Get to grips with the new Community Pharmacy Contractual Framework in England (CPCF)

NPA members in England should familiarise themselves with the new community pharmacy framework after PSNC, the Department of Health and Social Care and NHS England announced a new five-year deal. The funding settlement is for £2,592bn per year (almost £13bn over the five years).

PSNC has stated that from this October, there will be some immediate structural changes to funding including the phasing out of MURs and the Establishment Payment, with these monies being reinvested into the sector.

 

Other changes, listed on the PSNC website, include:

• Contractors will receive monthly transitional payments in the

second half of 2019/20 and again in 2020/21 in recognition of

costs associated with changes such as integration into Primary

Care Networks, preparation for Serious Shortage Protocols and

implementation of the Falsifi ed Medicines Directive.

• Contractors can earn payments for meeting quality targets under

the renamed Pharmacy Quality Scheme (formerly the Quality

Payments Scheme). The new scheme has a review point in

February 2020 and several revisions to the previous criteria.

• A new national NHS Community Pharmacist Consultation Service

is being commissioned from this autumn, which will bring

together the national NUMSAS and local DMIRS pilots into one

national service.

• An increasing use of technology and other enablers will seek to

make the dispensing process as effi cient as practicable.

• Other elements of the deal include the continuation of the

Pharmacy Access Scheme (PhAS) and the use of the Pharmacy

Integration Fund to fund pilot services which may, if successful, be

commissioned nationally from pharmacies.

 

10 things you can do right now to prepare for changes

to the pharmacy contract in England.

1. Read the information supplied by PSNC on its website (www.

psnc.org.uk) and the NPA’s initial reaction (see p44). Pharmacy

owners are advised to watch PSNC’s webinar for community

pharmacy contractors to understand the fi ve-year CPCF.

 

2. Familiarise yourself with the new Community Pharmacist

Consultation Scheme. The NPA has produced a webinar titled

‘NHS Community Pharmacist Consultation Service: a golden

opportunity for your pharmacy?’ Go to www.npa.co.uk/newsand-

events/past-events/

 

3. Gen up on the clinical knowledge you will need to deliver the

range of services now in the NHS service development pipeline,

and record this as CPD. Consider refreshing your knowledge on

minor illnesses and Hep C testing. You can access the NPA’s CPD

hub at www.npa.co.uk/training/cpd

 

4. Make sure you are, or are on track to become a Healthy Living

Pharmacy. It will be a requirement by the Terms of Service to

have attained HLP Level 1 status by April 2020. NPA training can

be accessed here: www.npa.co.uk/learning-and-development

 

5. In light of the fact that there will be no more new money for

dispensing volume, think again about how you can either

cut costs or work smarter and effi ciently in your business

and consider the skill mix in your pharmacy. There are lots of

practical tips in the Spring edition of InPharmacy magazine.

 

6. Take stock of where you are financially. Watch our webinar on

fi nancial advice and consider speaking to our business partners

by going to www.npa.co.uk/services-and-support/businesssupport/.

Watch the NPA’s webinars on Understanding the

Global Sum and Understanding Your Finances and Distribution

of Margins so that you can better assess the impact on your cash

flow. Go to www.npa.co.uk/news-and-events/past-events/

 

7. Start thinking about your engagement with Primary Care

Networks, liaising with your LPC. Take a look at this blog from

some intrepid NPA members already beginning their own PCN

journey and follow them over the months ahead to learn from

their progress. Go to www.npa.co.uk/2019/07/24/were-taking-aprimary-

care-network-journey-want-to-come-along/

 

8. Build your local connectivity by speaking to your LPC’s

independent representative and team and work to develop

positive relationships with GP.

 

9. Let us know your thoughts on plans to change pharmacy

reimbursement systems. The current DHSC consultation seeks

to deliver a fairer share of margin, but some changes may

have unintended consequences. Have your say at

independentsvoice@npa.co.uk

 

10. Review the new Pharmacy Quality scheme criteria for the second

half of the fi nancial year. Start thinking about how you can meet

them – NPA resources to support you will be available soon.

