PHARMACY PRACTICES COMMITTEE MEETING Thursday, 19 November, 2015 at noon Boardroom, John Dewar Building, NHS Highland, Inverness Retail & Business Park, Highlander Way, Inverness, IV3 8AG Application by GREEN+ HEALTHCARE LIMITED for the provision of general pharmaceutical services at 30 Laurel Avenue, Dalneigh, Inverness, IV3 5RP
PRESENT Elaine Wilkinson (Chair) Michael Roberts (Lay Member) Okain McLennan (Lay Member) Ian Gibson (Lay Member) Fiona H Thomson (APC Non Contractor Nominate) Gareth Dixon (APC Contractor Nominate) Caroline Morgan (APC Contractor Nominate)
In Attendance Andrew J Green (Area Regulations, Contracts & Controlled Drugs Governance Pharmacist) Helen M MacDonald (Community Pharmacy Business Manager) James Higgins, Green+ Healthcare Limited, Applicant Tim Ferguson, Green+ Healthcare Limited, Support Laura McElroy, Rowlands Pharmacy Donna Mackenzie, Rowlands Pharmacy, Support Tom Arnott, Lloyds Pharmacy Jane Fraser, Dalneigh & Columba Community Council Mary MacRae, Dalneigh & Columba Community Council, Support
Apologies John Ross, John Ross Chemists Limited Carmen Harrold, John Ross Chemists Limited
Observers in attendance Grant Stewart (NHS Highland Lay Member in Training) J Mark Sutherland-Fisher (NHS Highland Lay Member in Training) Mary V Morton, NHS Highland Head of Community Pharmaceutical Services Tracy Beauchamp, NHS Highland Pharmacy Data Analyst
1. The Chair welcomed everyone and asked all members to confirm that they had all received the papers for the hearing and had read and considered them. All members affirmed these points.
2. APPLICATION FOR INCLUSION IN THE BOARD’S PHARMACEUTICAL LIST
Case No: PPC – Dalneigh _2, Inverness Green+ Healthcare Limited, 30 Laurel Avenue, Dalneigh, Inverness, IV3 5RP
The Chair asked each Committee member if there were any interests to declare in relation to the application being heard from Green+ Healthcare Limited. No interests were declared.
3. The Committee was asked to consider the application submitted by Green+ Healthcare Limited to provide general pharmaceutical services from premises sited at 30 Laurel Avenue, Dalneigh, Inverness, IV3 5RP, under Regulation 5(10) of the National Health Service (Pharmaceutical Services) (Scotland) Regulations 2009, as amended.
The Committee had to determine whether the granting of the application was necessary or desirable to secure the adequate provision of pharmaceutical services in the neighbourhood in which the Applicant’s proposed premises were located.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P1 The Committee, having previously been circulated with all the papers regarding the application from Green+ Healthcare Limited, agreed that the application should be considered by oral hearing.
Prior to the hearing, the Committee had, as a group, visited the vicinity surrounding the Applicant’s proposed premises; the route followed being as laid out in advance and as directed by the Chair of the Pharmacy Practices Committee. In doing so, the Committee visited the existing pharmacies at Rowlands, Grant Street, Lloyds Pharmacies at both Greig Street and Ballifeary Lane and Kinmylies, all Inverness where a full range of amenities and services were sited within them in the immediate and surrounding areas of Dalneigh, Merkinch, Ballifeary and Kinmylies, all Inverness. The Committee noted the significant mixed housing which had been developed and occupied since the last application in the Westercraigs, Leachkin Hill and Craig Dunain areas in particular. The Committee also noted the West Link development which would link the Holm side of Inverness with the west side and onto the A82.
The Committee then visited the boundaries of the neighbourhood as defined by the Applicant and the residential area, noting the new housing in St Valery Avenue, which had been built and occupied since the last application, off St.Valery Avenue within the neighbourhood and various walkways, footpaths and play parks. Pedestrians and cyclists were noted to be travelling around the neighbourhood, as well as two individuals with mobility scooters and the No.4 bus was seen travelling throughout the neighbourhood, making several stops at bus stops where remarkable queues had built up. There were few private vehicles travelling around the neighbourhood.
Dalneigh is a neighbourhood consisting in the main of local authority housing, sheltered housing and supported housing, although there is some housing on Dochfour Drive and off Fairfield Road which is private, mostly of Victorian age and design and some of which had previously been large homes, now developed into flatted residences.
The Committee then visited the proposed premises where the Applicant was represented by Mr Higgins and Mr Ferguson, who were on hand with plans of the proposed fit out and premises plans to guide the Committee around the premises. It was noted that parking was available immediately outside the premises which were part of a retail esplanade below flats, the other units of which housed a hairdressers, charity shop and convenience store. A Baker’s Shop and a convenience store, with post office and ATM were noted on Montague Row, a further convenience store in Bruce Gardens and another on St Margaret’s Road. The Lidls Supermarket and other retail units were noted on Telford Street (Harvey’s Furniture, Curry’s Electrical, PC World, and Oak Furniture Store). Within the neighbourhood, there was also a veterinary surgery, fast food takeaway, Mosque and Church of Scotland. Social Services offices on Bruce Gardens and Limetree Avenue, Inverness High School, a nursery, two primary schools, (Dalneigh and Central School). The Community Centre was host to a varying number of community groups which met during the day and also in the evening (Over 50 Club, Mother & Toddlers Group, etc).
The Committee then returned to the Boardroom, John Dewar Building, Highlander Way, Inverness, IV3 5RP where the hearing was to be held. The hearing was convened under paragraph 3(2) of Schedule 3 to the National Health Service (Pharmaceutical Services) (Scotland) Regulations 2009 as amended (“the Regulations”). In terms of this paragraph, the Pharmacy Practices Committee “shall determine an application in such a manner as it thinks fit”. In terms of Regulation 5(10) of the Regulations, the question for the Pharmacy Practices Committee is whether “the provision of pharmaceutical services at the premises named in the application is necessary or desirable to secure adequate provision of pharmaceutical service in the neighbourhood in which the premises are located by persons whose names are included in the Pharmaceutical List.”
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P2 The start of the hearing was delayed by 30 minutes due to the site and neighbourhood visit taking longer than anticipated.
The Applicant, Support and Interested parties were invited into the meeting at noon.
4. The Chair apologised to all in attendance for the late start of the hearing and welcomed:-
The Applicant, Green+ Healthcare Limited represented by James Higgins, supported by Tim Ferguson, the Interested Parties who had submitted written representations during the consultation period and who had chosen to attend the hearing, were Laura McElroy, Rowlands Pharmacy and Donna Mackenzie Rowlands Pharmacy support, Tom Arnott, Lloyds Pharmacy and Jane Fraser and Mary MacRae for the Dalneigh and Columba Community Council (“the interested parties”). John Ross Chemists Limited submitted their apologies and a paper for reading at the appropriate point to the Health Board.
The Chair then invited the Committee members and Board officials to introduce themselves to the Applicant and all other parties.
5. The Chair reminded everyone that the meeting had been convened to hear the application from Green+ Healthcare Limited for the provision of general pharmaceutical services at 30 Laurel Avenue, Dalneigh, Inverness, IV3 5RP. The application would be considered against the legal test contained in Regulation 5(10) of the National Health Service (Pharmaceutical Services) (Scotland) Regulations 2009, as amended.
The Chair advised Grant Stewart and J Mark Sutherland-Fisher, NHS Highland Lay Members in training were in attendance, as was Mary Morton, Head of Community Pharmaceutical Services and Tracy Beauchamp of NHS Highland in an observation capacity for training purposes only and if there were any objections to their presence for any party to declare this now. No objections to the presence of the observers being present were made.
6. Regulation 5(10) was read out:
An application shall be granted if the Board is satisfied that the provision of the pharmaceutical services at the premises is necessary or desirable in order to secure adequate provision of pharmaceutical services in the neighbourhood in which the premises are located.
7. The Chair then described the format of the hearing, reminding those attending that no new evidence could be introduced at the summing up, explaining that it would be the sole responsibility of the Lay Members to decide whether or not to grant the application. Only after the decision had been made would NHS Highland Board officials rejoin the Committee to enable the decision and reasons to be recorded.
The procedure adopted by the Committee at the hearing was that the Chair asked the Applicant to make their submission. There followed the opportunity for the Interested Parties and the Committee to ask questions. The Interested Parties would then make their submissions. There followed the opportunity for the Applicant and the Committee to ask questions of the Interested Parties in turn. The Interested parties and the Applicant were then given the opportunity to sum up.
The Chair then asked the Applicant to give their statement.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P3 7.1. The Applicant’s Case
Mr James Higgins of Green+ Healthcare Limited stated
“Good morning, my name is James Higgins and I’m very grateful to the Chair, to the Committee and to NHS Highland for affording me the opportunity to appear here today and present this case in support of this application on behalf of Green+ Healthcare Limited.
I am aware that a large amount of evidence has been placed before the Committee in recent weeks and it may be a relief to everyone that I don’t intend to revisit every line of this. My intention is to summarise our research and place the facts of keenest relevance to the legal test before the Committee.
To that end, I’ll begin with our neighbourhood. Our neighbourhood is what most Inverness residents would describe as Dalneigh. A long established area of residential and some commercial building with a strong community spirit and identity. I am delighted to say that representatives of the areas’ Community Councils are with us today.
Physically, we define the neighbourhood as follows:-
To the north by the A862 Telford Street, starting at the Muirtown Bridge on the Caledonian Canal along to the Telford Street roundabout of the A82 at Kenneth Street;
To the east by the A82 from Telford Street roundabout along Kenneth Street, Tomnahurich Street and Glenurquhart Road to Tomnahurich Bridge at the Caledonian Canal. I can confirm that Transport Scotland classes this as a trunk road;
To the south, where the A82 meets the physical boundary of the Caledonian Canal; and
To the west, by the Caledonian Canal itself.
The population has recently been defined by Community Health Index as approaching 5,600 people.
The neighbourhood contains almost everything you’d expect to find in one of Highland’s larger towns including a large supermarket, several large scale retail outlets, places of worship, several convenience stores, a post office, a community centre, sports pitches and play facilities, vets, numerous small businesses including a hairdressers, orthodontists, therapists and tourist accommodation.
Two primary schools and one large secondary school are also contained within the proposed neighbourhood as are areas of sheltered accommodation, care homes, and a large proportion of the city’s social housing. As I’ve said, everything you’d expect, except, obviously, a pharmacy.
There is a tremendous amount of information available regarding this neighbourhood but to summarise it, let us look at what we can say about its average resident.
Compared with the average resident of Highland, a resident of the neighbourhood is more likely to be income deprived, employment deprived and to be dependent on benefits.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P4 In regards to their health, they are more likely to suffer at least one limiting illness and to develop these earlier, to be a carer for an ill loved one or to be a young carer. They are more likely to smoke, to miss opportunities for health screening, to have a smoking related disease, a mental health issue or a painful condition. They are much more likely to live in social rented housing, to be over 65, to be admitted to hospital as an emergency or to die younger.
By almost every measurable factor which would increase a person’s healthcare needs and decrease their quality of life and lifespan, the average resident is disadvantaged when compared with Scotland, with Highland or the City of Inverness.
This picture must then be overlaid with that of the wider challenges facing Inverness which impact directly on our neighbourhood. The city’s population has grown more than 25% in the 25 years to 2010 and is projected to add a further 30% to this already massively increased population before 2035. This expansion is not limited to the southern edge of the city. The inner Moray Firth development plan sets out the reconfiguration of land use around much of the city. One of its central foci is the area of west Inverness where it identifies no fewer than 19 areas to be developed. Ten for housing, with a total of 1,157 to be built out over the coming years. Some of these are already well underway, such as those at Westercraigs – and, just 9 days ago, 160 homes were approved by The Highland Council to be built on a 19 acre site at Torvean. Although, most development is not within the boundaries of our neighbourhood the further large scale development at Torvean and Muirtown are at its northern and southern extremities; and one of the largest developments shares its western boundary. The remainder are all nearby.
Additionally, the new Ness crossing will link the area with the south of the City and its population, itself to be boosted by a further 759 housing units which will be placed less than a mile from our neighbourhood.
Over the years 2010-2035, the percentage of people over 75 is projected to more than double.
The needs of the City have changed with its increasing population and the heatlhcare needs of the population are changing as it ages. The numbers of prescriptions to be dispensed per person annually rises as a population ages. Data from Nuffield illustrates the extent of rising prescription volumes increasing nationally by 20% in seven years. The risk of adverse drug reactions in elderly patients rise with the number of medications taken and studies have shown that good quality pharmaceutical care can reduce the risk and the cost of healthcare delivery to this patient group by ensuring better adherence to treatment and improved clinical outcomes. Put simply, the potential is there for pharmacy to play a part in keeping us healthier at home for longer and for less.
