What is PSNC doing?
Published on: 15th February 2016 | Updated on: 15th March 2022
In the immediate aftermath of the Department of Health (DH)’s unprecedented decision to publish their plans for the future of community pharmacy in the 17th December letter, PSNC gave its initial response, outlining that the announcement had delivered a financial blow to community pharmacy. Since then PSNC has been working with the other national pharmacy organisations and its public affairs agency, Luther Pendragon, to launch a campaign to protect the sector and ultimately patients.
Since the Government’s decision to impose a new funding package on community pharmacy on 20th October 2016, PSNC and the other national pharmacy organisations have been continuing to work to ensure that the media and politicians are aware of the imposition announcement and the ongoing concerns about community pharmacy.
The imposition followed PSNC’s rejection of the Department of Health’s proposals and Chief Executive Sue Sharpe has stressed that PSNC is “very concerned about the impact that this will have on patients”.
LPCs have also been busy keeping local politicians and stakeholders informed and asking for their continued support, as well as handling local media coverage.
Over the coming months PSNC will be working closely with LPCs to help the sector to adapt to the changes. We must also continue to build on the phenomenal support we now have among politicians from all parties and the general public to make the case for pharmacy’s long-term future.
PSNC will be going through the announcement and impact assessment in more detail and working with the other pharmacy organisations to develop more detailed plans for the next phase of our campaign for community pharmacy.
Currently, PSNC is in the process of seeking a Judicial Review.
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At PSNC’s January 2016 meeting (held on 12th and 13th January), the Committee dedicated most of the time to considering the letter and planning PSNC’s response. Following the Committee meeting, a written response to the DH letter was published on 15th January 2016.
In the letter PSNC said it was unable to commence negotiations on community pharmacy in 2016/17 until DH shared further detail of its longer term plans and the analysis underpinning them. PSNC Chief Executive Sue Sharpe said she feared NHS England was aiming for a larger funding cut in 2017/18 alongside reductions in pharmacy numbers and a drive towards a commoditised supply service, bypassing access to the support and advice available at community pharmacies.
PSNC has also provided the following responses to specific elements of the Government’s plans:
- The £170m funding reduction: PSNC is committed to protecting a strong, diverse and accessible service offered through community pharmacies and we reject any proposals that would reduce the support they offer their patients. We believe that the reduction in funding in 2016/17 runs counter to the Government’s stated aim to develop a more clinically focused pharmacy service.
- Pharmacy closures: PSNC does not accept that there are too many community pharmacies. We agree that there is some clustering of pharmacies and will work with the NHS and Government to facilitate voluntary mergers. We reject their proposals to use blunt instruments based on volume as a crude measure of the care provided by pharmacies.
- Online pharmacy services and hub and spoke models: PSNC is committed to the further adoption of online services from the community pharmacy network. But we don’t accept that the development of large warehouse supply operations, removing the need for local community pharmacies, is an acceptable alternative to the services currently provided by those pharmacies. We will not oppose amendment to legislation to support hub and spoke assembly of medicines, but would oppose models for hubs without those community pharmacy spokes. Any revised regulations must prevent misuse of collection point arrangements intended for rural locations as an inferior but expedient alternative.
- Periods of treatment: PSNC rejects proposals to transfer funds to CCGs to drive longer periods of treatment, and will insist on effective protection against GP direction of prescriptions. We will commit to developing changes to pharmacy funding delivery that will drive prescribing periods appropriate to patients clinical needs by repeat dispensing and clinical interventions.
- Future: PSNC believes the proposals as set out create massive risks to the sustainability of an already fragile supply system and we cannot accept anything that will jeopardise the services and supplies community pharmacies provide to their patients. We want to see positive proposals for the development of a more clinically focussed community pharmacy service as an essential part of the negotiations. PSNC has also called for a five year commitment from the NHS that protects and supports the community pharmacy network and develops the clinically focused ‘contract’.
PSNC has also submitted its views on how the Pharmacy Integration Fund should be used to support the development and integration of community pharmacy services in England.
In response to the Government’s call for ideas on how pharmacy services could develop in future contained with the letter, PSNC published a set of service proposals. The proposals, published on 9th February, include the introduction of a care package, which would see repeat dispensing becoming a default option where medicines are needed on a long-term basis, patient registration at pharmacies, and pharmacies offering enhanced medicines optimisation services.
An important part of PSNC’s response to the letter of 17th December 2015 has been a counter proposal setting out how community pharmacy could use its unique skills, accessibility and contact with the public and patients to reduce NHS costs and improve quality. The counter proposal sets out how community pharmacy services, including an emergency supply of medicines service, could be used to generate the savings the NHS needs to make through pharmacy, without a cut in funding.
