1. No two schemes are the same and certainly no two LIFTCos are the same.  We are interested to explore, through this consultation, the extent to which the application of this guidance can be tailored to suit the unique circumstances of particular health economies.

We have two main reasons for posing this particular question:

·                     over the coming year, the Department and its delivery arm, Community Health Partnerships plan to introduce a number of changes to LIFT.  These changes are designed to make LIFT and even more flexible product.

·                     at the same time, the Department is considering how to recognise and accredit those PCTs and LIFTCos that are operating effective partnerships, delivering good quality projects that represent real value for money for patients. 

When planning a LIFT project the likely impact on the local community pharmacy network should be considered.

The current network of community pharmacies is an essential element of healthcare provision within the UK. In addition to the core role of dispensing patients prescriptions pharmacists support self care by giving health and lifestyle advice and selling over the counter medicines when appropriate or referring to other healthcare professionals if necessary. Increasingly pharmacists are providing more clinical services from minor ailments and stop smoking services to anti-coagulation monitoring and dosage adjustment of medication with much in between. The recently published White Paper – Pharmacy in England; building on strengths - delivering the future (DH March 2008) sets out the Government’s vision   for the expansion and development of community pharmacy services.

Pharmacies are easily accessible as they are located where people live and work, 99% of the population, even those living in the most deprived areas, can get to a pharmacy within 20 minutes by car and 96% by walking or using public transport. Pharmacies are open at times which suit patients and consumers.  Pharmacists see people when they are well as well as when they are suffering from ill heath and they usually see those suffering from long term conditions and the elderly more frequently than any other health care professional.

Pharmacies are often located near to GP practices and the relocation of one or more GP practices to a LIFT site could seriously affect neighbouring community pharmacies ability to survive and disrupt the local network and therefore the ability of residents to have easy access to a healthcare professional leading to potential health deserts, the effect is likely to be more pronounced in areas of deprivation and could have a negative impact on the health of the population.

Careful consideration should be given as to the exact requirement for pharmaceutical services within the LIFT site; a full dispensing service may not be the most appropriate option. A well designed hub and spoke model of service provision, with neighbourhood pharmacies providing a range of access-critical services could enhance healthcare, especially where existing GP surgeries have moved into the LIFT and the population has further to travel to see a GP.

The NPA is concerned that some LIFT scheme developers view pharmacy as an income stream and not as an equal partner in delivering primary care services to the community.

The NPA is asking PCTs to apply the following principles when planning their primary care estate:



1 Consider the potential for expanding community pharmacy based services to ensure continued or improved, access to services

2 Underpin public consultations with rounded information that explains the full potential impact on services and communities surrounding the health centre, including those not in the direct vicinity

3 Assess those bidding to develop new GP-led health centres with the following considerations relating to community pharmacy:



a. Whether the bidder can describe how the health centre services will integrate with the local community pharmacy network, making the most of neighbourhood outlets to supply access-critical services



b. Whether the bidder can describe how any proposed pharmacy provision within a health centre links to the other services to be located there and aligns to the needs of patients accessing those other services.





c. Can the bidder can give assurances that any pharmacy provision within the health centre will be regarded as a ‘health service’ on equal terms with, for example, general practice, rather than viewed primarily as a third party income generator.



Among the core criteria set out by the Department of Health in procurement specifications is that all GP-led health centres should ‘maximise opportunities to integrate and co-locate with other community based services’. The NPA is concerned that co-location should not be enacted except within the context of a truly integrated vision.

The NPA believes that developments in the health care estate must be carefully managed by PCTs to ensure that they draw out rather than squeeze, even irreparably diminish, community pharmacy’s potential.

Pharmacy services should be developed which provide choice of provider and are accessible to patients, especially if access to a GP is less easy as a result of the LIFT relocating GP surgeries.

2. What criteria do you think could be used to assess whether a partnership between a PCT and its LIFTCo is operating effectively and delivering good quality projects that represent real value for money? How could these be objectively measured?

3. What sorts of benefits/freedoms do you think should be offered to such accredited organisations?

4. How could LIFT be made more flexible whilst still meeting the fundamental principles of ensuring that public money is used properly and that projects demonstrate value for money and are affordable and ensuring that, in relation to existing projects, the procurement rules are not breached?