 

Five year deal on the Community Pharmacy Contractual Framework

PSNC, the Department of Health and Social Care and NHS England have announced a five-year deal for community pharmacy, from October 2019 through to 2023/24.

It includes what PSNC calls “a clear vision for new pharmacy services” including a NHS Community Pharmacist Consultation Service being introduced later this year.

The funding settlement is for £2,592bn per year (almost £13bn over the five years). There is also a commitment to achieve “smoother cash fl ow and fairer distribution of margin”.

Mark Lyonette, chief executive at the NPA, said: “We strongly support the emphasis on clinical services and the recognition that pharmacies can play a signifi cantly greater role in urgent care and public health.

“What’s more, the five-year term of this settlement gives us the long view we asked for. But static funding year on year means

it will be very difficult to deliver the transformational improvements we all want to see. We know that many of our members are not breaking even, let alone in a position to invest in new services that would greatly benefi t patients and the NHS.

"The government must be prepared to direct more money into community pharmacy, to avoid uncontrolled closures, or if it becomes clear that funding is insuffi cient to maintain current core services and invest in positive new developments like the Community Pharmacist Consultation Service.

“We note the proposed annual review each October. To ensure the service levelsn required for patients, we suspect the £2.59bn needs to be a fl oor not a ceiling.”

The NPA will seek meetings with DHSC and NHS England to advocate for more progress on areas not dealt with during the current round of negotiations. This includes thorough reform of the concessionary price system to ensure that pharmacies are not dispensing at a loss. We also want a guarantee of full, accurate and timely drug reimbursement and payment of fees.

 

National framework to improve public health

The National Pharmacy Association has helped bring about the first ever “high-level, system-wide commitment” in England to improving quality in all

areas of public health.

The Public Health System Group, which includes a wide range of key partners across health, local and national Government, worked together to set out the framework.

The group includes the NPA, alongside others such as the National Institute for Health and Care Excellence (NICE), Care Quality Commission and the Health Foundation.

Helga Mangion, policy manager at the NPA, said: “As providers of public health services community pharmacists and their teams now have a framework that outlines and measures what quality in public health means.

“Pharmacies are disproportionately located in deprived areas – a rare exception to the so-called inverse care law under which people with the highest needs have the least access to advice and treatment.

“With growing challenges facing the health and care system, maintaining a focus on quality in public health is more important than ever in order to improve health outcomes and reduce health inequalities.”

The six key principles and actions which the Public Health System Group have agreed upon include the following:

 

1. Developing a system-wide focus

on prevention

• Ensuring that prevention is prioritised with

focus on strengthening communities.

• Ensuring individuals and communities are

empowered to manage their physical and

mental health and wellbeing.

 

2. Reducing health inequalities

• Ensuring the reduction of inequalities in

health outcomes.

• Ensuring equity of access and usage on

all services as well as providing targeted

services where needed (proportionate

universalism).

 

3. Embedding health in policy

• Promoting and advocating with

others action to infl uence the wider

determinants of public health.

• Assessing policies to evaluate impact.

• Identifying opportunities for cross sector

policy making.

 

4. Evidence and needs-based public

health

• Supporting the gathering, generation and

dissemination of evidence on what works.

• Listening to stakeholders’ needs and

wishes before making decisions.

 

5. Developing strong systems

leadership

• Ensuring mutual accountability and

system wide assurance

• Mobilising community assets and the

wider public health workforce

• Continually learning.

 

6. Responsibility to future

generations

• Taking due consideration on present

day decisions and how they will impact

on the health and wellbeing of future

generations.

• Support the delivery of UN Sustainable

Development Goals.

For more information email

independentsvoice@npa.co.uk

 

A recent review of the NPA’s

current purchasing model

has given members a more

streamlined process for

purchasing their pharmacy

consumables

As a result of the review, the NPA is

pleased to announce a new partnership

with EMT Healthcare, a family-owned

and operated business which has been

serving community pharmacies since

1963 and is aligned with the NPA and its

values.

