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PSNIDecember 9 2015

The Pharmaceutical Society of Northern Ireland is consulting on registration fees for 2016-17 as well as the regulatory fee structure.

It follows a review of the fee structure used in recent years which found inconsistencies in approach, including certain regulatory discrepancies. The effect has been that charges have been increased without the required legislation in place and that some of the fees should not have increased since 1994.

In its consultation document, the Society says that in the review of the 2014-15 review of fees, the Department of Health, Social Services and Public Safety had been asked to approve amendments to some of the fees levied by the Society. “During this approval process it became clear that there were a number of irregularities with the fees charged and that not all of the fees were consistent with the regulatory fee structure.”

This resulted in an immediate and extensive review of how fees had been charged in the past. “As a result, it became clear that over a period of years some registrants and prospective registrants were charged fees for services provided on the basis of a fee structure that was not wholly reconcilable with the regulations.” Those most affected were students registering with the Society and those taking the pre-registration exam.

A letter sent to registrants said that substantive amendments to fees made in 2009 did not incorporate some of the changes that the Society had requested, but this had not been recognised until the 2014-15 review. The annual retention fees for registrants outside the categories stated in the letter have been unaffected.

Explaining how the Society intended to proceed, the letter stated: “The Council has given serious consideration including the taking of legal advice concerning any potential liability to repay sums charged in excess of statutory authority to any affected persons.

“We do not consider it appropriate or equitable to refund any of the sums that have been charged in excess of statutory authority and an explanation why we arrived at this decision is set out in the following paragraphs.”

In essence, the Society says it will not refund fees as it has only used the fee income to “legitimately pursue” the objects of the Society as set out in statute, that it has been acting in good faith at all times, and that:

  • it has a duty to be fair and equitable to all registrants, past, present and future;
  • all fees that have been charged have been commensurate with the actual services provided;
  • amendments to fees charged have, routinely, been publicly consulted upon;
  • all fees charged are published on the Society’s website.

The outcome is that the Society is now comprehensively reviewing its fee structure and the legislative basis for doing so with the aim of ensuring that the future fee structure is fair.

It is asking that the DHSSPS agree that:

  • the registration fee rise from the £372 which has been the fee since 2009 to £398 for 2016-17
  • the student registration fee increase to £206 for 2016-17, up from the £194 it has been since 2009
  • the pre-registration exam fee increase from the £164 it has been since 2009 to £174 in 2016-17.

The consultation runs until January 25 2016.

Links:

PSNI announcement

PSNI consultation document

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