House of Commons - Health - Written Evidence

Select Committee on Health Written Evidence

APPENDIX 7

Joint Memorandum by Pharmacy Health Link and United Kingdom Public Health Association (PS 9)

BACKGROUND

The primary remit of the charities PharmacyHealthLink[7] and the United Kingdom Public Health Association[8] (UKPHA) is to improve the health and well-being of the public principally through influencing broader health policy and by working with health service, and other professionals, to help them deliver high quality, accessible and effective services to the public and local communities.

Both charities welcome this investigation by the Health Select Committee which we believe is both timely and pertinent to its role. We were very pleased that the Health Committee previously recommended that "the Government takes steps for community pharmacists to play a more active role in public health"" in its Inquiry into Public Health[9] and we hope the Committee will bear this recommendation in mind during its deliberations on the current inquiry.

Neither charity has any commercial interest in the outcome of the Government's consultation on the OFT report, however, we are concerned that if its proposals were implemented they may have a serious impact on access to, and the quality of, the resulting services available to the public through pharmacy. We have listed our main concerns about the health effects of the report's proposals below and would be happy to expand on these points further, if required by the Committee:

MAIN HEALTH EFFECTS

1. Reduced access to pharmacy services for those with the greatest health needs

We believe that the control of entry regulations have helped to create and maintain a nationwide network of community pharmacies that currently give the public excellent access to pharmacy services. Research commissioned by the Royal Pharmaceutical Society of Great Britain (RPSGB) [10]indicated that use of pharmacies by the general public is almost universal (with an average of 12 adult visits a year) and indeed the OFT's own research replicated these results. We believe that unregulated free market competition in the pharmacy sector, however, would lead to vital segments of this nationwide network being dismantled. We have serious concerns that loss of access would be concentrated in less profitable shopping areas, in particular rural communities and deprived areas where access to timely public transport services and car ownership is low. Research has also indicated[11] that the most frequent users of pharmacies are those who with the greatest health needs—especially older people, families with children under five years old, unemployed people and other vulnerable groups such as the homeless and drug users. All of the latter are less likely to have access to a car or reliable public transport and therefore are more likely to rely on local services, and local pharmacies in particular, to meet their health needs.

2. Disruption to the potential benefits to patients of extended pharmacy services

Both charities support the general aims and direction of the Government's plans for modernising the UK National Health Service[12] [13] [14] and the inclusion of community pharmacy within these plans. [15][16] [17] In particular we were very pleased to see the needs of patients and other service users being given much higher priority together with some new and exciting plans for developing pharmacy services for their benefit.

It is within this increasingly favourable policy context for the development of pharmacy services that we view the OFT proposals as potentially having a retrograde effect on the public's access to health services. We are concerned that the piloting of some quite radical means of service provision, such as supplementary prescribing, repeat dispensing and Local Pharmaceutical Services pilots, will be given less commitment as pharmacists' attention is drawn away to combat the threats of free market competition. We are concerned that the potential benefits for patients from these pilots will be lost, watered down or delayed, and that the transfer of learning or provision of services to a national level will similarly be impeded. We are also concerned that the current provision of many low-profit, but high-community-value, services such as home deliveries may be lost to the community.

3. Lack of integration of pharmacy services into planning for local health needs, and particularly a failure to address health inequalities

We are worried that the full range of health needs of the population may not be properly addressed if free market competition is allowed to dictate the siting of pharmacies—and the services they provide—without there being considerable influence from the NHS and local populations receiving the services. In particular we are concerned about anecdotal reports where there have been examples of supermarket-based pharmacies changing their service provision in response to limited customer feedback and without consulting adequately with the NHS. The reported behaviour that concerns us most is of pharmacies:

— Withdrawing from, or not taking part in, any arrangements to supply medicines to the public using Patient Group Directions—for example, the supply of emergency hormonal contraception to under 16 year olds.

— Opening hours of supermarket-based pharmacies being determined by purely commercial considerations resulting in access to extended services in pharmacies in these locations being either restricted or withdrawn, often with very little notice given to local health service providers.

— A reluctance to provide public health services for vulnerable groups that may not be acceptable to other supermarket customers, for example, to people with drug problems and young women requiring emergency hormonal contraception. The latter group is particularly important to strategies to reduce teenage pregnancy.

