PSNC submits response to Hub and Spoke consultation
PSNC has submitted its response to the proposals set out in the Department of Health and Social Care’s (DHSC’s) consultation on hub and spoke dispensing.
The consultation proposes making legislative changes to allow the operation of hub and spoke dispensing across different legal entities, and proposes to introduce two different models for this. Model 1 would involve patients only interacting with the spoke pharmacy, whilst Model 2 would permit the hub to supply medicines directly to the patient on behalf of the spoke.
PSNC’s consultation response indicates that whilst the Committee supports the appropriate changes to the medicines Act 1968 and the Human Medicines Regulations (HMRs) 2012 in principle, it believes that only Model 1 is appropriate, with manageable risks relating to patient safety, and is a model that has the potential to allow the whole community pharmacy sector to benefit fairly. We are particularly concerned about the likely patient confusion (and safety issues this causes) if medicines are delivered to patients in an uncoordinated way from both the spoke pharmacy as well as one or more hubs, which is likely to happen under Model 2 for patients with co-morbidities or complex needs.
In particular, we have made the following comments and observations:
- Model 2 raises patient safety issues and PSNC cannot support this model.
- Remote, national supply pharmacies with no physical access for patients (Distance Selling Pharmacies) are already available as a choice for patients, for both private and NHS prescriptions.
- There are virtually no financial efficiencies envisaged by these proposals, and, if used, they are more likely to add cost to the community pharmacy sector.
- Aspects of the proposed legislation are not clear or are ambiguous and require further consideration to ensure there are no unintended consequences.
- There should be no change to Section 220 of the HMRs and pharmacist supervision of supply prior to:
- the envisaged consultation on skill mix later this year; and
- confirmation of the meaning of ‘at or from’ and the scope of collection and delivery arrangements (Section 248 of the HMRs) – an exception to supply at a pharmacy and under the supervision of a pharmacist.
- We consider that market entry concerns around Model 2 in the consultation, including the proliferation of hub pharmacies, would be problematic to address in NHS Pharmaceutical Regulations (whilst noting this is not the subject of this consultation)