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Element 11 - Customer service

11.1.1 - This action seems to be the same as Element 1 Action 5. Why the duplication?

Although the evidence requirements for this Action and Element 1 Action 5 are identical, the Actions are different. Element 1 Action 5 is a requirement for consumer confidentiality from the perspective of the business entity, the pharmacy. Element 11 Action 1 is a requirement for consumer confidentiality from the staff perspective. Although similar, confidentiality is such an important requirement it was necessary to include it from both perspectives.

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

The pharmacy still must have a Confidentiality Policy. There won’t be any signed undertakings as there aren’t any staff members.

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11.1.3 - If new staff members sign a T12E Offer of Employment that includes requirements in relation to confidentiality, is this compliant?

Yes. Either a completed and signed Offer of Employment including the requirements in relation to confidentiality or a signed undertaking of the Confidentiality Policy are acceptable.
The signed Confidentiality Policy is the preferred option.

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11.3.1 - Where must the pharmacy’s T11C Customer Service Statement and Australian Charter of Healthcare Rights be displayed?

The Evidence Required at Assessment requires the Charter and Customer Service Statement to be publicly displayed. As it does not state where they are to be displayed, it will be up to the pharmacy to display them in a suitable location.
As the Charter and Customer Service Statement are meant for consumers to read, they shall be displayed in an area easily visible to the public. They may be adhered to a wall, counter surface or placed in a display stand if printed in a pamphlet or leaflet form. The approved adaptation to the Australian Charter of Health Care Rights is the Community Pharmacy Service Charter.

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11.3.2 - Element 1, Action 5 and Element 11, Action 3 requires the pharmacy to have access to 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. Pharmacies can display this document or the Community Pharmacy Service Charter. The Community Pharmacy Service Charter adopts the principles of The Australian Charter of Healthcare Rights and describes how it applies to community pharmacy.

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11.3.2 - Do the mandatory requirements of the pharmacy's T11C Customer Service Statement need to be displayed on a single document?

No. The requirement is that all mandatory information is displayed. If all mandatory information is displayed and visible to consumers (such as sign writing on a window front), the pharmacy is compliant with this requirement.

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11.3.3 - The T11C Customer Service Statement includes displaying alternate after hours services. How can I meet this requirement?

Displaying alternate after hour services on the T11C Customer Service Statement can be achieved in a number of ways. This may include, but is not limited to, promoting the find-a-pharmacy website, providing details of a late night pharmacy or an Emergency Health and Walk-in Centre.

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11.4.1 - Does each individual item need to be recorded on the pharmacy’s delivery register?

For the purposes of QCPP documentation, it is permitted for the delivery register to include a ‘count of items’ rather than individually listing each item for delivery.

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11.5.1 - When is delivering a prescription considered to be a delivery rather than Distance Supply, as per Element 2 Action 3? Has it anything to do with the number of medications being delivered?

No, it has nothing to do with the number of medications being delivered. If dispensed medicines are delivered by pharmacy staff, then it is considered to be a delivery and covered under the requirements of this action. If dispensed medicines are delivered by a contractor e.g. Courier, bus company, Australia Post, then it is considered to be Distance Supply and covered under the requirements of Element 2 Action 5 and will require compliance with the Distance Supply checklist.

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11.6.1 - What are some examples of third party service providers and is there any relevance as to the amount of time they spend at the pharmacy or in conducting their duties??

The amount of time a third party service provider spends either at the pharmacy or in conducting their duties is not relevant.  This action is relevant whether they spend a few hours or a few weeks providing services to the pharmacy. Some examples might include product demonstrators to the public, contracted consultant pharmacists for HMRs, weight loss clinics held in-store by external companies, photo sessions held at the pharmacy by an external company, DAA deliveries from the pharmacy by an external company to an aged care residential facility.

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11.6.2 - If a pharmacy does not engage any third party service providers, does it need a policy?

Yes. This Action has two possibilities.
If the pharmacy has not engaged any third party service providers in the past, but might in the future, it must have a written policy in preparation for the possible engagement of a third party service provider.
If the pharmacy's policy is never to engage a third party service provider, then this must be documented as the pharmacy's policy.

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11.6.3 - When a Third Party Service Provider is delivering a service within the pharmacy, do they need to comply with the requirements of the Element?

Yes. If the service being offered is described in Element 2 or 3, then the Third Party Service Provider will need to meet the mandatory requirements of these Elements. It is the responsibility of the pharmacy to confirm that the Third Party Service Provider complies with the Element and any relevant policies, procedures and checklists. The Assessor will seek evidence that the pharmacy has implemented the requirements.

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