The National Pharmacy Association Response to DoH Duty of Candour Work stream and Being Open Sub Group consultation on Duty of Candour & Being Open Policy Proposals
The NPA welcomes the work on promoting a Duty of Candour among Healthcare Professionals but are concerned about proposals to introduce a statutory individual duty of candour which would mean that pharmacists would be managed differently in Northern Ireland in comparison to elsewhere in Great Britain.
The NPA has responded to the DoH Consultation on proposals to introduce a Duty of Candour and Being Open on behalf of members. Duty of Candour is inherent to a safe and effective healthcare system. We have pushed back on the introduction of a statutory individual duty of candour and have responded that would cause unnecessary duplication of existing professional requirements. Implementation of this proposal would also mean that pharmacists would be treated differently in managing their duty of candour obligations than professionals elsewhere in Great Britain.
We recognise the benefits of an organisational statutory duty of candour to promote greater openness amongst all staff which would benefit patients. It is important that the Being Open Framework will implemented in such a way as to enable staff to feel able to speak up for patient safety without risking any opposition or intimidation from their peers or other stakeholders.
NPA supportive of temporary authorisation of the supply of unlicensed products in interest of public health
The Department of Health and Social Care (DHSE) alongside the Medicines and Healthcare products Regulatory Agency (MHRA) recently published the outcome of a consultation on changes to the Human Medicines Regulations to support the rollout of COVID-19 vaccines.
The NPA, which responded to the consultation, said it is supportive of the proposal by the Joint Committee on Vaccination and Immunisation (JCVI) on advising the government to use a tested but unlicensed vaccine against Covid-19 in the interest of public health.
Helga Mangion, Policy Manager at the NPA said: “We are pleased with the reassurance from DHSE and MHRA of their commitment to robust scrutiny, objectivity and safety.
“In our submission we reiterated the need for their objectives to be reviewed on a regular basis in line with new research and pandemic progression.
“We foresee community pharmacies will also have a crucial role to play in ensuring as many people as possible get protected by any future coronavirus vaccine.
“Provided the appropriate safety, quality and efficacy measures have been put in place, the NPA is supportive of the deployment of effective and legal mechanisms for bringing this pandemic under control.”
The consultation which ran from 28 August to 18 September concluded that there will be three key changes to the proposals set out in the original consultation document, including; robust scrutiny of the impact of regulation 174A (which is the new power to impose conditions and dealing with their consequences); promoting objectivity by changing the ‘objective bystander’ test that relates to loss of immunity from civil liability; and creating an additional level of reassurance in relation to the expanded workforce.…
NPA response to DoH Consultation on the Pharmaceutical Services Regulations (Northern Ireland) 1997
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.
Local is “where the magic happens” says NPA, as pharmacy representation review enters new phase
The National Pharmacy Association is recommending continued investment in local leadership and better accountability across the system, in light of a survey issued today (29 January) on behalf of PSNC and Local Pharmaceutical Committees.
In a statement published today, the NPA also emphasises the importance of equitable governance, to ensure that the voices both of independents and multiples are fairly represented in local and national leadership.
A key passage in the NPA statement reads:
“Local is where the magic happens; it’s where ideas are conceived, innovation is sewn and patient care is delivered. Local capacity for effective support and representation is especially important in the light of the funding that now exists (£4.6 billion) for primary care via Primary Care Networks.
The NPA highlights that the NHS has begun to move decisively in the direction of commissioning for population health needs at a local level. It follows that any monies released from LPCs consolidating should be reinvested to support local activity. This includes investing in a programme of support for the newly selected 1,259 Pharmacy Primary Care Network Leads, says the NPA.
At the same time, PSNC’s core role of negotiating the national contractual framework must be adequately resourced, as a crucial part of a coherent, end-to-end system of representation and support.
The NPA statement continues:
“There should be clear KPIs and lines of accountability throughout the system. Approximately £11.3 million of contractors’ money is spent annually by LPCs and PSNC.…
Members are invited for their thoughts and comments to the Prevention Green paper
Joint statement on HMRC IR35 off-payroll working rules consultation: Community pharmacy sector concerned about new tax proposals
The NPA, alongside the Company Chemists’ Association (CCA), the Association of Independent Multiple Pharmacies (AIM), the Royal Pharmaceutical Society (RPS), Team Locum and Locate a Locum have issued a joint response to an HMRC consultation highlighting our concerns about how proposed changes to tax law might impact the sector.
HMRC consulted on their proposals for implementing changes to tax law known as IR35, or “off-payroll” working rules, between 5 March to 28 May 2019.
From April 2020, medium and large businesses (companies employing more than 50 people) will become responsible for assigning the tax status of locums contracted through their own limited company, to reflect the correct employment status position.
However, there are other changes taking place with HMRC conducting a wider review of the use of self-employed locums which could affect a larger proportion of the sector than the IR35 reforms.
