Memorandum by National Co-operative Chemists
Limited (PS 14)
1. National Co-operative Chemists Limited
are delighted to have been invited to give evidence to the Health
Select Committee on the health implications of the OFT recommendations.
We thought it might be helpful to the Committee to provide some
brief background information on National Co-operative Chemists,
and Co-op Pharmacy in general.
2. Over 500 pharmacies are operated by Co-operative
Societies throughout the UK, with National Co-operative Chemists
responsible for 300. Of these, nine are in Northern Ireland, 27
in Wales, 31 in Scotland, and the remaining 239 throughout the
English regions.
3. A further breakdown shows that 15% of
these are in Health Centre locations, 10% within Co-op retail
stores, and 10% in larger High Streets and shopping areas, with
the balance and vast majority being in neighbourhood communities.
4. As can be seen, therefore, we have an
interest throughout all the United Kingdom home counties and in
every type of location. Our strategy is to provide pharmaceutical
services to meet the needs and expectations of our patients and
to work closely with other members of the primary health care
team.
5. We wish to make the following detailed
comments on the potential health implications if the Control Of
Entry Regulations were to be abolished.
Firstly, we are strongly of the opinion that,
if all Control of Entry Regulations are repealed, we will see
a speedy return to the situation prior to 1987, with pharmacies
congregating around the major sources of prescriptions in a bid
to secure their future incomes. We also envisage an increase in
the number of out-of-town pharmacies where business is driven
primarily by car borne footfall.
6. It follows that with more pharmacies
opening that the average prescription numbers of pharmacies in
general will fall and those most affected, for example, the pharmacies
dispensing fewer scripts but providing a local service will close.
Our concern is that these pharmacies will be the ones that communities
can ill afford to lose.
7. Our own business modelling clearly indicates
that based on the OFT expectations of new pharmacies, we would
see an overall decrease of 10% on our NHS prescription volume,
which would threaten the viability of up to 20 NCC pharmacies
across the UK. Further analysis shows that a number of these are
essential pharmacies meeting the specific health care needs of
individual communities, often those communities that are geographically
isolated or economically deprived.
8. Pharmacists are health care professionals
working within the NHS.
Governments have recognised this with the publication
of:
"The Right Medicine"—Scotland
"Remedies for Success"—Wales
"Pharmacy in the Future"—England
9. Each of these publications recognises
the contribution that pharmacists and pharmacies can make to health
care. The documents envisage the further innovative development
of pharmaceutical services as a lynch pin for achieving their
total health care plans. These services include repeat dispensing
services, minor ailments clinics, pharmacist prescribing, and
medicines management.
10. These services are designed to make
the best use of pharmacists' skills and expertise whilst improving
the patient journey by facilitating access to medicines and appropriate
services without the need to visit a GP surgery.
11. Plans for such service development are
well under way. Repeat Dispensing Pathfinder sites are planning
to go live in the next month with Scotland rolling out pharmacist
prescribing for minor ailments on a national scale in the coming
year. Pharmacists are very much engaged in delivering the wider
health agenda and playing their part in modernising the NHS.
12. In addition to new developments pharmacists
currently provide a range of services, some such as supervised
Methadone and Emergency Hormonal Contraception are locally commissioned
and remunerated, with others such as collection and delivery and
the supply of compliance aids provided as part of a wider service
offering, often unremunerated.
13. We believe that services such as these
will come under threat if the Control of Entry Regulations were
to be abolished. Community pharmacists invest in premises, stock
and training to deliver the wider health care agenda, in times
of uncertainty and threat such ongoing investment may not make
sense. Unremunerated services will be withdrawn as pharmacies
struggle to remain viable with diminishing prescription numbers.
More controversially we believe critical services, in particular
those to drug misusers, will be under threat as they are often
unpopular with other pharmacy customers and commercial pressure
can be brought to bear to stop their provision.
14. Against this background of instability
and uncertainty it is difficult to see how local health bodies,
including PCTs and Health Boards, will be able to incorporate
community pharmacies and the services and health benefits they
can deliver, into their primary health care teams in a planned
and structured way.
15. Health bodies need to be able engage
the public and all health care providers to develop service provision
and to make robust sustainable plans for the future. Community
pharmacy has so much to offer here. There are six million visits
to a community pharmacy every day, we are the only health care
professional to routinely interact with people who are not ill,
the opportunities for us to engage with communities, to act as
advocates, to act as source of advice and information and to deliver
health promotional messages on wider public health issues are
immense.
16. Health is too important to be left to
market forces, there must be some degree of planned provision
of pharmaceutical services at local level. Commissioning bodies
must have a leading role in determining local services.
The abolition of the Control of Entry regulations
will not achieve any of these objectives.
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