This will only be possible if the infrastructure, including health provision, keeps pace with the challenges. The Inverness Local Plan has recognised this, when it refers to the city’s expansion “outstripping the resources of public agencies to provide infrastructure and key services”.
The NHS Highland Pharmaceutical Care Services Plan also recognises the challenge in terms of deprivation, stating, “areas with high numbers of income deprived people consistently have poor population health outcomes”; and in terms of population growth and age profile, saying “significant growth in the general population, through planned housing developments will necessitate corresponding planned developments in the provision of core and additional pharmaceutical care services. The migrant population and significant growth in the elderly population will add to this requirement”.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P5 This requirement must be met by a modern, engaged and evolving pharmaceutical service and much of the work NHS pharmacy and others in the profession are currently engaged in is to make the strategy “Prescription for Excellence” a reality.
One of Prescription for Excellence’s central aims is encapsulated in the statement “The Scottish Government Vision for healthcare is that by 2020 everyone is able to live longer, healthier lives at home, or in a homely setting.”
The evidence suggests that this is achievable; however, it is impossible to pretend that there will not be an additional burden where current pharmacy services are proving themselves unable to cope with even current levels of demand or are consistently failing to deliver the current pharmacy contract.
Today, the residents of our neighbourhood are denied equality of access to pharmaceutical services as a result of several factors. The first and most obvious of these is that the neighbourhood, whilst possessed of most services does not possess a pharmacy. Secondly, travel to pharmacies outwith the neighbourhood is restricted. Restricted for those on foot by distance, the canal and by the extremely busy A82 Kenneth Street and Glenurquhart Road which, as earlier mentioned is classed by Transport Scotland as a trunk road and the A82 Telford Street which is four lanes wide for most of its length. These are amongst the busiest thoroughfares in the City. Nor surprising given that trunk roads, although only 6% of the total Scottish road network carry 37% of the nations traffic and 63% of its heavy goods vehicles.
What this means for residents was brought home to me by a partially sighted respondent to the joint consultation, who describes, and I quote “taking my life in my hands trying to cross Glenurquhart Road to get to Riverside Pharmacy” and goes on to make mention of others, similarly disadvantaged.
For those attempting to use public transport, there are issues with times of buses, the few streets served, distance to stops, waiting times for services and the fact that not one of the buses which travels through the neighbourhood passes any of the nearest pharmacies. This leaves them with no choice but to travel into the City Centre or to access services which have a substantial walk at both ends of the bus journey rendering bus travel to access a pharmacy self defeating. The extremely limited nature of bus services has been a major concern for the Community Council over many years.
Those who have access to a car may drive to services but they too must contend with barriers. There are, of course, the usual issues with parking at several of the pharmacies, particularly free parking and cost of this or fuel, road tax and running costs is likely to be a factor for many in our neighbourhood with restricted income. The central issue though is actually access to a vehicle. Even those households with a vehicle may not have access to it during the date where it is used for commuting or, in the course of employment. Here, though, census data clearly shows that a large proportion of the neighbourhood population simply don’t have a vehicle at any time.
It is common to find that areas of Highland have higher than average car ownership when compared with Scotland as a whole and the explanation is often given that a car is more of a necessity when living in any part of the Highlands than, for example, with the central belt, however, unusually for Highland, 2011 Census figures show that 40% of households do not have access to a car or van. That means that they are actually a third less likely than the average Scottish resident and only half as likely as the average Highlander to have a vehicle available to them.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P6 This is quite a disadvantage on its own, but if we consider this is the light of the poor bus services and geography the problem of access becomes more acute. Add in the higher likelihood of limiting illness and carer responsibilities which will restrict mobility and ability to freely travel, as well as the fact that existing pharmacies are cited as being under pressure or overstretched six times in response to the consultation then we can see very clearly that there is a multi factorial bar on access to services for many people.
It is true that many pharmacies will make deliveries to people within the neighbourhood. By this, I mean that they will bring dispensed medicine to someone’s home. This should not be confused with an adequate pharmaceutical service as these patients are denied the minor ailments service, a pharmaceutical advice service, the chronic medication service, public health service and smoking cessation services in this way. It seems incredible that in the past contractors have sought to use their provision of such a limited, non NHS service to a few people as justification for denying a full NHS pharmaceutical service to the many.
How then are the pharmacies situated in adjacent neighbourhoods delivering these services to those who are able to access them? Most prescriptions dispensed by pharmacies are acute medication or AMS prescriptions. The number of items dispensed by the pharmacies considered as interested parties by this application has risen by over 83,000 or 16% in 6 years and in the three pharmacies closest to our boundaries by 24%. That this workload has affected adequacy is evident in the six mentions of existing pharmacies struggling in the Consultation Analysis Report and in many other non specific references for the need for service improvement, access and for information on pharmacy services. The feelings of our respondents are backed by FOI data which shows that a single pharmacy based miles from the city is dispensing more than a thousand items a month produced by the medical practices yards from the pharmacies ranged here to oppose our application and by the fact that Councillor Bet MacAllister has raised the concerns of her constituents regarding repeated trips to a pharmacy represented here today for prescriptions that have taken multiple days to dispense.
What about the minor ailments service? A central plank of the current pharmacy contract, the minor ailments service is designed to encourage self care, to ease the pressure on GP services and provide access to medication, treatment and advice. We are fortunate in that we are able to look at the performance of the interested parties over time, with information being available from several freedom of information requests between 2011 and 2015.
Generally, the picture is a poor one. In 2011 the 5 worst performing minor ailments service pharmacies in the City were to be found amongst our interested parties, in terms of patients treated. Through the years, what is most remarkable is how little has changed. In 2014, 5 of the 7 showed well below average rates of registration and dispensing and four of those 7 not only fell below 50% of those averages but remained in the lowest activity banding possible for this service. Looking at June, 2015 information, 5 of the 7 are still well below the average for registration and dispensing and only lack of information on the city’s other pharmacies for this year prevents us confirming if they are still the 5 worst performers, but it is difficult to imagine they would have caught any of their rivals with this level of consistently poor activity. This is all the more remarkable given the high local indexes of health deprivation which are known to correlate with greater need for an uptake of this service.
The chronic medication service aims to encourage joint working between GPs and community pharmacies to improve patient care by identifying and prioritising risk from medicines and addressing existing and preventing potential problems with medicines; minimising adverse drug reactions; and providing structure follow up and interventions where necessary.
The pharmacy care record allows us to record interventions of all kinds, including smoking and particularly new medicines and high risk interventions.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P7 The average Scottish community pharmacy has almost 400 CMS patient registrations. The latest available figures show continued failure in this group of pharmacies to match even the average performance in NHS Highland. Unfortunately, this is not just a recent phenomenon. In 2011, the bottom 3 CMS performers in Inverness were drawn from those pharmacies invited here as interested pharmacies. In January 2013 the 7 pharmacies had a desultory one new medicine and 4 high risk interventions, not each but between them!
Not much improvement even by December, 2014, when not only continuing to have lower average registrations than other pharmacies across the region, 2 pharmacies had still to record a single high risk or a new medicine interventions and 2 had actually had fewer people registered than they had in the 23 months previously. The other pharmacies within Inverness and Highland doubled or trebled their numbers of registered patients over the same period illustrates the lack of effort and engagement this represents. Finally, in September of this year – mere weeks ago – the group’s activity was still below the average expected and some startling instances of non engagement remain. Two pharmacies have still not – and this was just weeks ago – have still not registered even one high risk medicine or new medicine assessment, despite this having been a condition of payment since March 2013, and 4 of them have failed to risk assess even 50% of their registered patients, indeed 3 of these have not risk assessed 5% of theirs.
These omissions are of genuine importance, the correct risk assessment is an absolutely key first step in the management of these conditions. Without this activity, encouraging registrations and the ongoing work to engage with those on new or high risk medications, CMS simply will not work and patients are put at grater risk of harm or at best denied a valuable service that is available to their peers residing elsewhere. In one pharmacy, these failures would give us cause for concern but across a localised cluster such as this it represents a fundamental failure and a serious gap in available care.
Other core services are grouped together as the public health service or PHS. This is all about a more proactive involvement of the pharmacy team in promoting self care, healthy lifestyles and backing health promotion campaigns, both locally and nationally.
The focus has shifted from supply of treatments for conditions to prevention and education. Although PHS consists of many strands including the sexual health service (emergency hormonal contraception and health promotion), probably the most recognisable and readily measurable of these is smoking cessation.
Locally, smoking prevalence is high and this gives pharmacy a great opportunity to make significant contributions to the HEAT targets, especially the 40% of quits which are to come from areas of deprivation.
In the year to July, 2014 the invited pharmacies achieved fewer than 6 quits each, however, 3 of these managed zero and 2 of the 3 failed to register a single quit attempt. Again this is nothing new, 2 failed to record a quit or attempt in the year ending November 2012 and even in the latest set of figures (September 2015), 3 pharmacies have not a single 12 week quit and 2 have not completed a single attempt – shocking for a HEAT target, the majority of which were to be delivered through pharmacy, the total aim being a total of 80,000 national quits to which several of these pharmacies contributed zero. Bear in mind that HEAT is an acronym standing for:-
Health Improvement; Efficiency and Governance; Access to Service; and Treatment appropriate to individuals.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P8 In smoking cessation this is exactly what this group of pharmacies have failed to deliver in every year for which I have been able to obtain data.
This is yet another manifestation of an ongoing pattern. The bottom 3 performers for smoking cessation in the entire city were amongst our interested parties in 2011 and again in 2012, 2014 and 2015. We see clear failure to deliver a core service – in an area of national priority and where people not only stand to benefit most but where they are harmed most by the omission.
Even where something seemingly simple like health promotion is concerned there is evidence that these pharmacies have not been performing with multiple references in the Consultation Analysis Report to a lack of information about services as well as references to “improving pharmacy services” and existing pharmacies being at capacity.
To summarise the performance of these pharmacies is not easy, however, we can certainly state that they have failed to deliver adequate pharmaceutical services, not occasionally or even repeatedly, but continuously across a number of services, over a number of years and often to those who need them most.
The information I have presented here today comes from a variety of sources, from Highland Council, NHS Highland, Scottish registry office, Scottish neighbourhood statistics, freedom of information requests and others. To be clear, these are not my opinion, but information gleaned from reputable sources with no vested interest in this application.
The committee will be aware that there have been submissions from amongst the interested parties stating that service is adequate or making a number of other points in support of their interests which bear at best tangential relationship to the legal test. I think it is also worth noting that several of the interested parties have chosen not to exercise their right to appear here and state their position at all.
In addition to the information I have put before the committee we have the information gleaned from those who have responded to the joint consultation on the proposed pharmacy. I personally view it as a major improvement in the application process that the consultation which now takes place jointly between NHS Highland and any potential applicant. In this case, Green+ Healthcare Limited together with NHS Highland and with the input of the Scottish Health Council.
This has enabled community engagement and elicited responses which are free from any attempt to influence their result or content. Further, the questionnaire utilised was structured in such a way as to reflect as closely the legal test as possible and the entire process agreed by all stakeholders as detailed.
It is only fair to report that some respondents to the consultation both in writing and in community feedback did state that the form was not very user friendly. Despite this, the Consultation Analysis Report reveals a strong response from a cross section of the neighbourhood and some who live beyond it. Over 90% of people recognise the neighbourhood and agree that the location is appropriate to the needs of this neighbourhood. 98% agree that the proposed opening hours are appropriate and over 80% agree that the granting of this application is necessary and desirable to secure adequate provision of both core and additional, pharmaceutical services within the neighbourhood. It is absolutely clear that respondents to the consultation feel that current pharmaceutical services located as they are and performing as they have been are inadequate.
Further support for our application has been forthcoming, from the comments of NHS harm reduction, local GP practices, Councillors, Community Councillors and the Area’s Member of Parliament, Drew Hendry.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P9 We submit, then that we have a neighbourhood, not only recognised by its residents and others but entirely enclosed by the barriers of the canal, the A82 trunk road and the busy A862.
We have a population disadvantaged by multiple measures demographically and denied equality of access to pharmaceutical services by, amongst other things, their geography and their income.
We have pharmacies situated in adjacent areas which have failed to deliver in multiple categories, which are subject to concerns raised by Councillors which have failed to deliver on areas of national priority in areas of great need to those in greatest need of these services not once, but again and again.