Our response to the off-payroll consultation identified that:
HMRC need to ensure that the Check Employment Status for Tax tool (CEST), which is being promoted by them as the means of determining tax status, is fit for purpose. We believe that this tool is not refined enough to meet the needs of the community pharmacy sector. Those using the tool need to be confident that it’s accurate and fair in all cases
We have significant concerns that, following these reforms, the flexibility of the pharmacy workforce may be affected to the extent that it disrupts the necessary supply of medicines and services to patients
The IR35 reforms are complex changes which will be difficult to embed across the diverse populations of workers that exist across the private sector.…
NPA response to Scottish Affairs Committee Inquiry on Use and Misuse of Drugs in Scotland
As submitted last month, April 2019.
The NPA response to the Scottish Affairs Committee inquiry into drug use and misuse in Scotland last month (April 2019) provided evidence that Scottish members as independent community pharmacy owners and their teams are integral to the support and treatment of drug users in Scotland. The NPA response urged the Scottish Affairs Committee to liaise closely with representative bodies for community pharmacy and in particular the Scottish community pharmacy negotiating organisation, Community Pharmacy Scotland, if any reserved area of policy that may involve community pharmacy is being scoped.
Read the NPA response here.
We would be happy to discuss the points raised in this response with the Scottish Affairs Committee in more detail. To arrange this, please contact Janice Oman NPA Scotland Representation Manager at email@example.com…
NPA response to leaked Brexit consultation
The NPA has responded following the leak of a Department of Health and Social Care (DHSC) consultation on maintaining medicines supply in the event of a no-deal Brexit.
A spokesman said: “We are pleased that the government is now looking at a range of options for maintaining a prompt medicines supply service in the event of a no-deal Brexit.
“The Government has listened to us and they are now consulting on legislative provisions to allow pharmacists certain flexibilities to make supplies under protocol.
“The NPA has been invited to comment on the proposals set out by the DHSC. We are currently in the process of preparing our detailed response.
“Government has asked manufacturers to ensure they have a minimum six weeks’ additional supply in the UK as buffer stock in case the UK leaves the EU next March with no-deal and without a transitional agreement. By itself, this is an insufficient contingency to deal with the potential disruption that might occur.
“Therefore we welcome the current consultation on contingency measures giving pharmacists the opportunity to use their clinical judgment to meet patient demand.
“This includes substituting medicines in short supply for other medicines without the need for referral back to a GP. This is a relatively straightforward contingency in the event of no-deal.
“We continue to be in close contact with Government and regulators about preparations for Brexit.”…
You may have seen the leaks were widely reported by the media today.
Review of the funding model in Scotland for Community Pharmacist Supplementary and Independent Prescribing Clinics
In early October the NPA responded at very short notice to the Scottish Government Survey on the funding model for community pharmacy prescribing clinics.
The NPA called for a new funding model to provide sustainable clinics by including set up, service promotion, pharmacist back fill and administrative time over an adequate period to enable service development.
Please tell us what would enable you to provide/contract an independent or supplementary prescribing service
The National Pharmacy Association Ltd representing our members as independent community pharmacy owners suggest the following criteria is required to enable an independent or supplementary prescribing service to be provided by a community pharmacist
Sustainable funding model which enables pharmacist backfill to be arranged and paid fully for each clinic session. This funding should be confirmed at least six months in advance and rolling year to year to enable service development and continuity. The funding should not be dependent on the number of patients seen, as pharmacist clinics in practice often see those patients who frequently “do not attend” surgery appointments. There should be allotted funding to enable the NHS Board to support the setup of any pharmacist clinic as to standard operating procedures, risk assessment, indemnity costs etc. Funding should also account for pharmacist time in reviewing and updating patient notes. This time can be considerable especially if the clinic situation provides no timely access to medical notes.…
NPA rejects remote supervision proposals
The NPA has confirmed it is against the remote supervision of pharmacies in almost all circumstances.
Responding to the Department of Health and Social Care’s Rebalancing Medicines Legislation and Pharmacy Regulation consultation the NPA said the practice could compromise patient safety.
Challenging proposals to allow the regulator to make exceptions, the NPA said it was unclear whether these would in fact be routine rather than genuinely exceptional circumstances, like major incidents.
Helga Mangion, NPA policy manager, said: “Responsibility and accountability for the safe supply of medicines should remain with the responsible pharmacist.
“Standard operating procedures and systems only go so far. In many situations there is no substitute for the professional and clinical judgment of the pharmacist on the spot.
“Therefore, there should be a pharmacist present in every community pharmacy throughout the opening hours.”
The NPA said this was compatible with the full use of the pharmacists and technicians’ skills and did not impede the deployment of modern technologies.
In addition, the NPA said it is eager to engage further on this topic and recognises that pharmacy teams must be enabled to support the community pharmacist to deliver more clinical services.
The NPA’s response states: “Regulations relating to supervision and the role of the responsible pharmacist together must permit the profession to move on and deliver services efficiently.…