Jeannette Howe
Head of MPI
Department of Health
G16 Wellington House
133 – 155 Waterloo Road
London
SE1 8UG
10th February 2016
Dear Jeannette,
Community Pharmacy in 2016/17 and Beyond
The Dispensing Doctors’ Association (DDA) represents over 6,600 doctors working in 1,335 practices across the UK. It is the only organisation that specifically represents the interest of dispensing doctors and their 8.8 million patients.
We note that dispensing doctors are not within the scope of this consultation, as they are part of the NHS GP Contract. However, there are certain aspects of the consultation that could affect dispensing doctors and our remarks are limited to these.
Reimbursement
We note that there do not appear to be specific proposals in the document relating to reimbursement. Dispensing doctors are linked to the Drug Tariff and have been affected when Category M funding has been reduced in the past. These reductions have not been the subject of any separate negotiation, or discussions, with NHS England. We continue to be deeply concerned about this and the lack of any resolution to the problem.
Were there to be any proposals to change the Drug Tariff that would affect dispensing doctors, we would expect this to trigger a negotiation with us and note that such a commitment was made, by NHS England officials, in the briefing about the consultation on 28th January.
Bringing Pharmacy into the Heart of the NHS
The Pharmacy Integration Fund would be an excellent means to fund the introduction of pharmacists working in GP practices, dispensing or not. It is essential that new money is made available to fund the scheme if it is to become embedded in general practice. One of the disadvantages with the current pilot is that the funding is tapered and will leave some practices, which are already financially stretched, with additional costs at the end of the pilot phase. One of the principles underpinning the GP contract is: no new work without new money. This will be the approach that most practices will take when they are offered the services of a community pharmacist.
Modernising the System to maximise choice and Convenience for patients and the public
Many dispensing practices already offer home delivery services to their patients. Practices are at the heart of small communities offering the kind of personalised service that their patients value and trust. When the Department last attempted to consult on changes affecting dispensing patients, there was an overwhelming response to maintain the status quo; we note that this consultation does not have dispensing doctors in its scope.
Dispensing practices have achieved a high quality service without having access to the Electronic Prescription Service (EPS). There is continuing irritation that EPS is still not available. Welcome progress is being made by one system supplier to implement EPS, but this is after eight years of the service having been available everywhere else in the NHS. Rural patients deserve rather better than this and the Innovation Fund should be used to fund the implementation of EPS in dispensing practices.
‘Click and Collect’ requires a decent internet connection, which is sadly lacking in many rural communities. Practices on the secure ‘N3’ connection suffer from very slow broadband speeds, which have been exacerbated since the migration to ‘hosted’ practice systems. The basics need to be right before moving to implement any other services. Nonetheless, dispensing practices offer their patients the ability to order and collect their medicines should they so wish, in addition to the delivery services mentioned above.
We also note the unfortunate situation, just before Christmas 2015, with one of the leading internet-based pharmacies being unable to fulfil its service obligations to its customers. This does not inspire confidence in the resilience of such providers, which appear to be neither efficient, nor innovative, if their customers had to be directed to ‘traditional’ pharmacies to rescue the service.
Making Efficiencies
The pharmacy contract is currently predicated on staff hours per the number of items dispensed and this also applies to dispensing doctors in the Dispensing Quality Services Scheme (DSQS). If the Department wishes to promote innovation in the dispensing process then it might wish examine this aspect of the current contract in order to be able to stimulate innovation.
If the Department intends to amend the Medicines Act to permit community pharmacies to provide ‘hub and spoke,’ then we would expect that part of the legislation relating to Dispensing Doctors to be amended as well. Rural patients should not be disadvantaged and nor should their practices.We do not see how Ministers could be expected to justify such a position in Parliament.
With regard to longer prescription durations, we note that the Department sponsored report, completed by York Economic in 2010, states there are “positive opportunities for the further reduction of medicines waste includes: encouraging the flexible and informed use of 28 day prescribing and where it benefits patients either longer or shorter periods”. 28 days is still the norm for most patients and we are not aware of any significant demand to increase this, even with more interventions by pharmacists in future, assuming that more medicines optimisation is undertaken in surgeries.
Maintaining public and patient access to pharmacies
Our remit is not community pharmacy, but we do have concerns about the effects on rural areas of the Access Scheme.
Were a pharmacy to close in a rural area, our understanding is that the national formula for the Access Scheme does not take into account the fact that patients may have access to dispensing practice. This seems to be both counter-intuitive and unfair, given that dispensing practices are referred to in Pharmaceutical Needs Assessments.
In addition, we assume that the final agreement with PSNC will be ‘rural proofed’ by means of an Impact Assessment.
We look forward to seeing the final proposals and to being consulted upon them.
Yours sincerely,
Dr Richard West MBE
Chairman
Registered as a company limited by guarantee
Registered No. 3406619 Registered Office: Low Hagg Farm, Starfitts Lane, Kirkbymoorside, N Yorks. Tel: 01751 430835