If we have all of these things before us then I further respectfully submit that we have the clear evidence that to secure adequacy of pharmaceutical services in this neighbourhood, the granting of our application is both necessary and desirable.
Thank you for your attention”.
The Chair thanked Mr Higgins for his statement on behalf of Green+ Healthcare Limited and invited the Interested Parties and then members of the Committee to ask questions of him.
7.2 Questions from Ms McElroy, Rowland’s Pharmacy to the Applicant
Q. Can I confirm the population numbers and where you got them from?
A. According to Community Health Information and NHS figures the population is 5,600.
Q. You talked about receiving a strong response to the questionnaire. How many responses were there?
A. 68
Q. Were they all based in Dalneigh?
A. Two thirds were.
Q. Would you say that was a good response from 5,514 people?
A. Yes actually, I would because this is the first time this had been done this way. We could have done a questionnaire but we needed to adhere to the Regulations but for 68 to respond if I put it in context with NHS Highland’s consultation about a hospital reorganisation across the whole of highland – they received only 20.
Q. How did the consultation happen?
A. There were press releases, Twitter, Facebook, signposting where the questionnaire was available on the website and at every retail place in the community were ballot boxes were placed, so no conversations were made by me directly so as to influence people. Anytime I attended Community Council meetings, I let NHS Highland know in advance and it was agreed. There were so many ways which this happened, through the NHS Highland Communications Team.
Q. You talked about a partially sighted patient who has to cross road to access one of the pharmacies. Where does that patient go to access his GP?
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P10 A. That’s not recorded in the Consultation Analysis Report.
Q. Would there be a GP practice within the neighbourhood where the new pharmacy would be?
A. You may not need to attend a GP if there was a pharmacy there.
Q. You talked about the delivery service from other pharmacies. Would you want to do this?
A. I guess if you have a housebound patient, you wouldn’t want to see them without their medication, however, I would encourage those who were able to come into the pharmacy.
Q. What would be your solution, then, for those housebound?
A. I would deliver to them but it would be best for them if they came to us as that would give them meaningful access to services such as the minor ailments service and the chronic medication service.
Q. You talked about patients being denied services from other pharmacies. How do you know that?
A. The Tavistock Institute supports signposting to pharmacy services, amongst other services, for vulnerable people. If you are just a delivery driver patients may feel they are getting a service but they are not. Further health development studies show That the level of engagement is lower, as are social factors for disadvantaged areas which mean that if you are just putting medicines through the door they are not necessarily accessing services.
Q. Are you sure this is what is happening?
A. Certainly from the response received, that is what seems to be the case.
7.3 Questions from Mr Arnott, Lloyds Pharmacy to the Applicant
Q. You kind of “had a go” at the current pharmacy service providers. Are you aware of any complaints to the Health Board in respect of current service provision?
A. I am only speaking from what I know from the consultation analysis report.
Q. If someone was living in the south of Laurel Avenue, adjoining Bruce Gardens. Would it not be nearer the Lloyds pharmacy at Riverside? If they lived on Attadale Road, where it joins onto Fairfield Road, would they not be nearer to the Lloyds pharmacy on Greig Street, than your proposed site?
A. I haven’t measured it but from my pharmacy, you wouldn’t have to cross a trunk road.
Q. You said acute medication is the majority of service provided by a pharmacy, is that true?
A. The four core services all refer to barcoded prescriptions and that is what I meant. The acute medication service refers to a system where all the prescriptions are barcoded.
Q. Are you saying it is all acute?
A. The acute medication service is the method that is what I am saying.
Q. Were you referring to Lloyds pharmacies when you said about the CMS figures?
A. Yes.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P11 Q. What’s the increase in the population been like between 2001 and 2013
A. Stable.
Q. Have there been any changes to the neighbourhood since the previous application 2 years ago?
A. The neighbourhood has physically changed. The gap in health outcomes has widened, there have been new homes built which has put pressure on the existing pharmacies. There has been the worsening provision of pharmaceutical core service delivery, including CMS and lack of progress of MAS but there has been a massive increase in dispensing figures and people are going without because of that.
Q. Where do you think they access the nearest bank?
A. Well, my bank is at 28 University Road in Belfast and I have not been there since 2008!
Q. Where would they access a GP practice?
A. They don’t live near the GP practices but they would access a pharmacy on a more frequent basis.
Q. Is a ten minute walk from your proposed premises to the nearest existing pharmacy doable?
A. If you can manage that in 10 minutes, then that is great.
Q. A resident from St Fergus drive would have a 10 minutes walk to your pharmacy. If they were able to walk, would they walk to your pharmacy?
A. You would have to ask them.
Q. 46 responses to the consultation is less than 1% of the population. Do you not think that is low?
A. I think that the response is not the number I would have sought, I’ll admit but we undertook a joint consultation with NHS Highland as we had to. It could have been more accessible but would have been less appropriate to the legal test. We could have had the Council carry out a petition but experience has shown that this doesn’t carry any weight.
Q. So why would 1% be good?
A. Only one respondent disagreed with the proposal from a response of 68. I have made every effort to get views but it is a snapshot as all survey results are.
7.4 Questions from Ms Fraser, Dalneigh & Columba Community Council to the Applicant
Q. If you were sited within Laurel Avenue, how effective do you think the additional services would be in the community at large?
A. I think they would be really effective, especially for the elderly and young in respect of the minor ailments service, information providing and signposting. The chronic medication service would enable their long terms conditions to be properly managed, closer to home, which is a priority under the Prescription for Excellence, Scottish Government initiative. I feel it can make a difference to the demographics and statistics in general but to the people within the community this is a real and great opportunity to make a difference.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P12 7.5 Questions from the Committee to the Applicant
Caroline Morgan, APC Nominated Contractor Pharmacist
Q. You talk about only delivering to the housebound. What about collecting from GP practices?
A. Yes, we would offer that as a service. If I can expand regarding the housebound patients. If you look at the terms of the community pharmacy contract, you get more out of face to face regular consultations with patients in terms of their wellness. I would certainly be encouraging people to access the pharmacy as much as possible.
Q. How much of your time would be taken up collecting prescriptions from the practice?
A. Well, it wouldn’t be my time, it would be another staff member who would go round the practices and collect the prescriptions.
Q. Would that be once a day?
A. Yes – may do more if required.
Q. If figures are low for MAS uptake why do you think that is?
A. Well, I think pharmacists have to promote this and drive it. There was a bit of variance and I have taken these up because they are so low below the area average. The pharmacy I work in, in Inverness has been open less than 3 years and even it has more engagement.
Q. Does that affect items dispensed?
A. Probably but we do more engagement in terms of providing information. Some people are of the mindset they need a pill for every ill but a consultation with the pharmacist may be the most effective course of action for them.
Q. Is it because the no of prescription is low under the minor ailments service the figures are lower than the average?
A. I would say the desperately low levels of engagement would reflect the numbers here.
Ian Gibson, Lay Member
Q. You have criticised the other pharmacies in terms of their levels of engagement. What would you do differently and which would demonstrate an improvement to pharmacy services?
A. The plan would be to have two consultation areas to engage more fully. I have already spoken to harm reduction services about providing their services. I would put to better use pharmacist time by employing an ACT (accredited checking technician) to enable the pharmacist to be out a bit and to make a difference in terms of the services, such as smoking cessation etc.
Q. That would be appropriate once they are in the door but what are your plans for engagement outwith the four walls?
A. I have spoken to the community councils and plan to still attend their meetings regularly. I have had a meeting at the James Cameron Community Centre, and would plan to provide a smoking cessation service from there. I have gone to the mother and toddler group and spoken about the minor ailments service as well as the over 60s groups to talk about these services.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P13 It is a challenge. I could leaflet, but engaging with groups where they already go is a start.
Michael Roberts, Lay Member
Q. Would you agree the consultation was multi mediate?
A. Yes
Q. Would you agree they are all familiar with multimedia and Twitter?
A. I do not have Twitter myself and that is why we made it available at the post office and community centre. I also had a drop in day and a sheet produced jointly with the Health Board to answer any questions.
Q. Why do you think there was apathy in responding?
A. The complexity of the consultation was raised as an issue by the Scottish Health Council and the Community Council along with the lower level of engagement which you get from deprived communities. Additionally, a lot of people are sceptical that this application will go through and that it should have the last time, so what was the point in participating.
Q. Would that not make them even keener to respond this time?
A. Some have responded because of that and there has been more response from the community councils but this has not been all the way.
Q. Within the responses you have 46 that were in the area. Unfortunately, we don’t have this broken down any further. Do you have any idea how they responded to each of the questions?
A. No I don’t have this.
Gareth Dixon, APC Contractor Nominate
Q. With your level of response at 68, how does this compare to any other surveys in any other areas?
A. I don’t have a direct comparison for any other pharmacy applications, as this is the first but the NHS Highland Communications Manager had advised that it was good as they had only received 20 for a whole Highland wide hospital reorganisation consultation.
Q. Would you say that acute prescribing has increased by 16%?
A. That is the Scottish average, according to the Nuffield trust – this didn’t match the freedom of information request data, so I can’t say. What I can say is that between the river and canal it has increased by 24% against a Scottish average of 20%.
Q. Are any GP sites switched on to delivery CMS in Inverness? A. Yes, Fairfield and Riverside are, at the moment, but all the pharmacies who have had their training have had it switched on.
Q. Do you have any figures to provide on the number of CMS serial prescriptions being written?
A. No.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P14 8. The Interested Parties’ Case – M Laura McElroy, Rowlands Pharmacy
Ms McElroy, Rowlands Pharmacy stated “Thank you, Chair and Panel. Thank you for allowing me to represent the views from Rowlands Pharmacy as to why we believe the application for a new pharmacy in Dalneigh in Inverness is neither necessary nor desirable. In order to cover the legal test, I’ll first address the issue of neighbourhood and for the purpose of this hearing, I will agree with the applicant’s neighbourhood of Dalneigh, that is:-
To the north – Telford Road, running along to Kenneth Street; to the east – down the A82; to the south, continuing down the A82 to meet the canal and to the west, the canal.
The area described as Dalneigh is included within this neighbourhood. Is it a neighbourhood in its own right? Does it have all facilities required for day to day living? Banks, post offices, libraries, schools, GP surgeries and, of course, pharmaceutical services? I believe that most people will have to come out of this neighbourhood to their GP practice or to come to a pharmacy, therefore, these residents are used to crossing the neighbourhood boundaries. Indeed, in Inverness, it should be noted that residents can register with any GP across the city and are not confined by geography or neighbourhood.
If we were to accept Dalneigh as its own neighbourhood, then we must remember that the legal test states that consideration must be given to the pharmaceutical services in adjoining neighbourhoods. The nearest pharmacies for residents around the area are at Rowlands, Grant Street; Lloyds, Greig Street; as well as Lloyds at Riverside Medical Practice; and Kinmylies pharmacy – four pharmacies in total – all just outwith the defined neighbourhood. In reality, these are well within easy reach by car, by foot, or on public transport. Indeed a frequent bus service, up to every 20 minutes for those that need to get out and about to conduct their daily business is available.
If patients travel a little further, they have the choice of 11 pharmacies within Inverness, all providing the core pharmaceutical services and additional delivery services too. Is access to pharmaceutical services a problem?
I am proud to be the Area Manager for Rowlands and I don’t like sitting here hearing that they are all delivering below average services. Rowlands, Grant Street provides all the core services of the contract – minor ailments, public health, including smoking cessation and EHC, gluten free food provision, stoma service, AMS – and, we provide CMS at figures above average. This branch was also one of the first in the Rowlands estate to provide blood pressure measuring and continues to do so. We have recently introduced a Rowlands’ inhaler service, which includes recycling and monitoring of patients, thus encouraging those with asthma and COPD to engage with the pharmacy team to manage their condition. Furthermore, we use the recycling element with the pharmacy team to support patients, particularly those who return full ones, are to engage in understanding what we can do to help them improve their compliance. Waiting times are low. We provide a comprehensive collection and delivery service to those that need it and, in fact our delivery drivers are counter assistant and first aid trained and know when to deal with minor ailment service queries themselves, or refer back to Ruth, our pharmacist, to deal with personally, if required.
We have no capacity restrictions for dispensing methadone, suboxone or NOMAD trays. Furthermore we have offered to deliver needle exchange but currently, at the moment, the Health Board are happy with current arrangements and see no need – at this particular point in time, for more contractors to be involved.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P15 We have a community notice board – and I hope you noticed this when you visited the pharmacy, just after going through the door. Our staff are “Dementia Friends” – every staff member is signed up to this and also ALISS – the Alliance with the third sector which is an amazing resource to support our patients with long term conditions.
