Starting an internship in Australia seems like a major milestone. You actually gain Australian pharmacy experience, work under the guidance of experienced professional, prepare for pharmacy registration exams and get accustomed to the local healthcare environment.
Yet there is one aspect of pharmacy practice that many pharmacy interns wish they knew more about: the resolution process when a patient, colleague, employer or another healthcare professional raises a concern.
My foremost discovery when researching the Australian regulatory pathway was that: an AHPRA notification does not automatically mean that an intern has done something wrong or will lose registration. A concern is assessed first, and different circumstances can lead to various outcomes. According to AHPRA, notifications can be closed at the assessment stage, managed through regulatory action, referred for investigation or sent for a health, performance or professional standards assessment depending on the circumstances.
This guide explains what pharmacy interns should understand, what can trigger a notification, how the pharmacy board complaints process Australia works, and what you should do if a concern is raised about you.
What is an AHPRA Notification
AHPRA uses the term notification "for a concern raised about a registered health practitioner or student." Concerns can vary from health, performance and professional conduct. As an intern pharmacist you are not exempt from the regulatory system simply because you are still completing supervised practice.
Intern pharmacists are required to undergo supervised practice as part of the pathway to general registration. Pharmacy Board of Australia has resources to pharmacy interns and preceptors noting the professional responsibilities interns have while completing their supervised practice.
A notification can arise from something such as:
- an allegation of unsafe practice
- significant concerns about professional conduct
- concerns about impairment
- practising while intoxicated
- significant departure from appropriate professional standards of practice
- allegations of sexual misconduct
- concerns about compliance with registration conditions.
Not every workplace disagreement or mistake will result in an AHPRA notification. Contractual or commercial disputes, issues with timekeeping, absence or disagreements about professional practice generally do not, by themselves, require a mandatory notification.
Complaint vs Notification: Why the Difference Matters
When a patient raises a concern they may use the term complaint whereas AHPRA refers to notifications. This does not mean that all patient complaints require intervention. First the Pharmacy Board or relevant regulator needs to assess if the complaint falls under their jurisdiction and if it requires notification.
The National Boards will evaluate the concern and its potential impact on the public before taking any action. It can also depend on the state or territory as AHPRA is the regulator but NSW and Queensland have separate health-professional regulatory authorities. In these states complaints need to be directed to the NSW regulator or Queensland’s Office of the Health Ombudsman. Mandatory notifications in NSW still need to be reported to AHPRA.
That is an important detail international pharmacy graduates sometimes miss.
What Can Trigger a Mandatory Notification?
Mandatory notifications have a much more specific legal threshold than an ordinary concern.
AHPRA lists four categories of practice that may result in a notification for a registered practitioner:
- impairment
- practising when intoxicated
- significant departure from appropriate professional standards of practice
- allegations of sexual misconduct.
A mandatory notification is not supposed to be based on gossip or rumours. A person making a notification must form a reasonable belief that the event or behaviour listed above has occurred and that the public risk threshold has been met. Different public risk thresholds may apply depending on who makes the notification. For example, a treating practitioner, non-treating practitioner, employer or education provider.
Let’s say, for example, that you made a dispensing error as an intern pharmacist. You promptly informed your supervisor pharmacist, participated in the incident review process and ensured that the patient received the most appropriate care.
The fact that an error occurred does not automatically mean you will receive regulatory disciplinary action.
The regulatory focus is much broader: what happened, the seriousness of the concern, the practice context, the practitioner's response, the steps taken to prevent recurrence and whether an ongoing risk exists.
When considering the response to a notification the following factors should be taken into account:
- The circumstances of the concern
- The context of the practice
- The practitioner’s regulatory history and
- The measures taken and the response by the practitioner and workplace to address the concern and mitigate any risk to the community.
That is why immediately hiding a mistake can potentially create a much bigger professional problem than honestly reporting and managing it.
The Pharmacy Intern's Professional Responsibilities
One mistake I see amongst overseas-trained healthcare professionals is that they may significantly underestimate the importance of documentation, communication and appropriate professional conduct when starting their careers in Australia.
Registered pharmacists and interns are bound by the AHPRA Code of Conduct. The code details standards, including the expectations around communication, privacy, complaints, record keeping, patient safety, professional relationships and insurance.
The roles and responsibilties of an intern pharmacist are as follows:
- Accurate Documentation: Records must be factual, objective, timely, legible and sufficiently detailed to allow for the continued care of the patient.
- Privacy and confidentiality: Patient information cannot be disclosed publicly without permission. Appropriate privacy protocols must be followed when accessing or storing digital information.
- Professional Communication: A disagreement with a patient, pharmacist, doctor or another professional should be addressed in a manner that is solution-focused and appropriately professional.
- Working with competence: As an intern pharmacist you have provisional registration and must work under the supervision of a registered pharmacist. Asking for guidance from your supervisor is a regulatory response when you are uncertain about a task.
- Responding to a complaint: Pharmacists must cooperate with the authorities and provide a detailed response on time when a complaint is received.
