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MODERNISING NHS COMMUNITY PHARMACY IN SCOTLAND

SECTION 6: CROSS BOUNDARY AND DISTANT PROVISION OF PHARMACEUTICAL SERVICES

The Policy Intention

6.1 To clarify and extend the current pharmaceutical list and control arrangements to allow for innovative ways of providing dispensing and supply services to NHS patients, and so give patients and pharmacy contractors greater flexibility in the way that pharmaceutical care services can be accessed and delivered.

The Need for Change

6.2 As previously stated, Boards are required to maintain lists of persons and businesses who provide pharmaceutical services, which includes the provision of appliances, in their respective areas. Once listed, the pharmacy contractors are subject to the terms and conditions in the 1995 Regulations.

6.3 Boards have a statutory duty to ensure that pharmaceutical services are provided to all patients who present at the community pharmacies in their area, regardless of whether they live in that Board area or another. Those services must be provided from premises entered on a Board’s pharmaceutical list. Ordinarily pharmacy contractors will dispense prescriptions to patients who present at their listed premises but there are occasions where they will arrange for the medicines to be delivered to the patient’s home or place of residence. In these circumstances the delivery may be to an address in another Board’s area, i.e. a cross-boundary dispensing.

6.4 There is nothing in legislation to prevent a pharmacy contractor dispensing ‘cross-boundary’ but the service must be provided from duly listed premises. However, it is possible that the pharmacy contractor will not be on the list of the Board where the patient receiving the medicine or appliance actually resides. Whilst the contractor will still be subject to the terms and conditions of service it is considered that there is a need to clarify the legal framework that governs cross-boundary dispensing.

6.5 The current arrangements for securing and delivering pharmaceutical services rest largely on the premise that they will be provided directly from a duly listed community pharmacy, and that the patient or their representative will initially present at those premises to access the service. As such, the current arrangements do not fully recognise changes in the way that services in general can be delivered, for example through ordering over the internet or by mail order. More specifically with regard to community pharmacy, there is increasing potential for the development of automated or centralised dispensing services. These would allow community pharmacists to order items for dispensing from another, or ‘distant’, site for delivery to either their own premises or direct to the patient’s home.

6.6 Collectively these developments have the potential to give patients greater flexibility in the way that they can present prescriptions and receive their medicines or appliances. They should also aid working practices within the community pharmacy. There is, however, a need to ensure that ‘distant dispensing’ services are managed and controlled in a way that ensures local access to the full range of pharmaceutical care services is maintained and that the provision is to appropriate standards.

The Proposals

6.7 The intention is to clarify the range of pharmaceutical services that can be provided cross-boundary and to extend the legislative framework to provide for distant dispensing arrangements.

6.8 Boards will be authorised to arrange for the provision of all pharmaceutical services to any person in their area and from a pharmacy contractor out with the Board’s area. This ability will give Boards with an under provision of pharmaceutical services in their area the option to secure it from outside the area (see Section 3 on Planning and Provision of Pharmaceutical Care Services). Boards will not be allowed to arrange services for persons outwith their area from contractors who are also outwith their area.

6.9 The requirement that pharmaceutical services must be provided by a person or businesses whose name and premises are listed in a Board’s pharmaceutical list will remain. Contractors who wish, or who are commissioned to provide, cross-boundary or distant dispensing services will also require to be entered on the list of the Board in whose area the services will be provided or delivered and, thereby, that Board will be responsible for the control and regulation of those services.

6.10 It will be open to contractors or businesses to establish or become distant dispensing premises. Such contractors would be able to dispense and supply medicines/appliances direct to a patient’s address but only where the prescription had been presented at or through a pharmacy contractor who provides a full pharmaceutical care service under the national contract, i.e. the Core Service (see 2.4). In this way there will be a ‘provision of products’ service and ‘provision of care’ service.

6.11 Persons or businesses that wish to provide only distant dispensing services and offer no ‘provision of care’ services will still be required to gain entry to a Board’s pharmaceutical list. However, in such cases the business’s location relative to other community pharmacies will not be the issue that it is under the current control of entry (to pharmaceutical lists) arrangements. Therefore, the intention would be to amend the control of entry arrangements for this category of contractor to place the focus more on meeting patient needs and less on where the service is located.

6.12. For contractors who wish to provide both ‘distant’ and ‘in person’ services the usual control of entry arrangements will continue to apply. Additionally, for such contractors the pharmaceutical list will detail the services that are to be provided.

6.13. Recognising that the development of cross-boundary and distant dispensing arrangements could give rise to new and possible untested ways of working, it will be necessary to have regulatory powers to limit the services or to dictate the ways in which they are to be operated. At this time, it is difficult to predict the situations for which those powers will be required but, for example, they could:

• Prevent the use of pharmacies that are not included on a pharmaceutical list as intermediaries in the dispensing process.
• Prohibit the provision of particular services by distant means or specifically across NHS Board boundaries, e.g. supply of controlled drugs; appliances that require fitting.
• Stipulate the minimum standards for the safe and secure transportation and delivery of distantly dispensed items.
• Stipulate the records and information to be maintained when dispensings or cross-boundary services are being provided.

6.14 Currently, pharmacy contractors are paid by the Board in whose list they are included and from where the services are provided. The cost of the drugs and appliances that they dispense are paid by the Board where the prescription was written. In view of the changes proposed, powers will be sought so that where necessary or appropriate Boards can be authorised or required to make payments in respect of pharmaceutical services delivered to people in their respective areas but provided by pharmacy contractors in another Board area.

6.15 It is envisaged that payment for distant dispensing services will be a matter for the respective service (product and care) providers to settle between themselves.

Questions

• Do you agree that is desirable to have powers that will encourage and allow innovative ways of providing pharmaceutical services in the future?
• Do the proposals offer sufficient flexibility for patient choice, convenience and safety or should they go further?

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