Since 2020, Nepuga/FAPUGA, a Higher Education Institution accredited by Brazil's MEC (Ministry of Education), has been working with the Regional and Federal Pharmacy Councils (Brazilian professional councils) to obtain the unprecedented and immediate endorsement (apostilamento, an official annotation on the certificate) of certificates issued by the University Extension Courses in Ozone Therapy.
Since open courses are not regulated by the MEC, CFF Resolution 674/19 was created precisely to oversee such courses offered by schools and institutes that do not follow any kind of formal education criteria, imposing minimum quality standards on informal pharmaceutical education.
However, countless pharmacist ozone therapists across Brazil, trained through Nepuga/FAPUGA's University Extension Course in Ozone Therapy , contacted the IES reporting that their respective regional councils did not want to recognize the certificates they had earned with so much effort.
Knowing this, Nepuga immediately, through its legal department, prepared all the documentation needed to demonstrate and substantiate that the extension course offered not only meets the requirements of Resolution 674/19, but exceeds them all, because it is offered by an IES that is subject to the MEC's rules and guidelines.
Since Nepuga has faculty with appropriate academic credentials (master's and doctoral degrees) and professional experience in the job market, and excellent physical facilities with laboratories and clinical practice environments, this implies high-quality teaching and conditions that meet the demanding evaluation criteria of the Ministry of Education for Higher Education.
As a pioneer of Aesthetic and Integrative Health in the country, Prof. Ma. Dr. Ana Carolina Puga understands her role as a representative of healthcare professionals in this scenario and is concerned about the pharmacist's place in the job market.
“With the pandemic, many professionals were hit by restrictions on practice, and aesthetic pharmacists were no different. However, during this period they could still study and earn new qualifications, such as Ozone Therapy, in order to prepare for the job market. But since the pharmacy councils delay the release of the qualification, even when everything complies with MEC guidelines, they also end up delaying these professionals' independence and financial autonomy. And I, and Nepuga, cannot accept that”, says Dr.
CRFs are required to recognize Nepuga's Ozone Therapy Extension Course
Despite this resolution existing, to this day there is no record of an actual open course that has been approved by the councils. So what is such a resolution for? Is it to create a market reserve? Is it to choose who can or cannot have an endorsed course in order to work in the market? Is it to create difficulties for some and ease for others? As an answer, let us analyze the following text.
Law 3,820/60, which creates the Federal Council and the Regional Councils of Pharmacy and determines their duties in Article 6, leaves no doubt that the council's role is solely to establish rules on professional practice.
The supervision of Higher Education Institutions and of undergraduate and sequential higher education courses in the federal education system was established by Law No. 10,861 of April 14, 2004, and regulated by Decree No. 5,773 of May 9, 2006. According to the law, it is expressly stated that only the MEC may oversee IES with the aim of ensuring conformity between the offering of higher education and current legislation.
Pharmacy Councils do not oversee IES, only the professional's practice
Given this clear division of responsibilities, it is very obvious to conclude that no council can ever oversee formal education, as that is the exclusive role of the Ministry of Education. Likewise, the MEC is barred from intruding on matters of professional practice in any profession. And the MEC does not intrude!
When pharmacy councils try to exercise the power to oversee formal education, a jurisdiction for which they have neither legal authority nor institutional vocation, they end up creating a series of disruptions and difficulties for their member professionals in the middle of a pandemic.
Instead of worrying about protecting society from bad professionals, fighting to expand pharmacists' field of professional practice, and seeking greater recognition of the pharmacy profession, which are the truly legitimate actions of a council, they seem to prefer expanding their powers by irregularly overstepping their jurisdiction and delaying pharmacists' progress just when they most need to work with ozone, a service in such demand during the pandemic.
What stands out to us most is that the councils are fully aware that they could never interfere with the autonomous acts of IES to the point of intruding on the MEC's exclusive powers, such as refusing for any reason the endorsement of any certificate issued by an IES accredited by the MEC.
There are countless court decisions, if not all of them, against professional councils when they try to intervene in formal education. The councils and their managers cannot ignore these facts. There is even a bill in progress, Bill 3,979/19, that regulates the activity of federal professional councils for regulated professions.
The proposal applies to all federal professional councils, and the text defines them as special autarchies and parastatal entities created by specific law, endowed with legal personality under public law and administrative and financial autonomy, whose purpose is clear: to oversee professional practice and issue resolutions, defining or modifying the duties or powers of duly registered professionals.
Pharmacy Councils may advise IES when the MEC allows it
The only exception for a council to move forward in seeking improvements in education is when the MEC opens the possibility of advising on the core of a pharmacy degree's pedagogical project that all IES should model themselves on. But note: only advising and nothing more.
That being the case, we are outraged by the conscious acts of administrative misconduct coming from the councils, harming and wronging their own pharmacist members by depriving them of working in the market of ozone therapy as soon as they graduate, in a pandemic economic scenario, which is a true absurdity.