Building Professional Judgement Alongside Exam Readiness
Studying for the Australian Pharmacy Intern Written and Oral Exam is not only about memorising clinical facts.
The oral examination preparation offered through Academically's Australian Pharmacy Intern Written and Oral Exam Preparation Course includes legal and ethical work, solving problems, communication and handling cases along with medical topics. The course now has live and recorded classes and also offers personal help and support from the instructors.
This connects to this subject because many of the problems that happen with pharmacists and interns are not about medical work but also about legal issues, keeping records, communicating with people and solving issues.
An intern who works through case-based problems is more likely to be ready when they face a situation in real life.
What Happens After an AHPRA Notification?
The process can look complicated, but the broad structure is easier to understand.
Stage 1: Initial assessment
AHPRA will first determine whether a notification relates to a registered or enrolled practitioner or student. It will also consider whether the National Law allows for the matter to be dealt with by the National Boards.
The information is then assessed in relation to the practitioner’s workplace, practice area and public health risk.
AHPRA will aim to complete the assessment within sixty days in most cases but the timeframe can be shorter or longer depending on the matter.
Stage 2: Possible outcomes
It is also important to note that an initial assessment does not always lead to an investigation. The National Boards can choose to close the matter, take regulatory action (such as imposing conditions or accepting an undertaking), refer the matter to an appropriate authority or investigate the notification.
Stage 3: Investigation
An investigation can occur if the National Boards are not satisfied with the outcomes of the assessment. The scope can be broad, including determining whether the events stated in the notification have occurred and whether the practitioner has adhered to the standards, codes or guidelines. The investigator can request information from the notifier and the practitioner, including their workplace.
At the end, the matter can result in no further action, conditions, an undertaking, a caution, referral to another organisation, further assessment or a professional standards panel or tribunal process.
Can AHPRA Suspend an Intern?
Yes, but immediate action is an interim protective measure rather than the ordinary automatic response to a notification.
A National Board can impose conditions on a pharmacist’s registration, if it considers that there is a risk to the community and that action is necessary to protect the community health and safety. You should also know that you have the right to a "show cause" hearing before such measures are imposed.
This is another reason why you should not dismiss an AHPRA notification as something that can be ignored until later.
What Should You Do If You Receive a Notification?
This is the part I would want every intern pharmacist to save.
1. Do not panic or immediately assume the worst
A notification is an expression of concern and should be taken seriously but it is not an indication that you will automatically face disciplinary action.
2. Read the notification carefully
It is important to understand what concern has been raised, what information has been requested and what the response timeframe is.
You should not respond to an allegation with an informal email. Take the time to understand the content and the context of the notification.
3. Inform the appropriate support person
Depending on the nature of the concern you may need to contact your professional indemnity insurer, a lawyer, professional association or another relevant third party for advice. Practitioners should seek advice from their insurer or legal representative if they are facing action.
4. Preserve your records
Do not delete or alter any records after a concern has been raised. Maintaining records is a professional obligation and records should be factual, objective, timely, legible and sufficiently detailed to allow for the continued care of the patient.
5. Respond factually
When responding to a notification, explain what happened, what you knew or should have known, what supervision was available, what actions were taken and what you have learned from the incident.
Defensiveness will not help you in explaining what has occurred and how you responded to the situation.
6. Demonstrate risk management
When you reply to a notification a main thing to include is your plan for managing and reducing risks. This can involve checking, doing some extra learning, making better notes or talking about the event with your mentor and manager to make sure it does not happen again.
Checklist for Every Pharmacy Intern
I would suggest that all pharmacy interns follow these rules while they work in Australia:
Know your registration status:Understand exactly what provisional registration and supervised practice permit you to do.
Know your supervisor: Always know who your pharmacist supervisor is and when to ask for help.
Know your code of conduct: Be aware of the standards you are expected to follow because a complaint or notice will not be the time you hear about it.
Document properly: Your records should show the right medical story.
Keep information safe: Treat digital health records and other electronic data as carefully as paper records.
Report errors properly: Always tell about mistakes, problems and almost-mistakes in a way. Your safety rules might be tested at some point in your work.
Keep evidence of professional development: Training, feedback, remediation and reflective learning can become important evidence of how you manage professional risks.
Never ignore regulatory correspondence: Deadlines are always important in pharmacy work.
Final Thoughts
My advice to a pharmacist intern would be to learn about the rules and the way things work before you need to use that knowledge. Understanding AHPRA notifications for pharmacists covers the things you need to know when you have a problem. However, it is not the same as getting help and you should always talk to a person you trust if you get a formal notice.
The AHPRA process is meant to check risks to the public and fix them which means that not all notices lead to results and not all checks mean you will have limits on your work. The best way to avoid problems is to build habits by asking for help when you are not sure communicating well, keeping good records, working within the limits of what you can do and being honest when you are asked about any issues or claims.
With this mindset you will be ready, for your pharmacy training, your exams and the whole pharmacy career that is waiting for you in Australia.