Our pharmacist, Ruth, has been with us for over three years and particularly enjoys engaging in all the services and has a real passion for delivering patient care to those with particularly complex medical histories. In addition, we are supported by a well trained and experienced team of dispensers and healthcare assistants. In fact, Janice, our non pharmacist, ACT Manager has working in this branch for 27 years and supports every one of her patients with the due care and attention they all require. She is an asset in that she also manages the branch for us, which frees up the pharmacist to go out when required and is always looking for new ways to enhance efficiency. So much so, it was her suggestion to expand upstairs and improve the capacity for dispensing dosette boxes and weekly prescriptions, therefore freeing up downstairs to deal with acute prescriptions and deliver more services. We do provide services to many patients from Dalneigh, who all are loyal customers because they value their interaction with the team at Rowlands, appreciate the services that are offered and feel supported in managing both acute and long terms conditions. In addition, they have built up good relationships with the local GPs, nurses, addition services and other healthcare professionals, including dentists and opticians, which ensure patient care is always at the forefront.
There is nothing to suggest our pharmacy, or indeed others, in the neighbourhood are offering poor or inadequate service. What we must look at is current provision. Is it adequate or not? Personally, I would be very pleased to hear what else we could do in our pharmacy to make it more adequate.
Does anyone within this neighbourhood have any problems in accessing pharmacy services? I think not.
Are the current services adequate? I think, without a doubt and, I cannot see the need for a pharmacy in the defined neighbourhood to be granted.
Thank you”.
The Chair thanked Ms McElroy for her statement and invited the Applicant, Interested Parties and then members of the Committee to ask questions of her.
8.1 Questions from the Applicant to Ms L McElroy, Rowlands Pharmacy
Q. Do you think that prescription numbers have grown and that this has put pressure on service provision?
A. No we have Janice who has redesigned and moved staff in and out of the dispensary, fully utilising them, with no pressure, releasing capacity.
Q. It’s just I wondered how almost 47% of patients registered have not been assessed for CMS?
A. Some of the work we have done looks at the assessment element of what is required from Scottish Government but I have asked that comprehensive care plans be done. I am aware that all risk assessments haven’t been done but this is because we were working on registration and low risk clients first and focussed on 50% higher risk and more patients centred. We have focussed on providing more thorough approach to make a better outcome for high risk patients.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P16 Q. How are you establishing risk if you are not carrying out the assessment?
A. We leave that decision with our pharmacists as they have the pharmacogenetic knowledge of their patients. Ruth would be able to tell from patient history and a general chat what her patients are like, so she has not currently done the tick box exercise for all patients out of the 384 registered. She wanted to do the assessments for the patients she viewed to be high priority first, focussing on need, according to her experience.
Q. Its just, are you aware of the NES pack for CMS guidelines?
A. Yes I am aware. The way we are doing it is around patient’s need, using our experience.
Q. What do you say as to you having provided no smoking quits through the calendar year?
A. I knew you would ask that. It is difficult. They do start a lot (of patients), done by counter assistants and they will come back but sometime getting patients to 4 weeks is really difficult. Engagement is low not because we are not engaging, but because we can’t get them to week 4 and it is even harder to get them to week 12. We have a higher number in our Culloden pharmacy because the demographics there are different as it’s easier to get people along the journey. It is difficult to get people through the journey but not difficult to get them onto the programme.
Q. Would you say, then, it was through the journey?
A. I don’t have the figures.
Q. In the year up to July 2014 only 4 attempts were made. Are you aware of that?
A. No, because I was on maternity leave and I am focussing on the figures now, in conjunction with the branch. Celebrating successes and moving forward.
Q. Do you know what the smoking prevalence is?
A. No.
Q. Were you aware that it is 20% above the national average and your shop is based in the bottom 10?
A. Yes, I am aware, but the process used for people giving up has also changed and we are actively engaging. Patients are maybe not as keen to engage and don’t want to stop so maybe our figures are not telling the story but we are still proud.
8.2 Questions from Mr T Arnott, Lloyds Pharmacy to Ms L McElroy, Rowlands Pharmacy
Q. Just to clarify have you no capacity issues?
A. None
Q. Are you offering all the services?
A. Yes
Q. And are you performing all elements of the pharmacy contract?
A. Yes, I have been looking at that and they are doing more than the average for MAS and other services.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P17 Q. Are all staff members Dementia Friends?
A. Yes, they came in and provided all staff with the training, how patients would interact and what they would be looking for. All staff are now trained and able to deal with dementia patients in a more robust way.
8.3 Questions from Ms J Fraser, Dalneigh & Columba Community Council to Ms L McElroy, Rowlands Pharmacy
Q. I am just wondering, with regard to the new housing in Glendoe Terrace and plans to build additional housing in Merkinch, how this would impact on your ability to deliver services?
A. We would welcome it. We deal with new patients coming in on a regular basis. We have expanded up the stairs to provide more capacity. We are on for a refit in the next financial year, approved by the company. It is a small space but the team and Janice are able to utilise it.
Q. What percentage of your customers come from Dalneigh?
A. Having looked at one prescription bundle this morning and our deliveries, this is difficult to put a number on but probably from 50 to 100 patients we would deliver to 8 in Dalneigh.
Q. Given the size of the population is that number not low?
A. No, because take that number over a day.
Q. You mentioned that it’s a library that makes a neighbourhood. Is there a library in Merkinch?
A. No, but when you define a neighbourhood it doesn’t have to have all the facilities in it to be a neighbourhood and people have to go elsewhere. It doesn’t mean that by not having a library or a pharmacy on their doorstep that they can’t access it from elsewhere.
Q. So, do you consider yourselves local to deliver a service to Dalneigh, i.e. in the situation of a local teenager popping in for a pregnancy test on the way to school, would you be local then?
A. That is about convenience, not adequacy.
Q. How easy would you consider it to be for someone to walk to your pharmacy?
A. I did it myself. It took me 15-20 minutes from Laurel Avenue and could be the same if you walk from within Merkinch, but I am fit and healthy and it didn’t take me all that long.
Q. If you aren’t fit. Is parking not restricted?
A. There is a car park across the road and you could park there.
Q. Much has been made of smoking cessation services and it’s been stated to have not, perhaps been as successful as everyone would like. From a Dalneigh resident’s perspective, if they don’t have transport would it not stop them accessing those services? A. It would be good for them to walk and keep them fit!
Q. Would this not put people off?
A. You could say the same for every service. You can access services through your GP and other avenues other than just pharmacy.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P18 Q. Much has been said of the delivery of medicines to the elderly. How willing would they be to speak to strangers about their medicines?
A. Our drivers are not strangers and may be the only people they see. We have made an effort to put them through their medicines counter and first aid training to ensure they are equipped as possible.
8.4 Questions from the Committee to Ms L McElroy, Rowlands Pharmacy
Caroline Morgan, APC Contractor Pharmacist
Q. Do you collect from the GP surgeries?
A. Yes.
Q. How often?
A. Once a day.
Q. What are your staffing levels?
A. We have Janice, our ACT, an NVQ Level 3 trainee, 2 NVQ Level 2s and a third person doing NVQ Level 2 training on the counter and a counter assistant. We also have our two delivery drivers. We put our counter staff through the NVQ Level 2 training so that they can have all the skills and be used best to help out in other areas of the pharmacy. The upstairs area will hold all the qualified staff once they are trained.
Ian Gibson, Lay Member
Q. You have highlighted the experience of staff and optimism. Do you do outreach work?
A. Yes, we do health promotion throughout the year by visits to local primary schools, businesses, similar to following the monthly health promotion calendar. We have encouraged staff working at Harry Gow’s next door (a bakery) to loose weight, but often this doesn’t work well!
Okain McLennan, Lay Member
Q. Regarding the risk assessment issue, you mention you have left this to the pharmacist to decide what intervention is appropriate. Is this not scientific?
A. 241 have had risk assessment against 346 and they are on track for getting this done. I understand your view that the risk assessment is a scientific tool but it is a tick box exercise.
Q. Is this not a method for recording scientific processing?
A. It’s just that the tick box element process has not been done. When she (the pharmacist) has looked at them she has done more with the 241 and is working on the 120 which, in her opinion, are the ones who have the most need.
Fiona Thomson, APC Contractor Pharmacist
Q. Going back to the services – blood pressure monitoring, inhalers, weight monitoring and recycling - are these core services?
A. No.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P19 Michael Roberts, Lay Member
Q. Did you look at the questionnaire?
A. Yes.
Q. What did you think?
A. It was difficult and always will be as the patient’s understanding of what a pharmacy is, is very difficult and hard to navigate, although at the back of the survey there was a good descriptor of what it was.
Q. Why do you think it had a low response?
A. I believe it was because patients that we have, are happy with the service that they receive from us at Rowlands.
Gareth Dixon, APC Non Contractor Pharmacist
Q. You mention that your pharmacist has used the Responsible Pharmacist Regulations to see patients. How many times has this happened in the last 12 months?
A. A handful at most, as these consultations start from a phone call.
Q. When did your delivery drivers become counter assistant trained? When did that happen?
A. When a member of staff was off sick and when there was a maternity cover requirement of 20 hours. I took the opportunity to increase the hours of the driver and spend time in the branch.
Q. How long ago was that?
A. At least within the last year, longer if not.
Q. How does your CMS risk assessment figures compare to say, Culloden?
A. In Culloden they are higher but then the registration numbers are higher in Culloden and there are 2 pharmacists working there.
Q. How do you assure consistency if the risk assessment tool is not being followed?
A. It’s not about consistency. I am still very happy with how Ruth has done this. I could get her to go back through all the patients and do this tomorrow but that would just be a tick box exercise and she has made a professional decision to go with the 241 first.
9. The Interested Party’s Case – Mr Tom Arnott, Lloyds Pharmacy
Mr Arnott stated “I would like to thank the panel for allowing me to speak today. The applicant’s reason for making this application seems to be that the pharmaceutical services provided by current contractors are inadequate because there are no pharmacy premises in his definition of the neighbourhood. There are, as the panel is aware, numerous examples from Pharmacy Practices Committee hearings and numerous National Appeal Panel hearings that adequate pharmaceutical services can be provided to a neighbourhood from pharmacies situated outwith that neighbourhood and this is the case in Dalneigh.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P20 In 2013 a similar application was refused by the Pharmacy Practices Committee and this decision was upheld by the National Appeal Panel on the grounds that the services provided to the neighbourhood were adequate.
Since then nothing has changed. It is also interesting to note that the applicants proposed opening hours are 6.5 less than in the previously refused application.
Indeed the panel will see from “The Advice and Guidance for those Attending the Pharmacy Practices Committee” they must consider what are the existing pharmaceutical services in the neighbourhood or in any adjoining neighbourhood.
There is a pharmacy within 800 metres of the applicant’s proposed pharmacy – Lloyds Pharmacy on Greig Street, which offers all core services as well as a full delivery service for those who require it. Lloyds Pharmacy, Riverside is 0.8 miles from the applicant’s proposed site. This also offers all core services as well as a delivery service and it also offers flu vaccinations. This pharmacy was recently classed as good on a recent General Pharmaceutical Council visit and I am sure that the applicant and the panel are aware that the awarding of “good” demonstrates the pharmacy is in good order and demonstrates its ability to offer safe patient care. There have been no complaints to the Health Board about any gaps in service or quality of care in either of these pharmacies.
Currently, Rowlands Pharmacy and Kinmylies pharmacy, both within approximately one mile of the applicant’s proposed premises also supply pharmaceutical care to the residents of Dalneigh. Indeed, if you take the wider boundaries as being the Caledonian Canal to the west, the river Ness to the east and south to the north, the Beauly Firth. These 4 pharmacies are providing services to 14,050 patients, approximately 3,500 per pharmacy. The national average is 4,600 per pharmacy, the granting of a firth pharmacy would reduce this figure to 2,810 per pharmacy and, without doubt could affect the viability of existing pharmacies. The panel must take into account whether the granting of an application would adversely impact on the security and sustainable provision of existing NHS primary medial and pharmaceutical services in the area concerned. If the applicant contends that Kinmylies pharmacy only supply a pharmaceutical service to the residents of Kinmylies and Scorguie, west of the Caledonian Canal.
