Thank you for giving the National Pharmaceutical Association (NPA) the opportunity to comment on the above consultation. The NPA represents the vast majority of community pharmacy owners in the UK. We have in voluntary membership virtually all pharmacy owners except for Boots the Chemists. The 11,000 pharmacies we represent have always played a key role in promoting, maintaining and improving the health of the communities they serve.
"You are invited to comment on the proposal that ‘standard’ branded generics should be removed from the PPRS and transferred to the new arrangements for the reimbursement of generic medicines."
We fully support this proposal, we believe that it is unfair for the NHS to pay a higher price for ‘standard branded generic products’, which have not incurred significant R&D costs and for which cheaper generic products are available. It is our view that standard branded generic products offer no clinical benefit over ordinary generic products. Further the current arrangements whereby branded generic manufacturers seek to differentiate their products through their pricing structure works against the benefits to the NHS of a competitive generics market. Option 2 in the consultation document would in our opinion be the best way forward, as it meets the needs of the patients and there will be no additional compliance costs.
Department of Health NPA Response – Standard Branded Generic Medicines 14 April 2005 2
Over recent years there has been increased activity where branded generic manufacturers have been approaching primary care organisations (PCOs) with a view to encouraging them towards the prescribing of branded generics. Such activity whilst deemed financially attractive by PCOs in the short term, serve to frustrate nationally agreed ‘reimbursement arrangements’.
Further the prescribing of standard branded generics has caused difficulties for pharmacists in obtaining branded generics in a timely manner to meet patient’s needs, due to a variety of supply issues (eg not stocked routinely by wholesalers, minimum order quantities etc).
Our members’ main consideration is to ensure that they meet their patients’ needs, by ensuring their prescriptions are fulfilled in a timely manner. This ensures acute treatment can be started as soon as possible and/or there is continuity in treatment for chronic conditions. We believe this proposal will further encourage generic prescribing and therefore our members will be able to meet their patients’ needs more efficiently. Ensuring as always patients’ needs remains at the forefront of primary care.
"You are invited to comment on the proposal that the future reimbursement price of ‘standard’ branded generic medicines will be the lesser of either the revised Drug Tariff price of the comparable true generic or the list price of the ‘standard’ branded generic medicine."
We have already mentioned that standard branded generic products offer no clinical benefit over the comparable generic. This being so we cannot see any reason why DoH should acknowledge the existence of standard branded generics by the use of a separate list price. Therefore the transfer of ‘standard’ branded generics from PPRS should lead to their being treated for all purposes as being generic medicines. If this is accepted that the NPA see no need for a separate price list for ‘standard’ branded generics. We would see that the brand originator would be allowed a separate listing. We therefore support the proposal to bring the price of ‘standard’ branded generics into line with the price of the true comparable generic.
Our members have recently accepted a new pharmacy contract. New contract funding is underpinned by a ‘fair return’ principle. We believe that the pricing of standard branded generics should not be considered in isolation, but rather as part of the bigger picture in this remuneration package.
We would like to seek reassurances from the DoH that this proposed switch will not have a significant effect on destabilsing the pricing of generics. There has been an agreed reduction in generic pricing in relation to the negotiation of the new pharmacy contract.
We would like to see a regular review, perhaps at least six-monthly intervals, on how the proposal to remove ‘standard’ branded generics from PPRS will effect the overall pricing of products in the medicines supply chain.
Department of Health NPA Response – Standard Branded Generic Medicines 14 April 2005 3
Further we would urge the DoH to consider the branded generics that are still to be maintained under the PPRS scheme, ie the modified release preparations. There are some modified release preparations where the prescriber need not specify a brand name according to guidance in the BNF. We believe that these preparations could in fact also be removed from PPRS and placed into the new generic reimbursement arrangements.
The reason for including modified release branded generic preparations with PPRS arrangements should be based on robust clinical data. If brand does not make a difference to clinical efficacy in these preparations, then there is no reason why they should remain under PPRS. As always, the main driver should be to ensure that patients do not face undue delay in getting their drugs to continue/start treatment.
14th April 2005
