Contractor guidance

Contractor guidance

Like all parts of HM Government, the Department of Health and Social Care (DHSC) is making contingency plans in case the UK exits the European Union with no deal and PSNC is encouraging community pharmacy contractors to follow the Government guidance issued on this topic.

DHSC advice to community pharmacy contractors states that:

  • Local stockpiling is unnecessary and could lead to unintended consequences, such as creating shortages where none should exist; and
  • Patients should continue taking their medicines as normal and should be reassured that the Government has contingency plans for a no-deal Brexit.

In addition, prescribers have been asked not to write longer prescriptions.

Contractors are advised to ensure that they are ready for the possibility of a no-deal Brexit on 31st October 2019. DHSC is grateful to all contractors making the necessary preparations, particularly since contractors made such preparations for previous deadlines.

Operational Readiness Guidance

Contractors should particularly note the Operational Readiness Guidance which sets out the actions that contractors should take to prepare for a no-deal exit from the EU, and PSNC’s summary of those actions:

PSNC Briefing 005/19: Key actions for pharmacy contractors to prepare for a no-deal exit from the EU

In December 2018 Health Secretary Matt Hancock wrote a letter to frontline healthcare professionals, stating that:

  1. Community pharmacies (along with other healthcare providers) should not stockpile additional medicines beyond their business as usual stock levels;
  2. There is no need for clinicians to write longer NHS prescriptions;
  3. Local stockpiling is unnecessary and could cause shortages in other areas, which would put patient care at risk;
  4. Any incidences involving the over-ordering of medicines would be investigated and followed up with the relevant Chief or Responsible Pharmacist directly; and
  5. If asked, patients should be advised not to store additional medicines at home because the Government is working with industry to ensure a continued supply of medicines.

This builds on a previous letter sent by DHSC to frontline healthcare professionals in August 2018, where community pharmacies were told they “do not need to take any steps to stockpile additional medicines, beyond their business as usual stock levels”.

NHS England advice

In April 2019, NHS England published a letter which is intended to be a companion to DHSC’s Operational Readiness Guidance. Written by EU Exit Strategic Commander Professor Keith Willett and Director of Primary Care Commissioning Dr David Geddes, this advice has been compiled for all primary care contractors.

Dr Keith Ridge, NHS England’s Chief Pharmaceutical Officer, wrote to community pharmacies in January 2019 to update them on the Government’s contingency preparations. Dr Ridge’s letter reiterates that it is ‘not helpful or appropriate for anyone to be stockpiling medicines locally’. Also, due to the risk of placing additional pressure on the availability of medicines for patients in other areas of the country, Dr Ridge writes that ‘any incidences involving the over-ordering of medicines will be investigated and followed up with the relevant Chief or Responsible Pharmacist directly’.

Additionally, Professor Keith Willett, NHS England EU Exit Strategic Commander, issued an update following Parliament’s vote to extend Article 50.

Patient messaging

The NHS.uk website contains information for patients on how they will be able to access their medicines and medicinal products in the event of a no-deal Brexit. Pharmacy teams may like to signpost patients to this information. NHS England has also published a series of FAQs and an accompanying message for healthcare providers.

Further support in discussing these topics with patients, prescribers and others is available here.

Raising concerns

DHSC already works very closely with manufacturers and wholesalers to manage supply disruption which may or may not be related to Brexit.

In the first instance, contractors are advised to resolve issues through the usual channels: report medicine supply issues to PSNC and notify your local NHS England team if you experience significant service delivery problems. Community pharmacy teams already work hard to source medicines for patients and, where a medicine is not available, are advised to liaise with the prescriber to consider a suitable alternative.

PSNC’s Community Pharmacy Brexit Forum, along with pharmacy and LPC reports, the NHS Commercial Medicines Unit and patient groups, are helping to inform DHSC’s work and these ‘business as usual’ arrangements will be supplemented by data gathered by the Regional Medicines EU Exit Panels.

Additional issues

Recognition of Prescriptions: If the UK leaves the EU with no deal, a prescription issued in the Europe Economic Area (EEA) or Switzerland can be dispensed in the UK if the prescriber is from a profession recognised by this DHSC guidance that is legally entitled to issue a prescription of that kind in the country in which the prescription is issued.

Continued recognition of EU professional qualifications: DHSC has confirmed that EU staff who are currently practising in the UK can continue to do so, and that professionals qualified in the European Economic Area (EEA) and Switzerland can continue to apply for registration after exit day, even if the UK leaves without a deal. European qualifications will also continue to be recognised by all professional health regulators, including the General Pharmaceutical Council (GPhC). Further information is available here.

Falsified Medicines Directive (FMD): This European Union Directive aims to prevent the entry into the legal supply chain of falsified medicinal products. It came into effect on 9th February 2019, but the full implementation of FMD may depend on the UK’s future relationship with the EU. Find out more at: fmdsource.co.uk

General Data Protection Regulation (GDPR): Originating from the EU, this regulation represented an overhaul of data protection legislation. GDPR, and the associated UK Data Protection Act 2018, came into force on 25th May 2018, but it may be affected by the terms on which the UK leaves the EU. Find out more at: psnc.org.uk/GDPR and in PSNC Briefing 005/19: Key actions for pharmacy contractors to prepare for a no-deal exit from the EU.

EU health and social care staff who wish to remain in the UK: EU citizens working in the NHS and in social care are encouraged to apply to the Government’s EU Settlement Scheme.

Beyond pharmacy

DHSC letter to pharmaceutical suppliers

Association of British Pharmaceutical Industry (ABPI): Pharmaceutical companies are doing everything in their power to avoid disruption to the supply of medicines in all Brexit scenarios. This includes increasing stocks of medicine in the UK, changing supply routes, transferring medicine licenses and duplicating testing in the EU.

Association of British HealthTech Industries (ABHI): This organisation is working to ensure the HealthTech position on Brexit is clearly communicated to Ministers and officials.


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