacist. The senior pharmacist must either be:

  • – The pharmacist-owner (if owned by an individual pharmacist)
  • – A superintendent or chief pharmacist
  • – A pharmacist of at least two-years experience nominated by the superintendent or chief pharmacist.

The senior pharmacist must be contactable by the new registrant for advice and to give direction where needed. They will also need to provide reports to the GPhC on the registrant’s conduct and performance and carry out monthly reviews of the risk assessment outlined above.

Supporting provisionally-registered pharmacists

Not being able to take the pre-reg exam and become a fully qualified pharmacist will certainly be a frustration to trainees. Many may see this as their careers being put on hold because of the pandemic.

It takes a great deal of hard work to qualify as a pharmacist, as indeed it also does to tutor and mentor trainees. Therefore, it’s important that employers and provisionally-registered pharmacists accept that no one is to blame for the situation.

Why not have an open discussion at the start of employment that gives the provisionally-registered pharmacist an opportunity to express their frustrations or concerns about the situation? This may help you understand each other better in the long run.

Being provisionally-registered is not a slight on the abilities of the pharmacists involved. In other words, employers should treat prov-reg pharmacists no differently than if they are newly qualified pharmacists (other than the guidelines laid out by the GPhC above). As such, this should include the offered salary and benefits.

Sitting the assessment

The new registrants will still need to sit their registration exam. Normally, this happens during their time as pre-reg trainees. But because of the current situation, the assessment will instead happen as full-time employed pharmacists.

The GPhC has said that two months notice will be given to prov-reg pharmacists ahead of their exam dates – either online or at university assessment centres etc. During this time, the registrants will need extra support to study and prepare for the examination.

This burden doesn’t typically fall on employers. But employers are encouraged to support the soon-to-be properly registered pharmacists by allowing them sufficient study time.


Overall the provisional register seems a good compromise given the situation. Would you agree?

Please let us know your thoughts about being a provisionally-registered pharmacist:

  • – Are you seeing fair salaries being offered?
  • – What are your concerns for the year ahead?
  • – Will you be employing provisionally-registered pharmacist in your pharmacy?

This post was written on behalf of My Locum Choice by Nicola Hasted from Pharmacy Mentor.

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