PSNC responds to consultation on additional information requirements for NHS supply chain

PSNC responds to consultation on additional information requirements for NHS supply chain

November 22, 2017

PSNC has published its response to the Department of Health (DH) consultation on Proposed legal requirements to provide information about health service products.

The consultation sought views on draft requirements to provide DH with information relating to the supply of medicines and other healthcare products to the NHS. The suggested requirements would be applicable to all those involved in the supply chain, from manufacturers through to pharmacies. DH also indicates that the information provided would be used to calculate payment for community pharmacies, as well as to ensure the availability of medicines and other products.

In its response, PSNC asks DH to re-think the applicability and scope of the proposed information requests to community pharmacy. Amongst PSNC’s concerns is why DH needs any additional information from community pharmacy contractors, arguing that the current arrangements for managing pharmacy remuneration, namely the Margins Survey, are sufficient, and there are proposals to obtain quarterly information from manufacturers and wholesalers. There seems little need to add this extra layer of regulation which would increase pharmacy workload.

Regarding any additional information used to calculate payment for pharmacies, at present, provisions are made for PSNC, as negotiator, to have sight of the data. PSNC argues that any additional information used by DH would need to be shared with as well to ensure fairness of the negotiation process.

PSNC also considers that DH should undertake economic analysis on the possible impact of the proposals on the competitive nature of the generics market, arguing that DH has failed to consider that increased regulation of generic medicines may put this competitive market at risk, which could hinder rather than help cost-effective procurement.

Read PSNC’s response in full.

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