Simon Tebbutt, head of relationship

management, said: “We’ve consolidated our

purchasing to make it better for members

and we’re working with EMT so we can

lower prices and reduce costs, offering a

wider range at the same time.”

The partnership includes an arrangement

whereby EMT still stock and review their

ranges with the NPA on a quarterly basis to

meet members’ needs.

Simon said that members can expect

to save an average of 15% on print stock

items previously available on the NPA

sales website. The current model used by

members and customers allows them to

purchase products from both the NPA and

EMT Healthcare.

“There are some things we sell that EMT

don’t and vice versa,” explained Simon.

“Currently things we sell include items

like CD inserts, stickers, and destruction kits.

Customers order from us but the products

are physically held by EMT Healthcare who

dispatch them to us.

“But now, rather than ordering through

us, customers can order everything from

EMT Healthcare which means we cut off an

extra step in the buying process.”

Simon added: “It’s a new way of buying

pharmacy essentials from a trusted partner

which creates price reductions and more

effi ciency. We’re always looking at ways

for members to get extra value out of their

membership.”

Rod Muir, managing mirector of EMT

Healthcare, said: “EMT welcomes this new

dimension to our important partnership

with the NPA. We strongly believe this is a

mutually benefi cial strategy will streamline

the service going forward. EMT has long

been associated with helping pharmacy

save money, so marrying our ability to do

just that with today’s pressure to reduce

costs wherever possible puts us in a strong

position to help. The cost savings are real.”

When pharmacy teams go to npasales.

co.uk to order items they will be directed to

www.emthealthcare.co.uk

 

Licensed brand of

melatonin oral solution –

dispensing advice

Pharmacy teams who dispense NHS prescriptions for

melatonin oral solution should be aware that a licensed brand

has been marketed by Colonis Pharma Ltd from June 2019 as

melatonin oral solution 1mg/ml. The product is a sugar-free

preparation and its only licensed indication is “short-term

treatment of jet-lag in adults”.

Colonis Pharma has confi rmed the licensed product is available to

order through mainline wholesalers Alliance Healthcare, Pheonix,

AAH and some short-line wholesalers including Mawdsley Brooks &

Co Ltd.

The NPA is receiving an increasing number of calls from pharmacy

teams querying reimbursement following advice from specials

suppliers that they should obtain the licensed brand of melatonin

oral solution to dispense against prescriptions calling for melatonin

oral solution 5mg/5ml.

NHS Business Services Authority, Business Services Organisation/

Community Pharmacy Scotland/Community Pharmacy Wales have

confi rmed the following information regarding reimbursement:

Pharmacy contractors will not be reimbursed for dispensing the

licensed brand of melatonin oral solution against prescriptions

calling for the unlicensed version.

In addition, pharmacists must dispense in accordance with the prescriber’s

instructions and therefore must not make substitutions without contacting the

prescriber and having the prescription amended as appropriate.

The Medicines and Healthcare products Regulatory Agency

(MHRA) has issued guidance on supply of unlicensed medicinal

product ‘specials.’

This states: “Although MHRA does not recommend ‘off-label’ (outside the licensed indications)

use of products, if a UK licensed product can meet the clinical need, even

off-label, it should be used instead of an unlicensed product.”

On that basis, pharmacy contractors who receive a prescription for

an unlicensed melatonin oral solution in any strength should take

the following action:

 

• Contact the prescriber to advise that a licensed product is now

available and even if it is being used for an off-licence indication,

it should be prescribed in preference to the unlicensed version

• If the prescriber agrees with the advice;

1. Have the prescription amended to state “melatonin 1mg/ml

oral solution sugar-free.”

2. Document the details of the discussion on the PMR.

• If the prescriber does not agree with the advice and wishes the

patient to have the unlicensed version;

1. Confirm that the prescriber is aware it is unlicensed.

2. Document the details of the discussion on the PMR.

 

For further information, please contact the NPA

pharmacy services team on 01727 891 800 or email

pharmacyservices@npa.co.uk

 

 

Employee claims rise for

the second year running

The latest round of Employment Tribunal

statistics has now been released – giving

employers a full year picture to compare

against the year prior.

