Written evidence from the Pharmaceutical
Services Negotiating Committee (COM 49)
1. The Pharmaceutical Services Negotiating
Committee (PSNC) welcomes the opportunity to contribute to the
Health Select Committee's inquiry into NHS commissioning. PSNC
represents and promotes the interests of almost 11,000 pharmacy
contractors in England and Wales. It is PSNC's responsibility
to liaise with the Department of Health and to negotiate the contractual
terms for the provision of NHS community pharmacy services.
2. As PSNC's submission to the Health Committee's
previous inquiry on this subject stressed, PCT commissioning of
pharmacy services has been regrettably patchy. This patchiness
has prevented many communities from receiving the full benefit
of their local pharmacists' skills, expertise and accessibility.
3. If the new commissioning structures set
out in the White Paper Equity and Excellence: Liberating the
NHS are to effectively harness the full potential of high
quality community pharmacy services, the Department of Health
and broader NHS must learn a number of lessons from the shortcomings
of the outgoing system.
4. This submission seeks to address three
particular questions raised in the Committee's Invitation to Submit
Written Evidence. These questions are:
(i) How will GPs engage with their colleagues
within a consortium and how will consortia engage with the wider
(ii) What will be the role of the NHS Commissioning
(iii) How will commissioning interface with the
Public Health Service?
This submission reviews the policy challenges
and questions that are specific to each of these areas, taking
into account community pharmacists' experience of current commissioning
structures. In considering these questions, it makes a number
of recommendations the committee may wish to consider in addressing
these challenges. These are listed at the end of the submission.
How will GP commissioning consortia engage with
the wider health community?
5. The White Paper's proposals to devolve
power and responsibility for commissioning services to healthcare
professionals are to be welcomed. However, it is of the upmost
importance that GP consortia fully engage with all local clinicians
and providers in order that locally designed disease pathways
and services utilise the skills of all in primary care. There
should be a community pharmacy representative on the Board of
all GP consortia in order to ensure pharmacy expertise on medicines
is used to best effect in the commissioning process.
6. Commissioning of services where GPs are
potential providers must be undertaken in a fully transparent
manner by a third party unconnected to any potential providers.
7. We welcome the proposals to develop standard
commissioning support for GP consortia, such as standard service
specifications, tariff pricing and standard contracts. Unnecessary
local variability in commissioning of the same service across
different PCTs has increased NHS and provider costs. A standardised
approach would avoid many of these costs and facilitate more efficient
commissioning and delivery of services; this must be a priority
in the current financial climate.
8. We believe GP consortia should be required
to demonstrate the best use of other primary healthcare professionals
and the infrastructure that they have to offer, which is frequently
funded by the NHS. One way to demonstrate this commitment would
be by commissioning a minimum number of Enhanced services from
community pharmacy contractors in all areas.
What will be the role of the NHS commissioning
9. We welcome the proposal to transfer responsibility
for the national community pharmacy contract to the NHS Commissioning
Board. The contract, introduced in 2005, has allowed community
pharmacy to make a significant contribution to the health of the
nation and at the same time save the NHS significant sums of money
each year, by effective procurement of medicines.
10. Our experience of PCT commissioning
of community pharmacy services over recent years has been varied.
Where good commissioning, following the Department of Health guidance,
has occurred, community pharmacies have been able to act as a
full team member within primary care service delivery. Sadly,
in many areas this has not been the case and PCTs have failed
to make best use of the skills and infrastructure that community
pharmacy has to offer, despite the NHS being largely responsible
for funding these resources.
11. In learning from this experience, we
believe that the pharmacy contract should be developed with more
nationally commissioned services and the introduction of directed
Enhanced services. These services would utilise standard service
specifications to support the efficient delivery of services,
yet still allow providers to personalise the service delivery
at the level of the patient or person. 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 NHS and the provider and a locally responsive
approach for the patient.
12. Community pharmacy and the other family
practitioner services are represented at a local level by Local
Representative Committees (LRCs), such as Local Pharmaceutical
Committees (LPCs). These bodies provide a range of important functions
that support service development for patients and the delivery
of effective and cost efficient services by contractors for local
commissioners. Currently LRCs have a relationship defined in the
NHS Act 2006 with one or more PCTs; a new relationship will need
to be established between the LRCs and the NHS, potentially the
NHS Commissioning Board's regional offices, in order that the
valuable work of these organisations can be continued.
How will commissioning interface with the public
13. We welcome the proposals to transfer
responsibility to local authorities for public health; this should
support a joined up approach to public health challenges by tackling
the wider determinants of health in a holistic manner. The Joint
Strategic Needs Assessment must be developed in partnership with
GP consortia and NHS providers and must be used as the basis for
local authority and GP consortia commissioning decisions.
14. 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. 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. 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.
15. 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
16. 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 PSNC has 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.
17. We support the establishment of statutory
Health and Wellbeing Boards and believe that community pharmacy
should have appropriate representation on the Boards, in order
that the potential of community pharmacy to improve public health
is maximised at a local level.
18. These Boards should help support partnership
working and commissioning by local authorities and GP 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 GP consortia commissioning,
particularly where a service could be commissioned by either side.
This issue could be addressed by the provision of a clear definition
of the services that local authorities will take responsibility
for in the forthcoming White Paper on public health.
19. It is also likely that without careful
collaboration between the two commissioners, there is the possibility
of public health commissioning driving conflict with GP consortia,
due to public health services, such as screening programmes, driving
unplanned healthcare expenditure.
20. We also note the potential for problems
where local authorities and GP consortia are not operating across
a coterminous area. These risks can all be overcome by commissioning
across a coterminous area, with excellent joint strategic planning
via the local Health and Wellbeing Board.
21. 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.
22. A full list of recommendations contained
in this submission is set out below:
(i) There should be a community pharmacy representative
on the Board of all GP consortia in order to ensure pharmacy expertise
on medicines is used to best effect in the commissioning process.
(ii) Arrangements should be put in place to ensure
that commissioning of services where GPs are potential providers
must be undertaken in a fully transparent manner by a third party
unconnected to any potential providers.
(iii) To ensure the most is made of the skills
and infrastructure that community pharmacy has to offer the pharmacy
contract should be developed with more nationally commissioned
services and the introduction of directed Enhanced services.
(iv) A new relationship should be established
between LRCs and the NHS (most likely in the form of the the NHS
Commissioning Board's regional offices), to replace the valuable
relationship between LRCs and PCTs defined in the NHS Act 2006.
(v) Pharmacy-provided public health services
that are shown to deliver undeniable value to all communities
should be commissioned at a national level.
(vi) Community pharmacy should have appropriate
representation on statutory Health and Wellbeing Boards, to ensure
community pharmacy's potential to improve public health is maximised
at a local level.
(vii) To ensure valuable community pharmacy services
do not `fall between the gaps' created by local authority and
GP consortia commissioning, the forthcoming White Paper on public
health should clearly define the services that local authorities
will take responsibility for as part of their public health role.
(viii) 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.
71 High Quality Care for All: Improving Pharmaceutical
Services, Department of Health, April 2009. Back