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APPENDIX A: COMMENTS ON THE CONSULTATION
As well as presenting their views on the various options outlined in the consultation document, a small number of respondents made comments about the consultation itself.
Some of these comments focused on the consultation document. While one respondent praised the general structure of the document and the depth of information it provided, a couple of others suggested that it contained too much jargon and was therefore not particularly accessible to the public.
The document is well researched and clearly presented guiding the reader through the different change possibilities. The background information, financial information and contrasts with other countries help to determine the implications of some of the change possibilities.
Aberdeenshire Council Housing and Social Work Service
I can't comment as I don't know what an HC3 holder is! If you want ordinary people to engage with government and participate in such consultation exercises why use such details without explaining clearly what it is or what it stands for. (In relation to PPCs) Acronyms are equally as incomprehensible as form numbers to anyone outside the civil service and benefit system!
Individual
Other comments related to the scope of the consultation and the extent to which the document addressed issues in the current system of prescriptions and exemptions. It was suggested that options under consideration were not sufficiently "wide-ranging" and that what was required was a more "fundamental" and informed review of existing practices.
1) A first key observation from the nursing perspective is that the consultation fails to acknowledge the significant growth in non-medical prescribers. With the recent extension of nurse and pharmacist prescribers we would have expected this work to at least have referred to it in the consultation. It is important because of the way in which prescribing is likely to change in future years. 2) [We] believe that this consultation could have been more wide ranging and was an opportunity to look genuinely at the case for complete abolition of the charging system as well as options for reform.
Medical professional/body
NHS prescription charges and the associated exemption arrangements require a fundamental review with supporting economic argument and evaluation, based on an epidemiological approach and prescribing activity data. The consultation appears to overlook this need and merely seeks to modify an already ineffective system with little supporting evidence for the options outlined.
Pharmaceutical body
Finally, several respondents presented views regarding appropriate 'next steps' for the review. The need for economic modelling of options was once again highlighted, as was the importance of "affirmative resolution" of emerging proposals.
1) An economic evaluation based on prescribing data and epidemiology should support the review 2) New system should be based on ability to pay and the total level of cost to any patient within a given time period. 3) Any new system should be easily administered and not place an undue burden on community pharmacists or their staff.
Other body
1) It is essential that a full health and economic appraisal is undertaken. The table outlining comparative systems in other jurisdictions is meaningless without an evaluation of what adopting such systems would mean in the Scottish context.
Pharmaceutical body
[We] would like to see any proposals being subject to affirmative resolution and also that the resolutions are put out for consultation prior to their approval in the same way as was the case with the ban on smoking in public places.
Patient group/voluntary organisation
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