Broadly speaking, the findings are as

expected, with the overall claims trajectory

continuing in much the same way as it has

been since Tribunal fees were abolished

back in 2017. These latest statistics serve

to remind employers of the importance

of taking proactive steps to minimise the

risk of claims. The stats relate to the whole

UK economy, not specifically community

pharmacy.

 

Volume of claims

The bottom line is that Employment Tribunal

claims are up 26 per cent year on year:

• There were 27,916 single claim receipts

lodged between April 2017 to March 2018.

• There were 35,429 single claim receipts

lodged between April 2018 to March 2019.

The Supreme Court scrapped Employment

Tribunal fees back in 2017.

 

Types of claims

Sex discrimination has seen the biggest rise

in claim numbers, from 5,522 in FY18 to

9,336 in FY19 – an increase of 69 per cent.

At fi rst glance, this seems to suggest that

the #MeToo movement may have gained real

traction. However this fi gure is skewed by

the receipt of over 2,700 sex discrimination

claims in the Scottish Tribunal in August

2018. Take that out and sex discrimination

claims are actually up 20 per cent.

Other claims which have risen include:

• Breach of contract, up 15.07 per cent.

• Race discrimination, up 17.75 per cent.

• Unfair dismissal, up 19.97per cent.

• Disability discrimination, up 24.54 per cent.

• Redundancy (failure to inform and

consult), up 35.76 per cent.

 

Claims for age discrimination, equal pay

and part-time workers regulations are down.

 

Where we’re headed

There’s no sign of the number of claims

slowing down and no indication this will

change any time soon. Fees were introduced

in July 2013, and in the 12 months prior to

this, 53,487 single claims were received. This

means there’s still potential for a further 50

per cent increase in claim numbers if we’re

headed back to the kinds of claim levels we

saw in the original pre-fee era.

 

For trusted legal advice on any

employment matter, contact

the NPA Employment Advisory

Service on 0330 123 0558 or email

employmentadvice@npa.co.uk

 

 

NPA launches ePGDs

An ePGD is an electronic, user-friendly alternative to paper

consent forms, which has a substantial number of inbuilt

safeguards that are impossible to implement in a paper

format. It is quicker and easier to complete than paper and

removes the need for expensive long-term storage of paper

records.

The NPA has partnered up with Medical Prescription Services

(MPS) for the provision of the PGD and certifi cate once the training

has been completed.

 

What are the benefits?

• Enhanced patient safety – ePGD has integral secure features and

alerts which make it safer to offer PGD services. Pre-screening

applications are automatically displayed as Passes or Failed and

further tailored advice is generated.

• It can save a pharmacist time and money as ePGD reduces a

typical consultation from 20 minutes to less than fi ve minutes.

Patients are also able to complete their applications from home or

work at a time that suits them, before attending a consultation,

saving even more time.

• Clear and easy-to-follow patient journey which prevents patients

from moving forward until they have read all the relevant

information.

• In line with best practice, a GP letter is generated which can be

printed and given to the patient.

• Free, secure electronic data storage removes the need for

expensive, long-term paper document storage. Paper copies are

not required as the system can be accessed at any time and data

retrieved.

• Electronic archiving and reporting makes robust governance quick

and simple.

• Free internet presence and enhanced accessibility to patients

and customers – the service has a free “Pharmacy Finder” which

is used to link patients searching for services to participating

pharmacies.

• Quick, safe, clinically robust, as well as creating a full audit trail.

 

How can I get an ePGD?

You will be asked to select your preference for the format of

your PGD(s) as part of the online enrolment process for our PGD

packages and training. If you select the ‘ePGD and Paper’ option,

there are a few more questions to enable you to be registered for

the ePGD facility.

 

I’ve already bought my 2019 PGD packages and

training - can I still get an ePGD?