Rowlands pharmacy only supply a pharmaceutical service to the residents of Merkinch, north of Telford Street, then the Lloyds pharmacies are supplying a pharmaceutical service to the residents of Dalneigh and Ballifeary – a combined population of 6,284. I would ask the applicant if another pharmacy contract were granted, what would be the impact on current service providers?
Currently, the residents of Dalneigh access services such as GPs and banks outwith the neighbourhood proposed by the applicant. There is a regular bus service which allows them to do this and, Donna within Rowlands tells me that this is regularly used.
Indeed, at the site proposed by the applicant, there is currently only a small convenience store, a haridressers and a community workshop. Further evidence that the residents of Dalneigh regularly access services outwith the neighbourhood. The applicant has carried out a public consultation. He received only 68 responses. This is an extremely small percentage of the residents of Dalneigh. Indeed it is only 1.3% of the population of Dalneigh. Of those, only 46 actually lived in Dalneigh – 0.9% and the total number of people who said it was necessary to approve an application was only 56 (that on page 34 of the Consultation Analysis Report, which represents 1% of the Dalneigh population. Interestingly, when asked about the provision of additional pharmaceutical services, on page 33 of the CAR, around half of those surveyed replied they did not know. On page 35, the response to the proposed location was that 29 out of 43 – 67% gave the reason as convenience.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P21 Convenience is not a reason to grant a pharmacy contract.
On page 39 – do you think that additional services are being adequately provided by existing pharmacies to the neighbourhood, only 18 out of 56 respondents said No. However, the panel has to take account of the views of the residents of Dalneigh. The fact, that the applicant has only managed to gain the support of only 0.9% of the residents of Dalneigh, despite a newspaper campaign and meetings with residents and local councillors, I note that at the meeting held on 17 June, 2015, 4 community councillors did not attend. This low response rate demonstrates that there are currently no inadequacies in pharmaceutical services within the applicants’ defined neighbourhood.
In the papers provided, the applicant has not shown any inadequacy in the current pharmaceutical services provision to the residents of Dalneigh, other than the nearest pharmacy is 800 metres from his proposed site.
There is no mention in the NHS Highland Pharmaceutical Care Services Plan for a need for a pharmacy in the proposed neighbourhood and I am unaware of any complaints to the Health Board regarding current service provision.
The applicant has shown no inadequacies in current pharmaceutical provision other than there is no pharmacy in his proposed neighbourhood. There have been no complaints about current service provision. I would, therefore, ask the Panel to refuse this application as it is neither necessary nor desirable in order to secure the adequate provision of pharmaceutical services in the neighbourhood in which the premises are located”.
The Chair thanked Mr Arnott for his statement and invited the Applicant, Interested Parties and then members of the Committee to ask questions of him.
9.1 Questions from the Applicant to Mr Arnott, Lloyds Pharmacy
Q. Are you aware that you cannot travel through the 800 metres you mention unless you go through back gardens?
A. Well, It took me 10 minutes and, I am not nearly as fit as Ms McElroy.
Q. If you look at the quote in the Inverness Courier of 6 March, 2015, did a member of pharmacy staff not say that she thought it would be ok to have another pharmacy?
A. Yes, but she said as long as it didn’t affect existing pharmacies.
Q. Regarding the additional services, is there an issue where people didn’t know about all the services?
A. Yes it is possible. The Government still doesn’t publicise eMAS.
Q. Did you notice that in the consultation where they said they didn’t know if services were adequate that they still felt it was necessary to approve the application?
A. No, but still only 46 of the respondents live in the neighbourhood.
Q. There were 168 other points made where people make their own comments I wonder if you notice that convenience was mentioned there?
A. I didn’t notice but still only 46 people who live in Dalneigh responded.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P22 Q. Did you notice that only one person from 168 mentioned convenience? Why is this no longer relevant than from when you made your speech?
A. I didn’t say that. What I said it was that only 46 people from the neighbourhood responded.
Q. I wonder if you can explain why MAS are so low in both branches i.e. Only 25% of the average for South and Mid CHP?
A. I couldn’t exactly say why because Rowlands are way above it. I cannot say why patients aren’t accessing it, but can assure you that all Lloyds are aware that it is a service.
Q. One of the branches in bottom 20%. Do you feel this is a service being properly driven in these branches?
A. I am confident that anyone who receives the MAS is appropriate to receive it.
Q. Why isn’t there any risk assessments being done for CMS between December, 2014 and September, 2015 and then up until Monday past only one.
A. I can say they have been done - 100%!
Q. Do you know smoking cessation prevalence in the area is 7% above national average for women and 11% for men?
A. No.
Q. What would you say about no quit attempts being provided between the two pharmacies and no uptake of the smoking cessation service?
A. I would agree with the lady from Rowlands that it is not quits but, then, you don’t have to come from a deprived area to need help stopping smoking.
Q. So, is it your position that the service has been offered but they have just not quit?
A. Yes, but also a there has been a massive drop off because of the new system.
Q. Can you tell us then why in 2014 they managed a total of attempts of zero? Do you think they were offering it and not recording it? Given in July 2014, between the 3 pharmacies there were 4 quit attempts and zero quits, would you say that was adequate?
A. I couldn’t say but they may be accessing the service from other areas like you said you would do then that might provide the explanation. I think people have access to adequate pharmaceutical services.
Q. Is it their fault if they don’t have access or is it their own fault?
A. No, it would be their choice.
9.2 Questions from Ms McElroy, Rowlands Pharmacy to Mr Arnott, Lloyds Pharmacy
Q. Would you say the border from your pharmacies and Dalneigh are reasonable?
A. They are accessible.
Q. Would you pharmacies encourage people to walk there?
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P23 A. Yes they would encourage people to take more exercise.
Q. Are you delivering all the core services?
A. We are indeed.
9.3 Questions from Ms Fraser, Dalneigh & Columba Community Council to Mr Arnott, Lloyds Pharmacy
Q. You made mention of the lack of response. Have you ever attended a community council meeting to hear the issues?
A. No.
Q. So, in basing your views on this consultation, would you agree that the questions are difficult for a lay person to understand?
A. It would depend on how they were given out but a return rate of 46 is low.
Q. Do you think that the various areas in Dalneigh aren’t that good and that that this may contribute to the low uptake of smoking cessation services? For example, I live in Dalneigh and further than 800 metres to your pharmacy, would this not deter me.
A. No.
Q. Do you think the main road to cross would be a deterrent?
A. Glenurquhart has at least 5 traffic aisles with zebra crossings and it is not a busy road. I may being going at the wrong time of day but had no difficulty.
Q. What about Kenneth Street?
A. It is busier but surely, if the council though this was necessary they would put measure in place.
9.4 Questions from the Committee to Mr Arnott, Lloyds Pharmacy
Caroline Morgan, APC Contractor Nominate
Q. What are the staffing levels in Lloyds? Do you employ ACT?
A. No but we do have counter staff and dispensers.
Q. Why are the MAS levels low?
A. I had a conversation with the pharmacy staff and they assure me they offer this service.
Q. Is it low across the Group?
A. No. There isn’t in Fife with eMAS in Dalgetty Bay which is an affluent area and eMAS is used the most.
Q. Would they be coming there on holiday?
A. Yes, or with young children.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P24 Ian Gibson, Lay Member
Q. Did you say there was no point in having a pharmacy and then going on to provide an outreach service outwith it?
A. What I was saying is that I was confused as to why the applicant would apply for a pharmacy contract and then want to provide services outwith it.
Q. What do your pharmacies do to promote services outwith the pharmacy?
A. Generally we wouldn’t do much except for maybe an outreach event but not at these pharmacies. We currently have flu vaccines going outwith the pharmacy.
Okain McLennan, Lay Member
Q. Following on from previous questions. We have a range of pharmacy services which require to be delivered in pharmacy to encourage eMAS and smoking cessation. Are you doing this solely from within the compounds of the pharmacy?
A. Unfortunately, we can’t promote these outwith.
Q. Forget that then. What about other services?
A. We provide a diabetes testing service, blood pressure monitoring. Lloyds are a branch which offer all these services. I am sure you will have seen the adverts.
Q. What about specific outreach. Do you not see that this is necessary particularly in areas such as this?
A. Not up until now.
Michael Roberts, Lay Member
Q. Do you provide a collection and delivery service?
A. Yes
Gareth Dixon, APC Contractor Nominate
Q. How much a percentage of prescriptions are delivered as opposed to being collected?
A. An average amount for the size of the pharmacies.
10. The Interested Parties’ Case – John Ross Chemists Limited (trading as Kinmylies Pharmacy) (read by Mrs Helen MacDonald, NHS Highland Clerk to the Pharmacy Practices Committee)
Mrs H MacDonald read out, in the absence of a representative from John Ross Chemists Limited, their statement advising that she would be unable to take or answer questions on behalf of John Ross Chemists Limited in doing so.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P25 Mrs MacDonald read as follows:-
“Unfortunately, due to unforeseen circumstances, I am unable to attend this hearing. I wish for my right to have representation still to be heard and so wish for this to be read out to all present – as it would have been should I have been there – and to be taken into consideration in the summing up by the panel:-
NHS funding, in order to be sustainable and profitable, pharmacies require to have the infrastructure to support it which comes at huge cost to any business. Patients in Dalneigh are supported and catered for with service provision by the existing pharmacies in the local area. It must be questioned how NHS Highland could justify the extra cost to the NHS should another pharmacy contract be approved when it would just serve to duplicate services already being provided by other contractors.
Should another new contract be granted then we would have to advise the potential for job losses in our pharmacy due to depletion of script numbers as a knock on effect. This would, I am quite sure not only be in our pharmacy as it is becoming harder and harder to maintain a margin to support future development and continuation of service level. Again, it would have to justify the rational and reason should another contract be granted.
The last hearing and appeal rejected the application and there has been no change within the 2 years which would validate a reason to grant this new application. The panel would have to show without any question that the other pharmacy providers do not already more than fulfil services to the population in Dalneigh and surrounding area.
We offer as do the vast quantity of other providers a delivery service. It must be stressed that this service is not just a drop off service but actually collects prescriptions from Doctors surgeries throughout the Inverness area and take back to the shop to be dispensed and then deliver to patients’ door.
This is not an NHS service but a service provided by the pharmacy at our own cost so that all members of the public have access to pharmacy provision regardless where they live or where their Doctors’ surgery is in relation to them.
Pharmacies do not receive any funding or financial incentive to provide this service and do so as a professional service so patients are not restricted or penalised in any way should they have a pharmacy right on their doorstep.
At all times during opening hours there is a pharmacist in the shop which can if required by used for telephone consultations should a patient have concerns around their medication or any other issues they may need support or advice with.
It should be remembered that the local Post Office closed due to lack of community support and was unviable due to lack of the support so this should be a high level consideration into the need and necessity of a provision within an area that could not offer the footfall to support a local post office.
It must also be highlighted about the closure of the pharmacy in Church Street just over 2 years ago which did not have the footfall and patient numbers to justify its future. This was a short walk from the Dalneigh area so again it would need to be questioned why anyone would see another provision to be a viable option.
The area is already at saturation point with pharmacy provision and there is no necessity to have another.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P26 If other pharmacies struggle to maintain service with financial constraints then why would it be deemed viable for another one?
A new pharmacy contract in Dalneigh would not be in the interests of NHS Highland and at best would be convenient to a small population all of whom already have easy access to a large number of pharmacies. This would just be a case of overlapping services in all directions from their current location. At worst it would be a drain on NHS resources which as everyone is aware are already stretched very thin as it is.
The public consultation was a very interesting read and the survey not what I would call appropriate in its line of questioning. If you ask members of the public would it be a good idea to have a pharmacy in their area, it is highly probable they would say yes just as they would should you ask them if they would want the post office to reopen!
Asking members of the public about services already provided by existing pharmacies again would flag up questionable responses. Unless a member of the public has the services provided to them for example gluten free or methadone then they will have no idea if the service level is adequate or not so it is a leading question which would not really in respect have any basis on how good a service is provided or not. I would not believe in any term that all those participating were in receipt of all the available services from all available pharmacies so they would not be able to give and honest and reliable response. This being said it would need to be taken at the very best with a pinch of salt and I would suggest further surveys are developed by a professional body that actually has an insight into the appropriate questions to be asked and be unbiased in methodology.
I would like to stress that a new contract should not be granted on a personality basis i.e. an applicant being “popular”, but should only be granted on the need and necessity of a new service provision being required.
I see no reason that could be validated to have this pharmacy contract granted and it is certainly not desirable or necessary taking into account surrounding facilities already on offer in Dalneigh area.
