NPA response to DoH Consultation on the Pharmaceutical Services Regulations (Northern Ireland) 1997

27 May 2020

The NPA has identified a number of potential implications of proposals to amend the Pharmaceutical Services Regulations (Northern Ireland) 1997 in response to a pandemic.

The NPA has recently responded to a DoH consultation on proposed amendments to the Pharmaceutical Services Regulations (Northern Ireland) 1997 as part of the response to a pandemic emergency. The proposals introduce provisions within the Regulations to ensure that a home delivery option is in place for eligible patients during a pandemic, and allow for variation in opening hours and suspension of specified terms of service in certain conditions. In our response we have encouraged the Department to ensure that a hierarchy for delivery is adhered to, whereby patients arrange delivery themselves using support from family or carers,  so that delivery by the pharmacy is not the default position. We are concerned that within the proposals there is the suggestion that a pharmacy may consider finding another pharmacy who will deliver medicines to a patient, the first pharmacy having dispensed it. We have asked for additional information to understand the role of the Responsible Pharmacist in each pharmacy. It is unclear where accountability for dispensing and communication with the patient lie, and what patient consent would be needed to operate such a process. We also have concerns about the impact that mandatory delivery services will have on rural members who have much greater distances to travel.

The NPA has welcomed the responsive changes HSCB have made to reducing pharmacy opening hours and amendments to service delivery during the current pandemic which have facilitated pharmacy team’s workload and recovery. We support the ability to be able to act responsively in further pandemics,  and ask that amendments are negotiated with the network and regularly reviewed to ensure a timely response to workload and conditions.