Yes, you are still entitled to a free upgrade to an ePGD for each of

the packages you have bought. Our Member Services team will be

in touch with you shortly to advise how to claim your free upgrade.

Read the free upgrade process here.

If you have any questions regarding PGD training and packages,

please email pgd@npa.co.uk

 

Launch of NPA Community Pharmacy

Hypertension Detection SOP (NI)

The NPA has published a new standard operating procedure

(SOP) to help participating pharmacies to prepare for

provision of the Community Pharmacy Hypertension

Detection service in Northern Ireland.

The service aims to detect undiagnosed hypertension in patients

aged over 45 years and will run for 6 months.

The NPA welcomes the announcement from the South Eastern

Integrated Care Partnership, in conjunction with the Health and

Social Care Board (HSCB) and Community Pharmacy NI (CPNI), that

the Community Pharmacy Hypertension Detection Service will be

available through participating pharmacies in the South Eastern area

from July 2019.

Pharmacists should ensure that they submit their training and set

up a claim after five patients have been reviewed in the service.

 

For further information on this or any other query, please

contact the NPA Pharmacy Services team on 01727 891 800 or

email pharmacyservices@npa.co.uk

 

 

Common dispensing errors resulting in

indemnity claims (UK)

Example 1: dispensing patient returns

A significant claim has arisen from an error involving patientreturned

vials of heparin which were accidently re-dispensed to

a pregnant patient. The patient had administered a few doses of

heparin before realising that the vials had been used before, and

alerted the pharmacy. The pharmacy accepted that the heparin vials

were patient-returned medicines which had been accidently redispensed.

Once the patient realised the error, she was treated with

preventive medication against the potential risk of infections such as

HIV and hepatitis B. The patient went on to give birth to a healthy

baby. However, the experience allegedly resulted in a signifi cant

ongoing psychological impact on the patient, both during her

remaining pregnancy and after.

A key element which resulted in this error was the failure to

segregate and store patient-returned medicines appropriately, and

a potential failure in implementing the patient-returned medicines

standard operating procedure (SOP) in the pharmacy.

 

The NPA advises that superintendents should:

• Ensure that all pharmacy team members, including locums,

are fully aware of the patient-returned medicines SOP and are

implementing it.

• Ensure that all waste medicines, patient-returned or expired

pharmacy stock, are properly segregated and not left lying around

in the pharmacy dispensing area.

• Ensure that the dispensing SOP is in place and being followed

– in this incident, it is not clear if the fi nal accuracy check was

conducted properly or not, and who was responsible for the

accuracy check.

• Use the NPA template essential SOPs for to help you to review and

update your pharmacy SOPs if required.

Example 2: MDS errors where medication were given

to the wrong patient.

1. A prepared MDS was incorrectly dispensed to the wrong patient.

It contained anti-diabetic medicines but the patient it was given

to, did not have diabetes. The patient’s solicitors alleged the

patient, who lived alone, took the medicines from the incorrect

MDS and collapsed, before being found by a carer. The patient

was admitted to the hospital and his solicitors allege he has been

left with a signifi cant cognitive brain injury. One of the issues

identifi ed has been the advance preparation of this MDS being

stored in a stack with all other prepared trays on a shelf with the

wrong tray selected to hand out to the patient.

2. Another claim has resulted because a prepared MDS tray was

allegedly given to the wrong patient. This incident also involved

anti-diabetic medicines which were allegedly taken by the patient

who did not have diabetes. Following a prolonged period of

serious illness in the hospital, the patient died. Despite questions

over causation issues, this has resulted in a claim against the

pharmacy.

3. Yet another claim involving MDS came about because a patient

was administered medicines from the wrong MDS tray by a care

company without making the proper checks. However, the care

company is also asserting that the pharmacy supplied them with

the wrong MDS tray which resulted in their error and are seeking

to recover their outlay to the patient.