There is more than adequate pharmacy provision in the Dalneigh and surrounding area so the panel should reject this application accordingly, yours sincerely, John Ross, Managing Director, John Ross Chemists Limited”.
The Chair thanked Mrs MacDonald for reading out, on behalf of and in the absence of a representative from John Ross Chemists Limited, their statement and noted that as a result the Applicant, Interested Parties and members of the Committee were unable to ask questions.
11.0 The Interested Parties’ Case – Ms Jane Fraser, Chair, Dalneigh & Columba Community Council
“Firstly, I would like to thank the Committee for allowing The Community Council to address this hearing. It would be safe to say we are on unchartered waters here, so please, abide with me.
Dalneigh and Columba Community Council have, after due consideration, come to the conclusion that a pharmacy would be of benefit to the community at large for the following reasons:-
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P27 1. I would refer to Councillor Campbell’s letter of 6th July 2015, as this highlights very clearly, the social and economic composition of the Dalneigh area and with the incumbent problems that such a composition can produce. I do concede that not all residents fall within any of the categories, referred to, but there are sufficient numbers to cause the Community Council concern in addition there will be those families who, while working, are on a low wage and may be dependent upon various benefits such as family credit;
2. The Dalneigh neighbourhood consists primarily of semi detached housing, with a limited number of flatted dwellings and single story semi detached housing. In common with other such council estates a large number of the dwellings are privately owned some of which are now privately rented out. Within the proposed pharmacy area there is a nursery, a primary school, a secondary school, which opened in 1937, a residential home, community centre, a church, sheltered housing complex, a dental practice, the usual convenience stores, a post office, allotments and a residents association. I would contend that Dalneigh is a well defined and well established neighbourhood, not just because of all the aforementioned but because, if someone were to ask where I lived and my reply was Dalneigh they would know the area of the town to which I had referred to;
3. The application highlights the current situation with regarding existing pharmacies. It is notable that there are currently no pharmacies within the Dalneigh area. Every individual who resides within Dalneigh, if they do not have access to private transport, will either have to walk or be reliant upon public transport. Firstly, consider those who do decide to walk. The pharmacy at Kinmylies is a considerable distance to walk especially for the elderly, those with children and those who have a long term medical condition, as this would entail an uphill walk, in all weathers. Secondly, the pharmacy in Greig Street. It is conceded, for certain areas within the proposed catchment area of the proposed pharmacy, this would be the closest option, but not all.
In this instance the individual would have to cross a main road – Kenneth Street – which is a trunk road. While there is a pedestrian crossing, it is within the knowledge of the Community Council that not all motor vehicles stop timeously. Thirdly, the pharmacy next to the Riverside Medical Practice, once again this would only be convenient for a selection of Dalneigh residents and this would entail crossing one of the main roads into Inverness, being Glenurquhart Road, which is another trunk road and a road in which there are no pedestrian crossings. Fourthly, there is Rowlands Pharmacy in Grant Street. While there may be no hill to walk up, it is a considerable distance to walk for anyone within the proposed catchment area and is simply not practicable. Fifthly, Superdrug and Boots pharmacies both are situated in the town centre and once again would be a considerable distance for anyone with a physical impairment and necessitate the requirement to negotiate the crossing of either one of the aforementioned trunk roads. In addition, certain main roads within Dalneigh are currently being used as “rat runs” which has resulted in additional traffic using Maxwell Drive. This is one of the roads which would have to be negotiated to go to the Lloyds Pharmacy at the Riverside Medical Practice, likewise, Dochfour Drive must be negotiated to go either to Greig Street or the town centre. I would make reference here to an article dated 20 October, 2015 in the Inverness Courier. The issue of the speed of the vehicles using the “rat run” has for some time been a live issue at the Community Council meetings with the implications of the increased volume of traffic and the speed of the motor vehicles concerned. Given the demographic make up of Dalneigh, not all individuals will be able to walk such as the elderly or the infirm. If they cannot access private transport their only option is public transport. Buses in Dalneigh only run every half hour. There are no bus services to the pharmacies in Greig Street or Lloyds at the Riverside Medical Practice.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P28 There is no direct bus services to either the pharmacy at Kinmylies or Grant Street and to make such a journey would result in considerable time consuming and convoluted journey, essentially making it impractical. This realistically, only leaves Superdrug and Boots in the Eastgate Centre, for which it is possible to access by bus, given the half hourly bus service. A copy of the bus timetable was sent to the Committee. Dependent upon the individual concerned, some may be in receipt of a bus pass but not all. Those with young families, who may be on a limited income, may find the charge prohibitive. The cost of the journey is approximately, for a single journey, £1.45 and return £2.75 (figures provided by Stagecoach), especially if they have to make two journeys. One to submit the prescription and another to collect same. While these fares may not seem prohibitive, if the individual is on a limited income, coupled with the implication of welfare reforms and proposed reforms, these fares take on a different perspective;
4. It should also be noted that at present the residences around the Lloyds Pharmacy in Greig Street are much closer to the two pharmacies in the town centre than for any Dalneigh resident;
5. I do concede that many pharmacies do provide a delivery service. While this is convenient, there being no requirement to visit the pharmacy, it does remove the personal touch and for some elderly individuals, in particular, this may be one of the few occasions that they will have to talk with someone, nor will they be able to ask any questions about their medication which may be concerning them. Social isolation is an issue in Scotland, as highlighted by the recent research by Age UK. Although I concede that the figures for Dalneigh would be difficult to quantify. Importantly, the pharmacist may be able to detect if there are any underlying issues with the individual concerned and, importantly, the individual could raise issues which may be concerning them in a more informal setting, other than having to make a doctor’s appointment, go along to the surgery and discuss same or talk themselves out of this course of action as they may feel that they would be just “bothering” the doctor. Essentially, the pharmacist may be able to pick up on concerns and/or issues and direct the individual to the right department or agency before it becomes a major issue, thus, eventually saving the NHS money by reducing unnecessary visits to the doctor or, even accident and emergency and, hopefully, enabling any health issues to be dealt with in the initial stage;.
6. The proposed core and nationally agreed pharmaceutical services can only be of benefit to the community as a whole given the social and demographic composition of Dalneigh, such as the Healthy Start Vitamins, which would benefit families with young children and the public health service, consisting of smoking cessation, sexual health service and health promotions, given the level of health issues with Dalneigh would, hopefully, not only raise awareness among the residents but provide ways of addressing these problems. Other pharmacies may provide such services but locally based services of such a nature would be more accessible especially if considering something like the morning after pill and the issuing of an emergency medication under the unscheduled care provision. Instead of a journey of at least an hour to another pharmacy, one would be local and convenient;
7. The proposed opening time is 8.30am, Lloyds in Greig Street and Rowlands in Grant Street open at 9am, the 8.30am opening time would be of benefit to those individuals going to work, if by car, parking is readily available in Laurel Avenue, unlike Greig Street or Grant Street, which can be congested and the prescription may be uplifted at night as the proposed weekday closing time is 5.30pm. The Saturday opening time of 9am to 1pm would provide sufficient time for anyone to visit the pharmacy and, as previously stated, there is sufficient parking available; and
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P29 8. The location of the proposed pharmacy is unlikely to be used by all residents within the proposed catchment area but could be used by those within the Dalneigh housing estate, thus they would not have to negotiate the various roads, be they the trunk roads or any of the roads on the local “rat run” list.
The Community Council has arrived at the conclusion that such a pharmacy would be necessary and desirable. There is currently no pharmacy provision within Dalneigh and all residents have to leave the area to access these services, which either entails a car journey, walking or using public transport which, if the individual has mobility issues, young children, limited income or a student at the local secondary school, a local based pharmacy would, essentially, be the more practical option. A locally based pharmacy, while offering services comparable to the existing pharmacies, would be able to advance various health initiatives such as smoking cessation which would benefit not only the individuals concerned but their respective families and finances. Such initiatives may be tailored to the local area and thus have a greater impact as individuals who would use the pharmacy on a regular basis and they would talk to others as it were, spread the word about what the pharmacy had to offer.
While much has been stated about the services such a pharmacy would provide, it would benefit Dalneigh in another way, halting the continued moving away of services. We have already had the post office relocate to Montague Row, which is still within the neighbourhood but not located within the centre of Dalneigh. Further, if individuals frequent the same pharmacy they will develop a more personal relationship and, in doing so, may be more willing to discuss other health issues, they will not just become another customer, but an individual who may feel it is safe to talk to the pharmacist if they have any health concerns and the pharmacist to pick up on any underlying issues, be it isolated elderly, young families, those with long term health issues or worried teenagers.
Lastly, just because to date, all residents have had to leave the area to access a pharmacy and are therefore considered to be used to the situation, I would like to draw everyone’s attention to the comments contained within the free text section of the survey phrases such as “it would be great to have a pharmacy”, “long overdue”, “great demand”, “valuable service” are used in relation to the proposed pharmacy. If such an argument were to be upheld then it could be argued that once a town had one type of service why do they need another such service, as people, after all, are used to going to that one provider.
A pharmacy would be desirable as it would be locally based and easily accessible and essential as it would be beneficial to the health and wellbeing of the residents of Dalneigh”.
The Chair thanked Ms Fraser for her statement and invited the Applicant, Interested Parties and then members of the Committee to ask questions of her.
11.1 Questions from the Applicant to Ms J Fraser, Dalneigh & Columba Community Council
Q. As we heard earlier, are you aware that the post office moved not closed?
A. Yes and it moved didn’t close because it first closed then relocated within the community centre, then to a shop and then relocated within a shop due to demand from not having one previously.
Q. Do you feel that people do have to leave the neighbourhood for their weekly shop?
A. Yes, I suppose everyone leaves to do their shop but a pharmacy would have a direct benefit on the health and wellbeing of the residents in that area. I walk to work so am aware of where it is to access.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P30 I would never consider walking to Grant Street and Kinmylies but then, I am not everyone and there is a high elderly population which is set to continue to rise and I envisage the impact would benefit people in the long term.
Q. Are you aware of the large Lidls supermarket in the neighbourhood?
A. Yes.
Q. Do you feel that there is more than 1.3 % support?
A. Definitely.
Q. Were you surprised about some of the figures you heard today?
A. Yes, I was very surprised but maybe not everyone going into a chemist knows what is available.
Q. Do you think that the 3 pharmacies offering smoking cessation services amounting to zero over a calendar year is acceptable?
A. Definitely not.
11.2 Questions from Ms L McElroy, Rowlands Pharmacy to Ms J Fraser, Dalneigh & Columba Community Council
Q. You talked about the delivery service not having a personal touch. How would a delivery service differ from a local pharmacy than what we are delivering in Grant Street?
A. Walking to a pharmacy may not seem so far to walk if it were within Dalneigh, which would encourage people to walk as the pharmacy would be closer.
Q. Do you not think the delivery service provided by us has a more personal touch?
A. Seems to me to be quite impersonal but then I am not in receipt of medicines in this way. A local service would be more personal rather than just a number on the prescription.
Q. Is local about convenience or adequacy?
A. I would say it’s about adequacy. It is a large area with a number of problems and a pharmacy may engage them in their services to rectify these.
Q. You talk about all the traffic problems. Will they all walk?
A. Probably not. Some will take cars.
Q. Will that not have more people coming into the area?
A. No. They are leaving the area that way. There is a lot of publicity and comments, particularly in relation to the elderly stood at junctions.
Q. Would more cars coming into the area not be worse?
A. I don’t understand how there would be more cars in the area.
Q. Well, would there not be more coming in to access the pharmacy?
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P31 A. This is not really an issue, given the services which would be provided.
Q. You said there were no pharmaceutical services being delivered in Dalneigh. Is that true?
A. They are on the fringe of the area, on the outside.
Q. Do you need to have them sited in Dalneigh? What would be the benefits over current service?
A. More accessible.
Q. And in terms of adequacy?
A. They would be more used.
11.3 Questions from Mr T Arnott to Ms Fraser, Dalneigh & Columba Community Council
Q. Why was Lloyds in Church Street closed?
A. Well, you are Lloyds, you must know but the Eastgate Centre has taken a lot of business away and a lot of the old town is now charity shops.
Q. So, are all core services currently offered by all providers?
A. I couldn’t tell you.
Q. Is convenience part of the legal test?
A. I don’t know.
11.4 Questions from the Committee to Ms J Fraser, Dalneigh & Columba Community Council
Caroline Morgan, APC Contractor Pharmacist
Q. How many members on the community council?
A. There will be 8 members.
Q. How often do you meet
A. We have 10 meetings a year.
Q. Did the new committee write this letter?
A. I actually wrote it with the full committee’s backing.
Q. Why would you think that to have a pharmacy open within the neighbourhood that patients could take their prescription there and get the personal touch? Would patients using their usual, same pharmacy not get this service there?
