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Report to Steering Group May 2017 Review of Dispensing GP Practices

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Report to Steering Group May 2017 Review of Dispensing GP Practices APPENDIX 3 Report to Steering Group May 2017 Review of Dispensing GP Practices 1. Purpose The purpose of this report is to detail the findings and recommendations of the group instructed to review the current arrangements for dispensing GP practices within NHS Grampian. These findings and recommendations will initially be presented to the Dispensing GP Practices Steering Group before presentation to NHS Grampian Board for further consideration. The review group would like to acknowledge and thank all those who contributed to the formal consultation and/or attended to make representation to the review group itself. 2. Background 2.1 Following the judicial review of dispensing medicines by the Haddo Medical Group completed in 2015, NHS Grampian’s Board accepted the recommendation to conduct a review of general practices providing a dispensing service to patients within Grampian and to ensure patients have access to the most appropriate services to meet their clinical needs. 2.2 The mechanism for Medical Practices to provide dispensing of medicines are set out in the National Health Service (General Medical Services Contracts) (Scotland) regulations 2004, Part 3 Prescribing and Dispensing - paragraph 44 Provision of Dispensing Services. Paragraph 44 allows NHS Boards to require a GP Practice to undertake dispensing for their patients: Where the Health Board is satisfied, after consultation with the area pharmaceutical committee, that a person, by reason of: a) Distance; b) Inadequacy of means of communications; or c) Other exceptional circumstances, will have serious difficulty in obtaining from a pharmacist any drugs; medicines or appliances, other than scheduled drugs, required for that person’s treatment. 2.3 The review is intended to determine which patients of the practices currently providing a dispensing service, will have ‘serious difficulty’ in obtaining any drugs, medicines or appliances, other than scheduled drugs, from a pharmacist required for treatment. Criteria for this review is based on those outlined in paragraph 44(2) of the National Health Service (General Medical Service Contracts) (Scotland) regulations 2014. The review process is based on those patients who are presently registered with practices, and who will be registered in the future. 1 2.4 For the vast majority of patients in NHS Grampian, medicines are prescribed by GPs and dispensed by Community Pharmacists. Where a patient has a serious difficulty in obtaining any drugs, medicines or appliances, other than scheduled drugs from a pharmacist the NHS Board shall require or authorise the patient’s GP to supply the dispensed medicines direct to the patient. Presently NHS Grampian requires or authorises nine GP practices to supply to such patients. In some practices the Board requires or authorises the GP to dispense to all patients, whilst in others the Board has defined a geographical boundary where patients living beyond a set distance from the practice can get their dispensed medicines from their practice. The term serious difficulty is not defined in law or regulation, but the Board can consider distance, the inadequacy of means of communication and other exceptional circumstances. 2.5 The Review was undertaken in relation to the requirements of Paragraph 44 of the GMS regulations. For a patient, who requires any drug, medicine or appliance, not being a Scheduled drug, and where such provision is needed for the immediate treatment of that patient before a provision can otherwise be obtained; this scenario is covered for all practices providing GMS, regardless of dispensing contractor status, under Paragraph 45 of the regulations. This provides a route of access for the patient to treatment that needs to be available immediately directly from the Practice. Therefore, scenarios such as those where a patient is required to begin immediate treatment where the patient is unable to get to a community pharmacy, or it is after the opening hours of a pharmacy, are covered by Paragraph 45 of the regulations and do not form part of this review. 2.6 This review has been triggered by the need to make sure that the Board is continuing to act legally in requiring or authorising these GP Practices to supply to their patients. NHS Grampian is required to assure itself that it is operating within its legal authority i.e. only requiring or authorising GPs to dispense to a person that it has defined as having a serious difficulty in obtaining any drugs, medicines or appliances other than scheduled drugs, required for that person’s treatment. 2.7 The NHS Grampian Board has previously renewed its requirement or authorisation for the practices of Strathdon, Glenlivet and Rinnes at Tomintoul to supply to all of their registered patients living within their agreed practice boundary. In renewing this requirement the Board concluded that all the patients of the aforementioned practices formed a group of patients or class of patients who qualify as having a serious difficulty in obtaining from a pharmacist any drugs, medicines or appliances other than the scheduled drugs required for their treatment by reason of distance from a pharmacy. Each of these practices serve populations that are designated remote and rural (based on the Scottish Government Urban/Rural classifications), are in the lowest deciles for geographical access deprivation, have a travel distance from the practice to the nearest pharmacy of eleven miles or more and have generally poor public transport links. 2.8 NHS Grampian agreed to the proposed review for the remaining six dispensing practices in Grampian. These are Rhynie Medical Practice, Portlethen Medical Centre, Skene Medical Group, Gardenstown Branch Surgery, Udny Station Branch Surgery and Auchenblae Medical Centre. 2 3. Public Consultation 3.1 A public consultation process was undertaken from 4th July until 1st October 2016. Information events took place in communities. Postal feedback forms and email responses were also available. Representatives from groups, organisations, elected public representatives and independent contractors to the NHS such as community pharmacies or medical practices were invited to respond during the public consultation to the question: “If dispensing of medicines was not available at a specific GP practice in this review, do you think that patients who currently get, or are eligible to get, their medicines from these practices will have serious difficulty in getting their dispensed medicines from a community pharmacy?” If the answer was yes, respondents were asked to describe what these difficulties would be and to whom they would apply. As part of the public consultation, six advertised public drop-in sessions took place so that NHS Grampian could engage with all interested parties and to keep them well informed and up to date with the consultation process. This enabled all stakeholders the opportunity to be actively involved in the review. NHS Grampian representation was also present at meetings organised by the Community Councils representing Rhynie and Udny Station residents. Both of these events were very well attended. 3.2 Individual responses to the consultation were collated and thematically analysed by the NHS Grampian Public Involvement Team (available in appendix 1 of this report). From the feedback received it was clear from those who felt they would experience serious difficulty, that this was due to distance from alternative community pharmacies and the time required for this journey. Poor or non-existent public transport was also mentioned with high frequency. Concern was also expressed regarding health conditions, being elderly and/or having mobility problems. 3.3 The public consultation was also open to any organisation, representative or body including local NHS contractors. The consultation included feedback forms for such groups and bodies to comment on the serious difficulty of affected patients, communities and populations. Awareness was raised amongst local contractors with letters to individual GP Practices affected and information about the review and consultation provided in the community pharmacy newsletter to all community pharmacies across Grampian, in addition to the wider efforts to raise awareness through the professional advisory structures and the NHS Grampian website. Local contractors responded through the local consultation in written form and also through the opportunity to make representations directly to the Review Group at public events in each of the practice areas. The Review group had access to and reviewed the response of each of these groups and bodies as part of its deliberations. 3 4. Review Group 4.1 The Review Group was set up to carry out this review, under the direction and guidance of the NHS Grampian Dispensing GP Practices Steering Group and has been provided with details of the consultation responses and key themes provided by individual groups and respondents. 4.2 The remit of the Review Group was to identify those individuals, receiving General Medical Services from Practices, who by reason of distance or inadequacy of means of communication or other exceptional circumstances, will have serious difficulty in obtaining from a pharmacist any drugs, not being scheduled drugs, or appliances required for this treatment in accordance with the National Health Service (General Medical Services Contracts) (Scotland) Regulations 2004 Paragraph 44 of Part 3. 4.3 The Group was also open to presentations from any party, organisation or individual who wished to present their
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