APPENDIX 5
Memorandum by The Royal Pharmaceutical
Society of Great Britain (PS6)
The Royal Pharmaceutical Society of Great Britain
(RPSGB) welcomes the Health Committee's invitation to write to
comment on the health implications of the report from the Office
of Fair Trading (OFT) titled: "The control of entry regulations
and retail pharmacy services in the UK." (January 2003),
concerning the distribution of NHS community pharmacy services.
The RPSGB is concerned by the limited consideration
given in the report to the NHS Pharmacy Plans for England, Scotland
and Wales. Any substantial change to the community pharmacy infrastructure
could compromise the delivery of these plans. All three plans
aim to use the community pharmacy infrastructure as a platform
to deliver local clinical services for the NHS. To effectively
undertake this role, community pharmacies will need to be planned
and managed so that they are sited in areas of patient need. It
is questionable whether commercial drivers alone will deliver
this objective. In the future, the public benefit of a planned
and managed distribution will potentially be even greater, as
community pharmacies are likely to become more integrated within
the NHS.
It would be wrong to conclude from the report
that the community pharmacy infrastructure is static. The OFT's
report states that the majority of the public already believe
that they have good access to their local pharmacy. Although,
the total number of community pharmacies has remained relatively
constant since the control of entry regulations were introduced,
there has been a fluid movement of community pharmacies to meet
local need. Within the current controls on NHS contracts, over
2598 minor relocations occurred in England and Wales alone, between
1993 to 2002.
The NHS is the principal customer by far for
the majority of services that community pharmacies provide. Therefore
the OFT principle that, "competitive markets to which there
are no barriers to entry generally serve best the interests of
consumers", should not be considered directly applicable
to community pharmacy. This may lead to a distribution of pharmacies
based on commercial drivers and not patient need, and could disadvantaged
those vulnerable groups already most at need of the health services
that pharmacies provide.
In addition to the locality issues raised, the
secondary effects on healthcare provision of the proposed lifting
of regulations must also be considered. The most pressing of these
would be the current workforce shortage that the profession is
experiencing. If deregulation were to occur, the report predicts
a large increase in the total number of community pharmacies.
This increase would further exacerbate the current shortage of
both pharmacists and support staff. In the medium to long term,
the recent growth in pharmacy student numbers may meet an increased
demand for pharmacists. However in the short term, the only readily
available source of a substantial number of trained pharmacists
and support staff would be NHS acute hospitals. Many hospitals
are already experiencing staff shortages, and any net loss of
staff would place additional pressures on the delivery of patent
care and compromise plans for future developments in clinical
services.
The RPSGB disagrees with the OFT assumption
that the best driver for the development of community pharmacy
would be commercial attrition. The RPSGB feels that development
through a planned expansion of professional services to meet local
health care needs, would be in the best interests of the public.
The NHS has already given its view on how these services could
be designed around the patient, and the structures needed to deliver
this. The plans promise a managed approach, supported by contractual
agreements, targeted at providing better services in localities
of health need. The RPSGB would be strongly opposed to any development
that threatened to adversely affect the quality and access of
healthcare services to the public.
March 2003
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