The MDS claims may have arisen because the MDS trays had been

prepared in advance, stored in a stack on a shelf, and potentially

proper processes not followed at the time of handing it over to

the patient to ensure that the right tray was being given to the

right patient. In the case of the care company, such organisations

also have a duty of care and must be able to demonstrate that

they have the right training and processes in place for their staff

for managing medicines in care settings and administering them

to patients.

 

LASA errors

Of the claims resulting from look-alike-sound-alike (LASA) errors,

the most common errors currently resulting in claims involve the

following two drug pairs:

• Amlodipine / amitriptyline

• Risperidone / ropinirole.

 

For further information please contact the NPA

Pharmacy Services team on 01727 891800 or email at:

pharmacyservices@npa.co.uk

 

 

Superintendent update on

CBD-containing products

Following discussions with the

Medicines and Healthcare products

Regulatory Agency (MHRA) and the

Home Offi ce (HO), we clarify the

situation surrounding CBD-containing

products and the controls to which

these products are subjected.

If a product contains any amount (even

trace amounts) of controlled cannabinoids

— such as tetrahydrocannabinol (THC),

even unintentionally — it will be subject

to controls as it would be classifi ed as a

Schedule 1 Controlled Drug (CD) under The

Misuse of Drugs Regulations (MDR) 2001.

Products containing controlled

cannabinoids are only lawfully available

for human consumption if the product is

classified as one of the following:

 

1. Cannabis-based product for medicinal

use in humans (CBPM). Currently, CBPM

are only available on prescription from a

specialist doctor. As per the defi nition of

cannabis-based products for medicinal

use in humans (CBPM), they would be

classifi ed as Schedule 2 CDs, with the

exception of Sativex which is a licensed

product as a Schedule 4 (Part 1) CD.

 

2. An exempted product under Regulation 2

of the MDR 2001. The HO has confi rmed

to the NPA that food supplements

containing any amount of controlled

cannabinoids cannot be classifi ed as

exempted products.

The HO has stated that cannabidiol (CBD),

when isolated and in a pure form, is not

subject to controls under The Misuse of

Drugs Act 1971 or MDR 2001. However, it is

very diffi cult to isolate CBD in its pure form

and the HO has raised concerns that many

CBD-containing products (such as those

being sold as food supplements) do not

disclose information on their full contents

that is required to determine the control

status of the product.

The HO has therefore advised caution

based on the following presumption

“that a CBD containing product would be

controlled under the MDA 1971 / MDR

2001 as a result of its other cannabinoid

content”. Furthermore, a Certificate of

Analysis stating the content of controlled

cannabinoids within the product should be

obtained from the manufacturer before a

CBD product is sold or supplied.

 

• If a product is found to contain any

amount of controlled cannabinoids (for

example, THC), the product must not be

sold as it would be classifi ed as a Schedule

1 CD and such a sale would be illegal.

• The HO should also be alerted.

 

Professional indemnity

NPA Insurance has issued the following

statement regarding NPA members selling/

supplying cannabis oil and CBD-containing

products, including those licensed as

medicinal products or classed as food

supplements:

“Members who are considering selling

or supplying cannabis, cannabis-based

products for medicinal use, cannabis oil

products, or any CBD products or derivatives

must ensure that they ascertain before

doing so the status of such products, and

whether they require a product licence

(marketing authorisation), or otherwise.

“Failure to do so (and to be able to

satisfy this requirement to NPA Insurance),

will mean that in the event that a third

party claim is made against the member’s

professional indemnity policy, or a

request is made by the member for legal

defence or representation to respond to a

Regulatory or Criminal investigation, that

indemnity, legal defence or expenses cover

may not be provided.

“If in any doubt, members are urged to

contact the NPA Pharmacy Services team for

advice in relation to selling or supplying of

any cannabis product, or the NPAI team in

respect of matters of policy cover.

“In terms of the indemnity, this will

be breached where the sale/supply of

the product is illegal both under UK and

EU law, or the product is being supplied

for an unlicensed use, or the necessary

permissions/authority to sell/supply the

product have not been obtained.