HC 1048-III Health CommitteeWritten evidence from Pharmaceutical Services Negotiating Committee (PH 66)

PSNC promotes and supports the interests of all NHS community pharmacies in England. We are recognised by the Secretary of State for Health as the body that represents NHS pharmacy contractors. We work closely with Local Pharmaceutical Committees to support their role as the local NHS representative organisations.

Our goal is to develop the NHS community pharmacy service, and to enable community pharmacies to offer an increased range of high quality and fully funded services; services that meet the needs of local communities, provide good value for the NHS and deliver excellent health outcomes for patients.

We welcome the proposals to transfer responsibility for public health to local authorities; this should support a joined up approach to public health challenges by tackling the wider determinants of health in a holistic manner.

Harnessing the Wider Public Health Workforce

Community pharmacies already provide a wide range of public health focussed services such as stop smoking support, NHS Health Checks, emergency hormonal contraception and sexual health screening; we were pleased to see this acknowledged in the Government’s White Paper Healthy Lives, Healthy People.

Given the scale of the challenge the country faces in improving public health and wellbeing, we cannot afford not to harness the expansive potential of the wider public health workforce, including the 10,700 community pharmacy teams that operate across England.

Given their position at the heart of the communities they serve, and their status as the health professionals with which people most regularly come into contact, pharmacists and their teams are ideally placed to provide an effective gateway into public health networks. In addition to providing high quality health and wellbeing services, and offering informed but informal health advice, pharmacists and their teams have a key signposting role in directing their patients and customers toward appropriate health services.

The new Public Health system should make use of a wider range of professionals, recognising that the expansive capacity of this broader workforce must be used to build robust and integrated public health networks operating at the heart of communities.

Health Inequalities

Community pharmacies are uniquely well placed to reach populations that can be difficult to attract to a conventional healthcare setting. Community pharmacies benefit from convenient locations and long opening hours. There is no need to make an appointment for most services, and they benefit from footfall attracted by the retail elements of the business. 99% of the population, even in the most deprived areas, can get to a pharmacy within 20 minutes, either by walking or using public transport. Some 84% of adults visit a pharmacy at least once a year.

NICE noted in 2008 that “They [community pharmacies] are able to meet the needs of minority ethnic and disadvantaged groups and those who may have difficulty accessing other community services.” Commissioning services from providers based at the heart of communities is an effective means of addressing health inequalities that cannot be replicated in traditional healthcare settings.

An Opportunity to Make a Bigger Impact – National Services

The accessibility of the community pharmacy network to patients and members of the public who do not frequently use other healthcare services is a key asset that the NHS and local authorities should leverage to improve public health. We believe that many of these services offer undeniable value to the population and would benefit from being commissioned at a national level. For example stop smoking services, observed consumption of substitute medication for treatment of substance misuse, brief interventions on alcohol, emergency contraception services and Chlamydia screening.

While we recognise the desire to provide personalised services for individuals and communities, we believe it is possible to benefit from the efficiencies of a nationally commissioned service, whilst at the same time providing sufficient flexibility for service providers to personalise their service offering to meet the needs of individuals.

Over many years, community pharmacies have developed the skills to allow them to personalise services for their customers in order to differentiate themselves from other pharmacies within this very competitive sector. Commissioning at a national level, whilst allowing the personalisation of service offerings at the level of the patient, provides the benefits of efficiency for the commissioner and the provider and a locally responsive approach for the patient.

Community pharmacy already has a public health element within its core NHS contractual framework which provides for provision of opportunistic healthy lifestyle advice to people visiting the pharmacy and involvement in locally organised public health campaigns. We believe that better use of the arrangements for public health campaigns and healthy lifestyle advice could support greater impact on the population’s health. For example, using the public health campaigns element of the contractual framework to promote nationally organised campaigns, such as No Smoking Day or DH cancer awareness programmes could see every community pharmacy in England promoting the same campaign over a defined time period, thus extending the reach of health promotion campaign messages.

An Opportunity to Make a Bigger Impact – Local Services

The transfer of some commissioning responsibilities from PCTs to local authorities should be informed by the experience of recent years, where we have seen a subtle range of local variations on standard services, such as stop smoking, commissioned by PCTs, without any perceivable benefit being delivered by this varied approach.

In order to support cost effective and efficient commissioning of community pharmacy services by local authorities we suggest that the work to develop standard service specifications we have undertaken with the Department of Health and NHS Employers should be augmented by the agreement of standard contracts or service level agreements and potentially tariff prices for some services.

This approach has the potential to support the delivery of services under an Any Qualified Provider basis; one such example is seasonal flu vaccination. A report published in May 2001 by the Health Protection Agency said last winter’s flu outbreak claimed 602 lives in the UK, with more than 70% of the deaths among 15 to 64 year olds. The HPA figures also show just 50% of under-65s in at-risk groups in England and Wales were immunised against flu.

In order to prevent unnecessary deaths from flu next winter, we believe the Department of Health should allow any qualified provider to administer vaccines, making proper use of the consistently high quality service offered by community pharmacists. As the commissioner only pays for flu vaccines administered, pharmacy-led services are a cost-effective way to increase the numbers of those protected against flu, and alleviate the pressure on GPs.

Where community pharmacies already provide vaccines, they have had very positive results in accessing hard-to-reach patient groups, and are really appreciated by the local community. For example, during last year’s challenging winter, nine out of ten patients on the Isle of Wight praised their local pharmacy flu vaccination service for being both “excellent” and “more accessible”.

Local Commissioning Structures

We support the establishment of statutory Health and Wellbeing Boards, but believe that it is essential that decisions and processes are transparent and take the views of health professionals and the wider community into account. A statutory online consultation process should be implemented to allow a wide range of stakeholders to influence decisions being made by the Boards.

Due to the significant impact that community pharmacy can have on the improvement of public health, PSNC believes that there should be representation of the interests of local community pharmacy providers on Health and Wellbeing Boards. Only with such representation, will the health improvement opportunities that community pharmacy can offer be fully realised.

These Boards should help support partnership working and commissioning by local authorities and commissioning consortia. We recognise the benefits of taking a more holistic approach to public health, but we are concerned that there is the potential in the new system for valuable services to “fall between the gaps” created by local authority and consortia commissioning. It is also likely that without careful collaboration between commissioners, there is the possibility of public health commissioning driving conflict with consortia, due to public health services, such as screening programmes, driving unplanned healthcare expenditure.

We are pleased to see the proposal that local authority funds for public health should be ring fenced. In the past such ring fencing has not always been effective in ensuring all funds are spent on the specified area. We therefore suggest that local authorities should be required to publicly account for their spending of the ring fenced public health monies at the end of a financial year.


Community pharmacies already provide many health improvement services, but we believe there is an opportunity for this contribution to be enhanced when the new approach to public health commissioning is implemented. The adoption of the suggestions we make above would support the community pharmacy sector to enhance its contribution to public health in an efficient and timely manner.

We would welcome further discussion on these matters with the Committee.

June 2011

Prepared 28th November 2011