PSNC responds to ‘Hub and Spoke’ consultation


PSNC responds to ‘Hub and Spoke’ consultation

May 23, 2016

PSNC has today published its response to the consultation on ‘hub and spoke’ dispensing.

This follows discussion between PSNC and the Department of Health to clarify various concerns that PSNC had with the draft regulations.

The Department of Health has confirmed that the draft regulations, if implemented, would permit hub and spoke dispensing between “relevant clinical entities” which it is proposed would include hospitals and surgeries (premises at or from which primary medical services are provided as part of the health service). This could potentially bypass registered pharmacy premises. There would still be pharmacist supervision of dispensing, but it is not clear if there would be pharmacist supervision of assembly or supply of the dispensed medicine at non-pharmacy relevant clinical settings.

While changes to the Medicines Act 1968 or Human Medicines Regulations 2012 do not change NHS provisions (and doctors have always been able to supply medicines to their patients), these changes, if implemented, would provide an entirely new legislative framework for the retail supply of medicines on which there has been no consultation.

Other issues PSNC raised in response to the consultation include:

  • the impossibility of creating a level playing field when independents must use and share patient lists with third party hubs;
  • the proposed unrestricted wholesale dealing between relevant clinical settings is arguably contrary to European legislation;
  • professional and legal issues and a change in legislative emphasis from pharmacies to pharmacists have not been considered and could lead to patient safety issues;
  • redesign of section 10 of the Medicines Act is unnecessary as a result of the Abcur judgment;
  • ‘hub and spoke’ dispensing may not be able to comply with the Falsified Medicines Directive;
  • that the alleged safety arguments are not evidenced and sharing the dispensing process between two legal entities could lead to quite the opposite effect; and
  • that the alleged economic efficacy arguments are not evidenced and arguably ‘hub and spoke’ dispensing could cost more overall.

Read PSNC’s response in full.

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