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This Response to the Consultation on Calderdale Metropolitan Borough

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This Response to the Consultation on Calderdale Metropolitan Borough This response to the consultation on Calderdale Metropolitan Borough Council’s Pharmaceutical Needs Assessment (PNA) is submitted on behalf of Community Pharmacy West Yorkshire. We are the local representative committee for all pharmacies in West Yorkshire including every community pharmacy in the area of the Health and Wellbeing Board for Calderdale. Question 1: Do you think the purpose of the PNA has been adequately explained? Yes x No Question 2: Do you think that the draft PNA provides an adequate assessment of current pharmacy provision in Yes x No Calderdale? Question 3: Do you think that the draft PNA provides an accurate overview of the pharmaceutical needs of Yes x No Calderdale’s population? Question 4: Do you think that there any gaps in service provision that are not identified in the PNA? Yes No x Question 5: Do you think there is anything else that should be taken into account when reaching conclusions about Yes No x whether current pharmacy (chemist) provision meets the needs of Calderdale’s population? Question 6: Do you agree with the PNA conclusion that there is adequate provision of essential pharmacy (chemist) Yes x No services in Calderdale? Community Pharmacy West Yorkshire is pleased to see that the draft PNA reflects our view that Calderdale has a good coverage of pharmacies. It is encouraging that stakeholders involved by Calderdale Council in writing this draft also expressed no concerns about the current number or location of pharmacies across the borough. We agree that it is the case that there are sufficient pharmacies geographically spread so that there are no gaps in provision for Necessary Services. We also agree with the sentiment expressed that there are no gaps identified in Other Relevant Services which could not be filled by existing pharmacies. Community Pharmacy West Yorkshire supports the overall content and sentiment expressed in the draft PNA but have a number of suggestions as to how it could be improved in line with the regulatory requirements. With reference to “The National Health Service (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013”: Schedule 1 – Information to be contained in pharmaceutical needs assessments The draft PNA does not clearly meet Paragraph 1 and Paragraph 3 (statements of ‘Necessary services: current provision’ and ‘Other relevant services; current provision’) and is not, in our view, explicit enough when explaining the position taken on gaps in provision for these different types of service. We suggest that terminology from the regulations is used to add to the clarity of the document for one of its significant purposes; market entry. The sentiment of the draft PNA could be summarised with the following statements which we would suggest should be added to the final version “There are no current gaps in the provision of necessary services in the area of the Health and Wellbeing Board” “There are no current gaps in the provision of other relevant services in the area of the Health and Wellbeing Board” “The PNA has not identified any future needs which could not be met by pharmacies already currently on the pharmaceutical list which would form part of its commissioning intentions.” Part 2 – Pharmaceutical needs assessment Regulation 9(1). Community Pharmacy West Yorkshire also believes that all areas of Calderdale have a reasonable choice of pharmaceutical services and we are not aware of any stakeholder views to the contrary. If this is the case then this should be made clearer in the body of the PNA to help meet Regulation 9(1)(b). Regulation 9(2). We are not aware of any expected significant changes to demography, population size or changes to the health or wellbeing in the area which would mean, within the life of this PNA, that there would be a future need for additional pharmaceutical services for which there is a planned intention to commission. This seems to be supported by the PNA and we would recommend including a statement to the following effect to make this explicit: “The PNA, having regard to likely changes to the number of people requiring pharmaceutical services, the demography of the area and the risks to the health and wellbeing of people in the area, has not identified any future needs which are not already met by providers currently on the pharmaceutical list” Points of accuracy References are with regards to the draft PNA. Page 7 – The PNA introduction introduces pharmaceutical services and divides them into two bullet points at the bottom of this page (paragraph 5). Combing the core essential services provided by pharmacies in Calderdale into the description “The supply to patients of medicines and appliances that have been prescribed by a primary care clinician…” does not reflect the breadth of skill, care and attention that goes in to ensuring this is safe and high quality. This section should be expanded to encompass all of the valuable essential services provided by pharmacy teams in Calderdale. Table 7 – It is stated that there are 90 house planned for Luddenden. This should read Luddenden/foot as this is a much larger area. Page 49 – The formatting of this table makes the data hard to read. There is no commissioned MAR chart service in Calderdale so this column should be removed. .
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