Commissioning - Health Committee Contents


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.

EXECUTIVE SUMMARY

  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 health community?

    (ii) What will be the role of the NHS Commissioning Board?

    (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 board?

  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,[71] 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 health service?

  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 approach.

  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.

RECOMMENDATIONS

  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.

October 2010







71   High Quality Care for All: Improving Pharmaceutical Services, Department of Health, April 2009. Back


 
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