PSNC responds to NHS consultation on restricting prescribing of certain medicines

PSNC responds to NHS consultation on restricting prescribing of certain medicines

October 20, 2017

PSNC has today published its response to the NHS England and NHS Clinical Commissioners (NHSCC) consultation on Items which should not routinely be prescribed in primary care: A Consultation on guidance for CCGs.

The consultation sought views on 18 medicines which NHS England and NHSCC suggest should no longer be routinely prescribed  in primary care, because they are either:

  • clinically ineffective, unsafe or not cost effective; or
  • the NHS can offer a clinically-proven alternative for patients.

In its response, PSNC has shown support for these proposals as evidence-based clinical rationales have been provided. However, in moving forward with this, PSNC emphasises the need for the development of clear communication materials for use at both local and national level “so consistent messages are used by all healthcare professionals”. PSNC recommends that consideration should be given to adding these products to the NHS prescribing ‘Blacklist’ (Part XVIIIA of the Drug Tariff) to “provide greater clarity” for both community pharmacy teams and prescribers.

The support provided for affected patients will also need careful handling. PSNC believes that any patient whose regimen is being changed “should have the changes explained to them in a face to face consultation”, as opposed to solely written communication. A recommendation is also made to refer patients being moved onto eligible products to the New Medicine Service (NMS) so that community pharmacy teams can provide additional support, as well as ensuring contractors are given advance notice “so that stock levels of the affected products can be properly managed”.

NHS England and NHSCC are also seeking people’s views on whether a wider list of 3,200 products that are available over-the-counter, without prescription, may be considered appropriate for future restriction. On this aspect of the consultation, PSNC raises the following points for further consideration:

  • the fundamental conflict with Principle 2 of the NHS Constitution (‘Access to NHS services is based on clinical need, not an individual’s ability to pay. NHS services are free of charge, except in limited circumstances sanctioned by Parliament’);
  • the conflict with the regulatory and professional obligations on doctors to prescribe a medicine where clinically indicated;
  • the likely disproportionate adverse impact on low income individuals / families and their children;
  • the risk of unintended consequences, such as increased use of A&E and other urgent care services; and
  • the likely practical challenges which will be faced by community pharmacy and general practice teams.

Finally, PSNC recommends that NHS England and NHSCC consider how national coverage of pharmacy minor ailments services, potentially restricted to people and families that are currently exempt from NHS prescription charges on income grounds,  may provide benefits for both patients and the NHS, whilst at the same time avoiding the “unintended consequences of implementing a blanket restriction on prescribing OTC medicines for some of the most vulnerable groups within society”.

Read PSNC’s response in full.

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