5. The purpose of Stage 1 is to provide a formal stop/proceed point in the New Project process.  Consequently there is an obvious tension between:

a.       Establishing that the necessary outputs can and will be achieved including genuine value for money; and

b.       ensuring the Stage is reached early enough to mitigate expense on ultimately unsuccessful projects

The best results can only be achieved by setting the right balance between certainty and expediency whilst allowing enough flexibility beyond Stage 1 to permit the addition of value and the reduction of unnecessary cost up until financial close.

We would welcome any comments/suggestions on how the correct balance (as outlined above) can be achieved in every case - including, if appropriate, reference to risk/cost allocation and/or sharing before Stage 1.

1.     Preliminary soundings

The NPA is pleased to note that Local Pharmaceutical Committees (LPCs) have been included in the list of stakeholders who should be consulted when the Stage 1 business case is being prepared. Consulting LPCs should be a necessity when considering the potential impact of a LIFT on the community pharmacy network.

2.     Planning and needs assessments

When considering a LIFT the PCT should ensure that there is an up to date robust Pharmacy Needs Assessment (PNA) and this has been consulted when the SSDP was being developed. This should include an assessment of the need for additional pharmaceutical provision within the LIFT and the nature of this provision.

3.     Local democratic input, not only health provision

Consideration should be given to the affects that the LIFT will have on the local pharmacy network whether or not a pharmacy is to be included in the LIFT. Assessment of this must be democratic and the view of local elected councillors must be heard and the views of the Overview and Scrutiny Committee listened to.

This is important because community pharmacies not only supply some of the health requirements of the population but are a key element, along with post offices, which help maintain the social cohesion of an area. An ICM survey commissioned by the NPA in 2003 revealed that older people and people in social classes D & E are especially likely to see their pharmacist and pharmacy as being  “at the heart of their local community” and in a trusted role as “a family friend”

4.     Design

If a pharmacy is included in the LIFT then the premises need to be fit for purpose, large enough to deliver the services required of it, now and in the future, including at least one consultation area which meets the specifications set out in the pharmacy contractual framework, has access to water and IT links and is large enough to provide services such as flu vaccination. The pharmacy should also be able to have access to consultation areas and meeting rooms elsewhere in the build. One consultation area must be included within the pharmacy so that pharmacists are able to work within professional regulation and ethics.

6. Does the guidance deliver its key objectives as they are detailed at paragraph 6. If not, an explanation as to the reasons why would be helpful in understanding how we may address your points.   

7. Does the formatting, sequencing of chapters, language, use of sections and appendices to provide more detail, make the document reader friendly. If not, an explanation of your views would be helpful.

8. Does the additional detail provided in sections 3.1-3.5 and appendices 1-5  provide added value to the document. If not an explanation as to why not would be helpful.      

9. Are there any others comments you wish to make about the document?

Commissioning routes for pharmaceutical services both within the LIFTCo and the community pharmacy network affected by the LIFT project.

Consideration should be given to the pharmacy services to be provided from the LIFT and those that will need to be commissioned from the other pharmacies in the neighbourhood and affected by the LIFTCo or the relocation of GP practices. Innovative pharmacy services will support the delivery of services relocated from secondary to primary care and provide access critical services in neighbourhoods who’s GPs have been relocated to the LIFTCo.

Thought will also need to be given to the commissioning route for the services to be provided both within the LIFT and the other local pharmacies, as to whether it will be a pharmaceutical services or an LPS contract? If an LPS contract is given to a pharmacy in the LIFT the categories of patients who are to have their prescriptions dispensed at the LIFT pharmacy needs to be considered carefully. Services, including those not traditionally considered to be pharmacy based services could be commissioned, using LPS, from pharmacies which might otherwise be threatened from closure as a result of the LIFT and whose closure, especially in areas of deprivation, would reduce the ability of the local population to access healthcare easily and quickly.

When a PCT’s proposals for a LIFT become public knowledge some companies will lodge applications for 100 pharmacies in the close vicinity of the propose site.  This can have the effect of destabilising the existing community pharmacy network and in areas where there already is an appropriate level of pharmaceutical care unnecessarily increase the costs, in terms of practice payments, to the PCT. To prevent this consideration should be given to making use of Local Pharmaceutical Service (LPS) designation of the area in which the LIFT is to be situated (see LPS Guidance DH March 2008). This will defer any applications for new pharmacy contracts, including those who apply under exemptions, which could further destabilise the existing pharmacy network.