Memorandum by the National Pharmaceutical
Association (PS 8)
The Office of Fair Trading does not believe that
the best interests of consumers are served by control of entry.
We disagree, and believe that implementing the OFT's stark and
radical recommendation could put at serious risk the current pharmacy
network and frustrate Government healthcare planning and policy.
It is not clear what problem the OFT is trying
to fix.
Although not perfect, the current arrangements
work well. Consumers like and value current pharmacy services.
The OFT Report acknowledges that there is currently an extensive
network of pharmacy outlets and refers to surveys which show that
consumers enjoy ready and easy access to pharmacy services from
where they live, work or their doctors' surgeries.
Moreover, a recent MORI opinion poll has shown
that 79% of the public believes it is important for a pharmacy
to be close to their home or GP surgery. Currently, through a
diversity of pharmacy ownership, pharmacy provides consumers with
a high level of choice and competition.
The fundamental flaw in this Report is that it
misses the point by disregarding pharmacy's principal focus as
a provider of NHS services. It also fails to take account of pharmacy's
future enhanced role as a key player in primary healthcare delivery.
Healthcare provision has to be planned and managed;
the free market cannot be relied upon to ensure that care is conveniently
available to those in need.
"Patient need" is a recurrent theme
in Government health planning and policy—and we contend
that the OFT recommendation runs contrary not only to patients'
best interests, but also to the health and wellbeing of the nation.
As part of overall healthcare provision, NHS
pharmacy services also have to be planned and managed. This will
be particularly important as PCTs and local health commissioners
throughout the UK become increasingly responsible for localised
healthcare planning.
Government has announced that it wants to make
better use of pharmacists in delivering its health policy objectives.
Pharmacists have a key role to play in helping patients get the
best from their medicines and to ensure that this expensive component
of healthcare is used safely, appropriately and cost effectively.
They also have a significant role in taking the burden off GPs.
If strategies toward making this happen are
to be successful, there needs to be some stability in the market
that will give stakeholders—particularly individual pharmacists—the
confidence to invest in developing services. The regulations underpin
this stability.
There is therefore a fundamental incompatibility
between the free market approach proposed by the OFT and the benefits
associated with a managed network of pharmacies. In underpinning
the pharmacy network, the Regulations provide the Government with
a tried and trusted mechanism for delivering a rationally distributed,
easily accessible NHS pharmacy service. This network also provides
a secure platform from which to launch many of the services listed
in the UK pharmacy strategies. The OFT recommendation thus flies
in the face of the Government's plans for pharmacy.
The Report is less than convincing about the
financial savings, which it suggests could result from its implementation.
But even then, the total estimated saving to the consumer is only
around £51-56 million—£1 per head of population!
Let us be clear; these figures are estimates—no more! Even
if the savings in the report are realised, and we would submit
this is unlikely, these are insignificant when compared with the
overall size of the market and total NHS "spend".
It is our view that to base a recommendation of
deregulation, with all its attendant risk to service provision,
on an estimate of such relative insignificance, is disproportionate.
At present, pharmacy contracts are awarded on
the basis of need. Without the regulations, openings of pharmacy
would no longer be based on need, but on a commercial imperative.
Pharmacies will open close to GP surgeries and in areas of high
customer footfall. And contrary to the OFT's view, the current
pharmacist shortage will not limit new pharmacy openings. Rather
it will lead to widespread variation in service provision according
to pharmacist availability.
More pharmacies will not add any significant
value or benefit to consumers; there will, in the short term,
be increased choice but little else. The market will only support
a limited number of pharmacies; after a flurry of early activity
there will be subsequent contraction in favour of the larger,
better resourced players.
This will put at risk many smaller pharmacies
that are providing a much needed service to local communities.
Closures, or reduced services, in these areas will disadvantage
particularly the elderly, mothers with young children and socially
deprived people and will cut across the Government's agenda for
tackling health inequalities.
There is room for improvement in the current
arrangements. The Regulations should work to patients' advantage.
We recognise fully the important and developing role of Primary
Care Trusts (PCTs) in ensuring that local patient health needs
are met. As part of this, we believe that PCTs should have greater
discretion to make the regulations more responsive to patient
need. In particular, PCTs should have the ability to identify
areas of need for new or improved pharmacy services and have greater
flexibility in implementing reasonable improvements to the range,
depth and quality of services.
We believe that improvements to the current system
could be agreed between the Department of Health, the NHS Confederation
(on behalf of PCTs), patient groups and the pharmacy profession.
In summary, deregulation is not needed to enable
pharmacy to play its part in helping the Government meet its health
objectives. On the contrary, deregulation will frustrate the Government's
health policy objectives for pharmacy at a critical time by cutting
across healthcare policy and planning and creating unnecessary
and untimely instability. Most importantly, deregulation will
disadvantage patients by putting local pharmacy services at risk.
Removal of control of entry is not therefore
the appropriate way forward for enhancing pharmacy's contribution
to patient care.
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