On 20th January 2016 the majority of LPCs were represented at a special meeting organised by PSNC to discuss the implications of the DH letter to PSNC. At the meeting ideas for campaigning at a local level were considered by the attendees; these ideas are being fed into the planning for a campaign that PSNC is undertaking with Pharmacy Voice, the NPA, AIMp and the CCA.
PSNC also held two meetings, one in the West Midlands and one in London, for community pharmacy contractors to discuss the implications of the recent Government proposals for the future of community pharmacy. During the meetings key figures from PSNC discussed the government’s plans, PSNC’s strategy, the campaign in response to the government’s plans and the action that contractors can take. NPA colleagues also joined us to speak about the NPA response and campaign support.
On 13th May Peter Cattee, Chair of PSNC’s Funding and Contract Subcommittee and CEO of PCT Healthcare, made a statement to contractors following a meeting of the full PSNC Committee in which they reviewed the outcome of our discussions and agreed next steps. Peter stated, “we are very pessimistic about the outcome of the consultation on community pharmacy’s future,” and “we strongly advise all contractors to make whatever provisions they can for the funding reductions”.
PSNC has published its response to the consultation on ‘hub and spoke’ dispensing. Following confirmation from the Department of Health 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, PSNC became concerned that this would potentially bypass registered pharmacy premises.
PSNC has now published its response to the Government’s letter from 17th December 2015. Within the response, PSNC makes clear that the proposals contained in the letter represent a major threat to the future availability of accessible healthcare, support and advice from community pharmacies. We are concerned that this threat has not been made clear to the public nor to their representatives, and that the policies underpinning the letter have not been based on analysis of the likely consequences or costs to the public as patients, members of our communities, or taxpayers.
On 20th October 2016, the Government announced it would impose a two-year funding package on community pharmacy. PSNC Chief Executive Sue Sharpe issued a strong statement in response which included the following key aspects:
- Pharmacy closures: we expect that pharmacy owners will be forced to take steps to reduce costs. We are very concerned about the impact that this will have on patients.
- Impact on patients: patients may find that they have to wait longer to receive advice that would previously have been readily available. The NHS must recognise this as winter pressures set in and it turns as usual to pharmacy for help.
- The Pharmacy Integration Fund: we strongly believe that this should be spent on supporting national community pharmacy services that will better help patients and reduce demand elsewhere on the NHS and will be seeking clarity about how it will be allocated.
- Impact on other NHS services: lots of big policies could be railroaded by these community pharmacy proposals, for instance if social care cannot cope with the increase in people left without support, there could for example, be a rise in hospital admissions. The removal of Establishment Payments will target for the greatest cuts the low dispensing volume pharmacies in areas with the highest health needs.
The imposition followed PSNC’s rejection of the Department of Health’s proposals and a statement by pharmacy minister David Mowat about an urgent repeat medicines pilot plus work by NHS 111 to develop a referrals process for minor ailments. PSNC and the other pharmacy organisations issued a joint response to the minister’s speech on pharmacy’s urgent care role.
In December 2016, PSNC sought permission from the High Court to apply for Judicial Review on the grounds that it believes the Secretary of State failed to carry out a lawful consultation on the proposals for community pharmacy.
PSNC believes that the DH has used poor data which it did not disclose as a basis for its decision, rather than updating existing high quality data.
PSNC’s four arguments seeking judicial review were the DH’s:
- failure to disclose the fact that it had carried out an analysis of pharmacies’ profitability based on Companies House data as part of its Impact Assessment;
- delay in providing this analysis to PSNC after the publication of the Impact Assessment;
- failure to adequately inform itself as to the effect of the proposals; and
- use of an indicative analysis that was fundamentally flawed.
In summary, PSNC will argue that the Secretary of State made a major policy decision to restructure community pharmacy and make financial savings, without any proper evidence and without any meaningful consultation, to the detriment of the public who rely on the services of community pharmacies.
PSNC was granted leave, or permission, for a Judicial Review just before Christmas, and this was originally scheduled to be heard in the week commencing 6th February 2017. But now that the NPA has also applied for leave for Judicial Review of the Secretary of State’s decision, the two cases will be heard together. The March timing gives the DH and its legal team time to prepare for both of the cases. The NPA’s case is focused on arguments that the Secretary of State failed to properly discharge his Public Sector Equality Duties and failed to appreciate community pharmacy’s wider healthcare role.
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