A. I guess the thing I am looking at is that rather than just passing, dropping off and collecting a prescription, you would be making relations and people are more likely to access other services from within the community as they would speak about the services available and be more inclined to use their services.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P32 Q. Are you implying that most of the prescriptions dispensed are just coming in randomly and not being regularly used as a regular pharmacy to build up relations?
A. Personally, I just go to the nearest one, be it Lloyds, Superdrug or whoever.
Q. Do you think that’s what the other residents do?
A. At present we have no option.
Fiona Thomson, APC Non Contractor Nominate
Q. Do you feel that there was more support in the community than was evident from the consultation?
A. This application is very different from the last time around and people are talking about it more. When I looked at the consultation it was very daunting.
Michael Roberts, Lay Member
Q. Where do you meet?
A. In the Dalneigh Primary School.
Q. Where do you go for your GP?
A. Riverside.
Q. Which pharmacy do you use?
A. Whichever is convenient at the time.
Q. Do you think that’s the norm?
A. I think it just depends on where you are at the time. If you are at work, you would use one near there and if that is in the town, then one near there but I have never used the one next to the doctors.
Q. Going back to your comment about a personal touch from a local pharmacy. Do you not think that they would access the pharmacy near where they access their prescriptions?
A. It’s not about the prescriptions. It’s about all the other services and I don’t think people would go outwith the area to access other services, such as smoking cessation services. If it was local we wouldn’t have to travel so far. We need to think about local people. The young, elderly and school age would definitely reap the health benefits.
Q. Where do people work in Dalneigh?
A. I wouldn’t like to say.
Q. Is there a nursery in Dalneigh?
A. Yes.
Q. Do you think adults leave Dalneigh and put their kids into the nursery?
A. It is probable as Dalneigh is a residential area in the main.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P33 Q. So if they needed to go to medical facilities would they do this out of Dalneigh?
A. Yes, they would have to.
Q. So if they were going out, the pharmacy would normally be closed when you got back and so wouldn’t it be necessary go to the pharmacy near your GP practice?
A. Perhaps not - after the doctor, you have to go back to work. I wouldn’t pick up my prescription then go to the pharmacy next door as I would need to return there on my way home and therefore would go to one which was near my work. I do think the 8.30 opening time would help and you could collect on the way to work the next day rather than undertake a detour, depending, of course, on where your GP is. People tend to stick to their GP. I have stayed with mine for over 50 years and I have moved and so have they.
12. Summing up
The Applicant and Interested Parties were then given the opportunity to sum up.
12.1 Ms J Fraser, Dalneigh & Columba Community Council stated “As a representative of Dalneigh & Columba Community Council I maintain a pharmacy would be of benefit to the residents as it would improve the health for the people who are in an area of deprivation”.
12.2 There was no summary statement received from John Ross Chemists Limited to read, however all parties were asked to note the letter which had been submitted and read by Mrs MacDonald.
12.3 Mr T Arnott, Lloyds Pharmacy stated “This is the first hearing I have attended where the public opinion has to have been 46/5500 evidence. I do think the local council do an admirable job but the panel must look at the legal test and take account of the services in the neighbourhood and adjoining neighbourhood and the effect of granting another contract on existing pharmaceutical services which there has been none to be shown. No complaints have been received by the Health Board. Please refuse this application as it is neither necessary nor desirable for to secure in the neighbourhood the adequate provision of pharmaceutical services”.
12.4 Ms L McElroy, Rowlands Pharmacy stated “I stand by my team and some of them have been there as long as 27 years. I believe they provide excellent pharmaceutical services to every patient who comes through the door. I don’t see a case for inadequacy and I don’t think there is a case for granting this pharmacy application”.
12.5 Mr J Higgins of Green+ Healthcare Limited stated “I would like to thank the chair, the committee, the NHS Highland officers and those representing the interested parties for their time and their attention today.
I believe that despite various protestations to the contrary, inadequate pharmaceutical service has become the norm for residents of my neighbourhood. The idea that the chronically low levels of engagement by the nearest Pharmacies do not mean that these people are being denied the service is a false one as we have shown, not only do we have a less mobile and seriously disadvantaged population but that the failures of service have been sustained and general throughout the wider area and adjacent neighbourhoods.
The neighbourhood is clear and proven by the consultation respondents and others.
There is clear inadequacy of current pharmaceutical service as shown by the Joint Consultation.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P34 There is clear inadequacy as shown from Freedom of Information Request and NHS Highland figures. This inadequacy is not a blip in one pharmacy but has been evident across many contractors over time and by certain measures continues to worsen.
All patients, regardless of any characteristic, their age, their income, education, location, religion or disability have the right to receive high quality pharmaceutical care and we have heard here today how this community feels it is being denied this. We submit that these facts taken together meet and exceed the burden of the legal test and respectfully place our case before the committee.
Thank you all once again”.
13. Private deliberations of the Committee
At the conclusion of the summing up, around 2.45pm, the Chair asked the Applicant, all of the interested parties, observers and Board officials if they would exit the hearing and take a seat in the waiting areas allocated and such time as they had concluded their private deliberations when they would be called back in to the meeting for a point of clarification or advised they were free to leave.
All parties were agreeable and Messrs. Higgins, Ferguson, Arnott, Stewart, Sutherland- Fisher, Green, and the Misses MacRae, Fraser, McElroy, Mackenzie, MacDonald, Beauchamp and Morton departed to the waiting areas as requested.
The meeting then became closed with only members of the Pharmacy Practices Committee remaining.
14. Point of Clarification
At around 3.45pm all parties, including Messrs. Higgins, Ferguson, Arnott, Stewart, Sutherland-Fisher, Green, and the Misses MacRae, Fraser, McElroy, Mackenzie, MacDonald, Beauchamp and Morton were requested to return to the meeting to enable clarification on a point to be raised and discussed openly.
The point clarification was requested on was “when considering the provision of pharmaceutical services does the legal test mean the availability or delivery of service”?
Mr Green referred the Committee to the data available to them and the testimonies provided by the applicant and interested parties today which should be taken into accordance with the legal test in reaching their decision and formulating their reasons for their decision.
The Chair asked all parties present if they were happy that the point had been satisfactorily clarified to which they all replied yes (meaning that they did consider the point had been clarified to their satisfaction). All the above mentioned parties again returned to the waiting areas until such point as they were called back in and advised that a decision had been reached.
Messrs. Higgins, Ferguson, Arnott, Stewart, Sutherland-Fisher, Green, and the Misses MacRae, Fraser, McElroy, Mackenzie, MacDonald, Beauchamp and Morton exited the hearing, returning back to the waiting areas, to enable the Committee to make their decision in private.
At the point where the Committee had reached a decision, they called all the parties back into the room and the Chair asked the Applicant and all of the interested parties if they considered that they had had a fair hearing. They all replied yes (meaning that they did consider they had had a fair hearing).
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P35 The Chair advised a written decision would be sent out within 15 working days. A letter would be included with the decision advising of the appeal process. The Chair then thanked all parties for attending.
15. DECISION Having considered all the evidence presented to it, and their observations from the site visits, the Committee had firstly to decide, the question of the neighbourhood in which the premises to which the application related, were located.
The Committee noted that Rowlands Pharmacy was the only interested party to actually define the boundaries of the neighbourhood and they had agreed with that put forward by the Applicant.
They also referred to the Consultation Analysis Report (CAR) of the joint public consultation undertaken jointly by NHS Highland and the Applicant. This showed that over 95% of the respondents of which over two thirds were resident in the defined neighbourhood agreed that the area highlighted on the map described the neighbourhood.
Although the Community Council representative did not define the boundaries of the neighbourhood in their case they stressed that the area of Dalneigh is a well established and defined neighbourhood in its own right and if someone from Inverness was to ask them as a resident where they lived, then they would know which area of the city Dalneigh was.
The Committee noted that neither John Ross Chemists nor Lloyds Pharmacy had commented on, or disagreed with the boundaries of the proposed neighbourhood as described in the CAR and by the Applicant meaning that no interested party had disputed the neighbourhood.
The Committee took into account a number of factors in defining the neighbourhood including the natural and man-made boundaries, who resides there noting the mixed housing, residential home and sheltered housing complex, neighbourhood statistics, land use and topography, and the distance, means and travel times by which residents have to travel to access existing pharmaceutical services and other services and their own observations from the earlier site visit.
In considering this area the Committee noted that the proposed neighbourhood contained most of the requirements that are required for daily living including a national chain supermarket, several convenience stores, one with a post office, an ATM cash machine a thriving community centre, dental/orthodontic services, veterinary services, a nursery, primary schools, secondary school, churches, large retail outlets, hairdressers, bed and breakfast businesses and sports pitches, play areas and allotments.
The Committee also took into consideration its obligations in terms of the Equality Act 2010:
the need to eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act; advance equality of opportunity between people who share a protected characteristic and those who do not; foster good relations between people who share a protected characteristic and those who do not.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P36 15.1 Neighbourhood: The Committee unanimously agreed that the neighbourhood was the same as indicated by the Applicant and should be defined as follows:
North: The A862 Telford Street from the Muirtown Bridge at the Caledonian Canal along to the Telford Street roundabout of the A82 at Kenneth Street. The Committee considered that this clearly marks the northern boundary as to the north of Telford Street lies the Merkinch area where the local residents would not consider themselves to be within the same neighbourhood as those of Dalneigh.
East: The A82 trunk road from Telford Street roundabout along Kenneth Street, Tomnahurich Street and Glenurquhart Road down to Tomnahurich Bridge at the Caledonian Canal. The Committee was of the opinion that the A82 was a perfect boundary to the neighbourhood not only because it is a busy trunk road but by crossing it then a different neighbourhood is accessed since the residents of Ballifeary, to the east of Glenurquhart Road, would not consider themselves to be living in the same neighbourhood as those of Dalneigh.
South: Where the A82 meets the physical boundary of the Caledonian Canal at Tomnahurich Bridge and the natural boundary of the hill and trees bounded by the fence around Tomnahurich Cemetery. To the south of this lies Torvean Golf Course and the open countryside beyond.
West: The Caledonian Canal which results not only in a man-made physical boundary but marks the edge of a different neighbourhood at the Kinmylies area to the West.
15.2 Adequacy of Existing Provision of Pharmaceutical Services and Necessity or Desirability: Having reached that decision, the Committee was then required to consider the adequacy of pharmaceutical services within that neighbourhood, and whether the granting of the application was necessary or desirable to secure adequate provision of pharmaceutical services in that neighbourhood. Again they considered all the evidence presented to them including the CAR and their observations from the site visits.
The Committee noted that within the neighbourhood as defined there are no community pharmacies and consequently the residents have no choice but to access pharmaceutical services from outwith Dalneigh. There are four pharmacies within the adjacent neighbourhoods on the same side of the River Ness: Rowlands Pharmacy, Grant Street, two Lloyds Pharmacies at Greig Street and Ballifeary Lane and Kinmylies Pharmacy, Charleston Court. There are also another three pharmacies who were invited to make representations to the Committee further away on the other side of the river, Boots, Eastgate and Superdrug, High Street in the City Centre and Boots, Southside Road in the Crown area none of whom requested the opportunity to do so. All of these pharmacies between them provide the NHS core and a range of locally negotiated services to the neighbourhood from outwith. However it was the opinion of the Committee that the direction of travel out of the neighbourhood is not a natural progression to the other pharmacies. Consequently, the Committee recognised that they needed to consider whether an adequate pharmaceutical service was being provided from these pharmacies to the neighbourhood, bearing in mind that residents can choose to access all of the community pharmacies throughout Inverness.
They did note that as described in the CAR that some residents have difficulty accessing services outwith their local area due to transport and distance issues. They also noted as described by the Applicant that the neighbourhood has amongst the lowest levels of car ownership in Highland with over 40% of households having no access to a car or van. Of the vehicles that are available many of these are used for daily commuting and so are not available to householders, stay at home parents, carers and the elderly, who are those most likely to need to access a community pharmacy.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P37 Certainly the lack of private cars was observed during the site visits, as were the bus stops busy with people waiting to catch a bus. Many of the residents are elderly or infirm or have young children meaning that walking to existing pharmacies isn’t feasible. The Community Council representative highlighted that there are no bus services to either Lloyds Pharmacy and no direct service to Kinmylies or Rowlands, and “to make such a journey would result in a considerable time consuming and convoluted journey, essentially making it impractical”. However it was also recognised as described by Lloyds and Rowlands that most community pharmacies in Inverness offer and provide a prescription delivery service to Dalneigh and they had advised that patients are able to speak to a pharmacist on the phone if required.
