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Element 1 - Compliance with legal and professional obligations

1.1.1 - What is the process for the T1A?

A pharmacy signs a T1A Legal and Professional Obligations Declaration for a two year period and must ensure a signed T1A is available for QCPP Assessors to sight at the time of assessment. This change has been implemented in Requirements Manual Update #4 which was distributed to pharmacies in January 2014
 

1.2.1 - Will the Assessor check if the pharmacy complies with all legislative requirements?

No, the evidence required by the Assessor for compliance with this Element is the signed T1A Legal and Professional Obligations Declaration. It is the pharmacy proprietors or managers responsibility to ensure compliance with legislation before signing the declaration. Once the Assessor has sighted this document, the pharmacy is deemed compliant.

Assessors are not legal experts and only check for compliance with the QCPP Elements. There may be instances where a QCPP requirement is enforceable by another authority. In such cases, the Assessor is checking for QCPP compliance and not for legislative requirements. While it is noted that legislation in QLD requires an employee to be 16 years of age or older to be involved in the supply of pharmacy medicines and pharmacist only medicines, Assessors are not required to check the ages of the staff as the T1A is a declaration by the pharmacy that they are fulfilling their legal obligations.

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1.2.2 - What should I do with my signed T1A and where do I keep it?

Commencing in 2014, the T1A will be retained in the pharmacy records and will be sighted by the Assessor at your assessment. There is no requirement for the sighted T1A to be sent to QCPP.

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1.5.1 - If a pharmacy does not employ any staff does it need a Confidentiality Policy and signed undertakings?

Yes, the pharmacy still must have a Confidentiality Policy but as there is no staff, there will be no signed undertakings.

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1.5.2 - Element 1, Action 5 and Element 11, Action 3 requires the pharmacy to have access to and display the Australian Charter of Healthcare Rights. What is this document and how do I meet the requirement?

The Australian Charter of Healthcare Rights specifies the key rights of patients and consumers when seeking or receiving healthcare services. The Community Pharmacy Service Charter adopts the principles of Healthcare Rights and describes how it applies to community pharmacy. Pharmacies can display either of these documents, providing consumer access and therefore meeting the requirement..

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1.6.1 - As proof of maintaining the various insurances, can the pharmacy show the Assessor the annual invoice or policy document?

Evidence must either be a Certificate of Currency from an insurance company or a Certificate of Insurance from an insurance broker.
The certificate notation on the document should be clearly identified and the certificate can only come from either an insurance company or an Insurance Broker.

1.6.2 - Can a pharmacy have a combined Certificate of Currency for Workers' Compensation rather than an individual policy for each pharmacy?

In the event a combined Workers Compensation policy (or a combined Certificate of Currency) is in place for a pharmacy group, the policy must list by name the individual pharmacies that are covered by the combined Workers Compensation policy.

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