— A reluctance to engage with, or provide, services that have a low commercial value (for example, home delivery or collection of medicines) but have a high value to the community and local health services.

It is our belief that community-based pharmacies in particular could play a significant role in reducing health inequalities by providing effective public health interventions—and that these interventions need to be available nationwide in order to maximise the benefits to the public's health. In this respect we strongly agree with the Health Select Committee previous recommendation that "the Government takes steps for community pharmacists to play a more active role in public health" in its Inquiry into Public Health. [18]We believe that the evidence-base to support this recommendation is now available[19] and has revealed the potentially significant contribution that community pharmacy can make at a local level to:

1. Coronary heart disease prevention: through smoking cessation, lipid management, secondary prevention with aspirin, anticoagulation monitoring, obesity and weight reduction, diabetes management.

2. Cancer prevention: through smoking cessation, skin cancer prevention.

3. Health protection: through providing clean syringes and oral substitutes to heroin users, increasing population immunisation levels.

4. Other key public health targets: by reducing teenage pregnancy and unwanted pregnancies.

We would be very happy to discuss the findings from this evidence-base with you further if it would assist your current inquiry.

CONCLUSION

Both PharmacyHealthLink and the UKPHA take the view that the current control of entry regulations have helped sustain a network of pharmacies across the UK that provides a resource for health to local communities, particularly in economically-deprived areas. This resource is also essential where pharmacies are sited in areas where public transport is poor, there is a relatively low proportion of the population with access to a car, and in inner city and deprived areas. Therefore whilst we accept that the current entry regulations may need some reform, we do not believe this should be to the detriment of the public's health or at the expense of those with a greater dependence on local community-based services. In conclusion we believe that reliance on the market place alone to set the agenda for the development of pharmacy services would be counter-productive for implementing many other aspects of Government health and social policy, but worse still, may result in further social exclusion for vulnerable groups and increased health inequalities.

For further information on this joint statement, or the work carried out by the PharmacyHealthLink, please contact Miriam Armstrong, Chief Executive on 020 7572 2264; email: marmstrong@rpsgb.org.uk.

For further information on the work carried out by the UKPHA please contact Ian MacArthur, Chief Executive on 01225 759 163; e-mail: ian@ukpha.org.uk.

7 PharmacyHealthLink is a registered charity set up to improve the health of the public through the activities of pharmacists in hospital, primary care and community settings. It achieves this by conducting research, providing training and information, and developing the skills of pharmacists to promote the health of the public and educate them in matters affecting their health. Back

8 The UKPHA is an independent UK-wide voluntary association, bringing together individuals and organisations from all sectors that share a commitment to promoting the public's health. The organisation aims to promote the development of healthy public policy at all levels of government and across all sectors, and to support those working in public health either professionally or in a voluntary capacity. Back

9 House of Commons Health Committee (2001). Second Report on Public Health (Vol I; Recommendation xvii). 2001, The Stationery Office. Back

10 Royal Pharmaceutical Society of Great Britain (1996). Baseline mapping study to define access and usage of community pharmacy. Back

11 Anderson C, Blenkinsopp A and Armstrong M (2003). The contribution of community pharmacy to improving the public's health. Report 2: Evidence from the non peer-reviewed literature 1990-2002. Available from the PharmacyHealthLink on 020 7572 2265; e-mail: pharmacyhealthlink@rpsgb.org.uk. Back

12 Department of Health (2000). The NHS Plan: A Plan for Investment. A Plan for Reform. London, The Stationery Office. Back

13 Scottish Executive (2000). Our National Health: A plan for action, a plan for change. Back

14 National Assembly for Wales (2001). Improving Health In Wales-A plan for the NHS and its partners. Back

15 Department of Health (2000). Pharmacy in the Future-Implementing the NHS Plan. Back

16 Scottish Executive (2002). The Right Medicine-A Strategy for Pharmaceutical Care in Scotland. Back

17 Welsh Assembly Government (2002). Remedies for Success-A Strategy for Pharmacy in Wales. Back

18 House of Commons Health Committee (2001). Second Report on Public Health (Vol I; Recommendation xvii). 2001, The Stationery Office. Back