The Committee agreed with the applicant that a delivery service is useful but it isn’t providing access to most pharmaceutical services. It also isn’t part of the NHS contract but is a private arrangement funded by the pharmacy contractors. This might give easy access to a dispensing service but not the other elements of the pharmacy contract particularly Chronic Medication Service (CMS) patient care records, the Minor Ailment Service (MAS) and the Public Health Service (PHS) notably emergency hormonal contraception and smoking cessation. They noted that Rowlands drivers are trained to Medicines Counter Assistant level but there still isn’t easy access to a pharmacist and pharmaceutical advice or quick access to patient medication records.
The Committee also noted the decision of the PPC from 2013 when it was noted that “the Lloyds Pharmacies in Greig Street and Riverside and Kinmylies Pharmacy were not engaging as well as they might with all four core services of the Scottish Community Pharmacy Contract. While all the services appeared to be available, statistics showed that engagement in some core services was well below the Highland average”.
This lack of engagement with pharmaceutical services was still of concern to the Committee when they referred to 2015 statistics e.g. MAS data for the pharmacies in the adjacent neighbourhoods showed that with the exception of Rowlands in Grant Street the number of patients registered and items dispensed were well below the NHS Highland averages. This would imply that although MAS was available to the patients of the Lloyds Pharmacies and Kinmylies it wasn’t being delivered to the expected number of patients.
The NHS Highland average for patients registered in June 2015 was 583 and number of items dispensed was 109 compared to Lloyds Greig Street 158 and 41, Lloyds Riverside 195 and 56 and Kinmylies Pharmacy 325 and 62 respectively.
The Committee agreed that it was likely that MAS wasn’t being delivered to many Dalneigh patients, many of whom would be entitled to access the service if it wasn’t being well delivered by these pharmacies and it was unlikely that they were accessing MAS further afield in large numbers. It was noted that only 34% of respondents in the CAR agreed that MAS was being adequately delivered to the neighbourhood.
Also of note is the fact that the majority of the population of this area are registered with either Riverside Medical Practice (30%) or Fairfield Medical Practice (24%) demonstrating that most of the residents choose to register with GP practices that are closest to the neighbourhood. Again because there is no medical practice within Dalneigh the residents of the neighbourhood have no choice but to access GP services from outwith. It was assumed that this might have resulted in Dalneigh patients, many of whom are eligible to register for MAS accessing the two Lloyds pharmacies as the closest two pharmacies to these practices for MAS advice. However the low levels of engagement by these two pharmacies with any Inverness patients for MAS would indicate that few patients from Dalneigh are doing so. The CAR reinforces this as only around one third of the respondents thought that MAS was being adequately provided by existing pharmacies in Inverness.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P38 The Committee also noted the below average community pharmacy engagement with smoking cessation services and CMS noting in particular that Lloyds Greig Street had only 10 CMS risk assessments completed despite registering 367 patients for CMS and Kinmylies had only done 3 risk assessments from 111 registrations. Also of concern was the fact that Kinmylies had not undertaken any high risk assessments or new medicine assessments. Lloyds Riverside and Rowlands had undertaken risk assessments but Rowlands had only achieved risk assessments for 241 of their 461 registrations. It was of concern that over two years after the previous application pharmaceutical services though available from other adjacent pharmacies are still not being delivered as expected based upon their dispensing activity and this is evidenced from the statistics provided and by testament received at the oral hearing. The Committee were of the opinion that existing pharmacies are struggling to cope with the core services due to increasing numbers of prescriptions and particularly in Kinmylies case due to new housing developments at Westercraigs, Leachkin Hill and Craig Dunain as observed during the site visit.
The Committee noted the concerns of some of the interested parties about the CAR and the questions asked during the joint consultation and the number of respondents. They were of the opinion that the CAR demonstrated that the applicant and NHS Highland had jointly made every effort to reach the majority of the residents in the neighbourhood by the regulated advertising, local engagement and meetings and on-line and social media coverage.
They acknowledged that some residents had found it difficult to complete the consultation form and this may have contributed to a reduced return but that the questions asked were designed to meet the requirements of the Pharmaceutical Regulations and that the Scottish Health Council had confirmed that the approach taken during the consultation was reasonable.
Although there were only 68 respondents these were considerably more than had been received to previous NHS Highland consultations. There was a strong consensus across all elements of the consultation with the vast majority supporting the location, opening times and range of services proposed.
Three local Highland Councillors had all demonstrated strong support for a community pharmacy in Dalneigh. Around 80% of respondents not only felt that the current provision of pharmacy services was not adequate in the area but also felt that a new pharmacy would help to foster improved joint working across other healthcare providers.
The Committee considered the area profile data provided to them by the NHS Highland Health Intelligence and Knowledge Team to help them understand the population demographics, social environment, economic opportunities and the health and wellbeing of the residents. This data is derived from Small Area Population Estimates, Scottish Neighbourhood Statistics, Scottish Index of Multiple Deprivation 2012 and the 2011 Population Census which are all in the public domain.
From this the Committee noted that the population of the neighbourhood is in the region of 5800 people and just over 20% of them are aged over 65 years. They recognised that not all the households within the neighbourhood are deprived but nearly 75% of the population live in data zones identified as being in the most 40 percent of deprived areas nationally. Within the neighbourhood the most deprived data zone is Dalneigh South West.
The Committee also made reference to the most recent Pharmaceutical Care Services Plan which states that “Community pharmacy smoking cessation services should be extended and pharmacies not presently promoting the service should be enabled and encouraged to do so”.
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P39 This document also describes the HEAT performance measure of targeting those people residing in the 40% most deprived data zones which includes Dalneigh as evidenced above. Consequently the below average engagement in smoking cessation by the existing pharmacies was of concern to the Committee.
There have been no formal complaints directly to NHS Highland about the current pharmaceutical services being provided by the existing pharmacies in the adjacent neighbourhoods.
The Committee, in determining the adequacy of the existing provision of pharmaceutical services in the defined neighbourhood, took account of the evidence provided by the Applicant, and the Interested Parties and made available from other sources including the CAR. They concluded that it was not necessary to grant the application as there is the potential for the existing pharmacies outwith the neighbourhood to provide adequate pharmaceutical services to the neighbourhood.
The Committee then considered whether it would be desirable to grant the application to secure adequate provision of pharmaceutical services in the neighbourhood. Again they took account of all the evidence provided. They concluded that it was desirable to grant the application as access is difficult to the existing pharmacies in the adjacent neighbourhoods due to transport and distance issues, and their engagement with the core services of the Scottish Pharmacy Contract with the exception of Rowlands Pharmacy is below average and hasn’t improved since 2013. This is not likely to change as these pharmacies will be under more pressure as they already dispense a high number of prescriptions and this is increasing year on year. There are currently no pharmaceutical services located in the neighbourhood and collection and delivery services are not providing access to the full range of pharmaceutical services in an area with a significant level of deprivation and an increasingly elderly population. Consequently the Committee was of the opinion that a community pharmacy located within the neighbourhood would be much better placed to deliver the needs of the population.
This not being a controlled locality there was no requirement to consider the prejudice test.
15.3 In accordance with the statutory procedure the Pharmacist Contractor Members of the Committee were excluded from the decision process:
DECIDED/-
The Pharmacy Practices Committee (PPC) was satisfied that the provision of pharmaceutical services at the premises of the Applicant was not necessary, but was desirable in order to secure adequate provision of pharmaceutical services in the neighbourhood in which the premises were located by persons whose names are included in the Pharmaceutical List and in the circumstances, it was the majority decision of the PPC that the application be granted.
The non-voting pharmacists and the Board Officers were then invited back into the room and were advised that the application had been granted and the decision of the Committee was recorded.
The Hearing was then closed.
Elaine Wilkinson as Chair of the PPC
Date: 7 December, 2015
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15.4 Revised Decision
NHS Highland Pharmacy Practices Committee was instructed by the National Appeal Panel to re-sit and consider the matters raised in NAP 49 (2015) and issue a revised decision.
In line with the NAP instruction, all of the original members of PPC attended the re-sit in the Committee Room, John Dewar Building at 9.00 am on Tuesday 17th May, 2016 to reconsider, address the issues highlighted in para 6.5 and 6.10 of the NAP 49 Decision and issue this revised decision.
The PPC revisited the evidence to familiarise themselves again with the case and explored their reasoning. It was agreed that all of the content in the original decision up to page 40, end of paragraph 2 formed part of the revised decision.
The Committee, in determining the adequacy of the existing provision of pharmaceutical services in the defined neighbourhood, took account of the evidence provided by the Applicant, and the Interested Parties and made available from other sources including the CAR.
In accordance with the statutory procedure the Pharmacist Contractor Members of the Committee were excluded from the decision process:
While there were differing views around the table the PPC concluded that provision of pharmaceutical services is inadequate. The reasons for this decision are that there is a lower than average provision of core services e.g. MAS, PHS and CMS from the neighbouring pharmacies, to which there has been little change in the past three years. There is an expectation that in an area with this level of deprivation there is a higher level of need for services and therefore there should be greater provision, as is seen for example from Rowlands Pharmacy, Grant St. The current provision of service was not considered to be sufficient to adequately address inequalities in the neighbourhood in terms of pharmaceutical care.
Also in relation to current adequacy, the PPC considered delivery services. While this is not a contracted service, it provides people with access to their prescribed medicines but can restrict access to core pharmaceutical services unless pharmacies take active steps to engage patients in these services and there was little evidence that this was happening.
The new community pharmacy contract aims to use community pharmacy staff more effectively to reduce the burden on other health services. In order for this to be effective pharmaceutical services have to be promoted, to the public by community pharmacy staff, to increase their use. This is even more important in areas of deprivation but there was limited evidence of a pro-active approach from the existing pharmacies.
There has been a limited increase in uptake of core services over the past three years in neighbouring pharmacies. This suggests there is a lack of capacity to provide these core services. It was noted that the pharmacies at the same time have been able to deal with an increase in prescription volume.
The committee also took the view that there would be an increasing need for pharmaceutical services in the future both within the defined neighbourhood and in surrounding areas. This was for a number of reasons:
1) People are living longer, with multiple conditions and being provided with their care closer to home;
Green + Healthcare Limited Dalneigh PPC Revised Decision 17th May, 2016 Notes.doc P41 2)There has been a considerable increase in prescription numbers over recent years and this is expected to continue although perhaps not quite at the same rate due to polypharmacy reviews and other measures being implemented. 3) The population of Inverness as a whole is expected to increase. There is significant evidence of new house building in the surrounding area. 4)There is some new house building within Dalneigh but the potential for this was considered to be limited due to the physical boundaries of the neighbourhood.
The PPC explored the issue of the impact that a new pharmacy may have on the sustainability of existing pharmacies and other health services. The PPC considered the statistics around the volume of activity per pharmacy over time and concluded that it was unlikely that any adjacent pharmacy would close if this new contract were granted. The PPC also noted that there is opportunity for the existing pharmacies to increase their remuneration by offering more core services.
The population around the Dalneigh area was seen to be increasing and this will be of benefit to the adjacent pharmacies in the future, and possibly to a lesser degree, in Dalneigh, by increasing the number of people requiring pharmaceutical services.
The PPC considered it likely that people from the neighbourhood would use their new pharmacy for the provision of pharmaceutical services, would support the pharmacy into the future and would be unlikely to move elsewhere. This would make it unlikely that the pharmacy, once open, would then close. They did not think granting the application would result in overprovision.
The majority of members of PPC had, at the original hearing, concluded that it was not 15.5 necessary to grant application but it was desirable. As a result of the resit, they have revised this decision to being that it is necessary to grant the application to address the current inadequacy, so they have changed their decision.
This not being a controlled locality there was no requirement to consider the prejudice test.
DECIDED/-
The Pharmacy Practices Committee (PPC) was satisfied that the provision of pharmaceutical services at the premises of the Applicant was necessary to secure adequate provision of pharmaceutical services in the neighbourhood in which the premises were located by persons whose names are included in the Pharmaceutical List, and in the circumstances it was the majority decision of the PPC that the application be granted.
The non-voting pharmacists and the Board Officers were then invited back into the room and were advised that the application had been granted and the revised decision of the Committee was recorded.
The Committee Re-sit was then closed.
Elaine Wilkinson as Chair of the PPC
Date: 17th May, 2016
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