The councils should be more interested in sending more and more pharmacist ozone therapists out into society so that Brazilian Pharmacy is recognized as the reference specialty among the healthcare professions that compete with one another in the field of Ozone Therapy.
Along with the concern for ensuring the entry of good pharmacists, IES already play the role of ensuring the training of such professionals to the highest standards. Therefore, let the pharmacy councils truly oversee the schools and institutes offering open courses, which we very much doubt they are doing.
So Nepuga embarked on this mission of fighting for the rights of its pharmacist students who are bravely surviving the pandemic, demonstrating to all the regional councils and the federal council that the Ozone Therapy Extension Course it offers meets all the criteria required by CFF Resolutions No. 674/19 and CFF No. 685/20, now updated by CFF No. 695/20, which regulates the pharmacist's role in the practice of ozone therapy.
Nepuga's mission in this scenario
Given this, our mission as Nepuga is to get the regional Pharmacy councils to immediately endorse the certificates of its University Extension Course in Ozone Therapy, since, besides meeting all the requirements of the resolutions in question, we exceed practically all of their requirements.
Since being an IES accredited by the MEC requires meeting an infinitely greater number of criteria to deliver a formal education of quality, tradition, and reliability.
Extension and advanced training courses follow the same standards as the Course Pedagogical Projects (PPCs) of postgraduate programs ( Lato Sensuspecializations). In other words, all the teaching materials, methodologies, class infrastructure, teaching clinics, technical support, psychopedagogical support, faculty, and so on, use the same pedagogical base.
If such postgraduate programs do not depend on a resolution to be endorsed by the regional pharmacy councils, then it is neither logical nor sensible for those councils to create obstacles and discrimination to endorse extension course certificates.
It is worth emphasizing that, besides extension and advanced training courses, these are also offered and operated exclusively by institutions accredited by the MEC. Postgraduate programs and specializations are prohibited from being taught and/or brokered by schools or institutes offering open courses, which are only authorized to offer informal education.
Nepuga has always acted in defense of the student rights of its pharmacist students. For every difficulty that arose in the past, the IES promptly went to the council in favor of the interests of its pharmacist students and of the whole professional class it represents.
It would be no different regarding recognition of the ozone therapy extension course, which is provided for in MEC legislation and is of great importance in the training of pharmacists.
Furthermore, this achievement by Nepuga sets precedents and encourages other Higher Education Institutions to also begin requiring pharmacy councils to recognize their respective extension courses, in order to raise the educational level of all pharmacists in Brazil.
Results and updates
We continue to await responses from the CRFs across Brazil, after sending the grounds through supporting documentation. It is important to stress that, even so, we have received no further complaints from pharmacist students about the refusal to endorse their ozone therapy certificates.
As of the publication of this article, the Regional Pharmacy Council of the State of São Paulo (CRF-SP) is the only one that has officially expressed support for the immediate endorsement of University Extension certificates in Ozone Therapy for pharmacists, exemplarily fulfilling its role of defending the interests of São Paulo pharmacists and society.
Dr. Karina M., a member of the legal department at Nepuga/FAPUGA, says it has been a long process of persuasion, with many exchanges of legislation by email and letters by mail, gathering documents so that, finally, a first council would immediately accept the certificate of an Ozone Therapy extension course issued by a Higher Education Institution accredited by the MEC, without the need for a specific resolution.
“Just like a postgraduate program, an extension course must necessarily be tied to an IES; for professionals who intend to work with Ozone Therapy, it is essential to have the guarantee that their certificate is valid in the job market and, moreover, that their training carries a weighty name that backs their qualification, and only an institution accredited by the MEC can offer all of that”, explains Karina.
That was only the first step toward another great achievement. According to Karina, the procedure for immediately endorsing Nepuga's extension course in Ozone Therapy is already underway with other CRFs. We will continue updating this article and releasing more news as this effort makes further progress.
Extension Course in Ozone Therapy for pharmacists
Besides being the first Postgraduate Program in Aesthetic Pharmacy in Brazil, which trained the country's first and most famous aesthetic pharmacists, with the largest academic community of postgraduate students in training and the largest number of graduate aesthetic pharmacist specialists, Nepuga/FAPUGA is also the first IES to have University Extension Courses in Ozone Therapy exclusively for pharmacists.
If you also support the causes of us pharmacists, want to see pharmacy growing more and more in the world of well-being and quality of life, in addition to providing clinical care, having direct contact with patients and understanding how to stand out from your fellow professionals in the job market, then learn more about the Extension Courses and the entire educational ecosystem of benefits offered for training and advanced education in Ozone Therapy, with hands-on, online, and hybrid teaching.
NewsJosiele Batista
NEPUGA content team — Núcleo de Especializações Ana Carolina Puga.
