A comparative analysis of disciplinary outcomes for pharmacy professions in the United States and Great Britain

Earlier comparative scholarship on physician regulation has revealed marked differences in disciplinary outcomes between the United States (US) and Great Britain (GB), the latter of which imposes more severe sanctions for comparable misconduct. This article extends the inquiry into pharmacy regulation to determine whether the identified divergence is unique to medical regulation, or whether it is representative of broader features of the procedural structures that govern professional discipline, by comparing the disciplinary outcomes from each of the US and GB for a 10-year period concluding with the latest publicly available data.

A quantitative comparative analysis was undertaken on a dataset comprising of disciplinary decisions issued over a ten-year period concluding in June 2025: a total of 22 129 cases; 21 561 (97%) of which occurred in the US and 1868 (3%) in GB. Sanctions were coded into four condensed categories: warnings, conditions, suspension, and erasure, and analyzed using Pearson's chi-squared testing to assess differences in disciplinary severity between the jurisdictions.

The results revealed a significant transatlantic difference in disciplinary outcomes against pharmacy practitioners: 79% of GB cases resulted in severe sanctions, whilst only 38% of US cases did so, with lenient sanctions prevailing in the US, closely replicating earlier findings relating to the discipline of doctors.

While some level of self-regulation is inherent to being a profession, the current extent in the US is excessive. Although professional autonomy is deeply rooted, it shouldn't be immune to reform, especially given growing evidence that professions are failing to uphold their responsibilities to the public. It is evident that our findings are not profession-specific, instead pointing to wider features of regulatory design and execution. This study contributes new empirical evidence to scholarship on the design of professional regulatory structures and cross-jurisdictional consistency in professional discipline and highlights the need for further research into the correlation between regulatory design and disciplinary outcomes.