We welcome the general themes of this framework, including greater focus on preventing ill health and greater choice for patients in how they receive their health care. People visit community pharmacies as part of their everyday life, so the community pharmacy is ideally suited to deliver on the prevention agenda. Developments such as independent prescribing and ‘pharmacist with a special interest’ will allow pharmacists to deliver more clinical services, increasing the choice of providers for patients. However, we were disappointed that there was very little mention of pharmacy within the document and an absence of examples of commissioned services involving pharmacists. Guidance on practice based commissioning encourages a plurality of provision and states that community pharmacy is one of those from whom services may be commissioned. Comments on specific points are detailed below.
Q1: Are these measures sufficient to enable people to take greater control of decisions about their health and care? What further action could central government take?
We welcome the reference to community pharmacy as an accessible source of self-care. However, the government could promote self-care, improve access to medicines and reduce GP and A+E visits by introducing a national minor ailments scheme, similar to that which already operates in Scotland. This could be achieved straightforwardly by moving minor ailments schemes from the enhanced to the essential/advanced level of the pharmacy contractual framework.
Q2: What special arrangements might be needed to ensure that the views are heard of those who do not routinely use local services?
Community pharmacies come into contact with many people who do not otherwise access NHS services. Community pharmacists can be better utilized – perhaps even commissioned - to engage hard-to-reach groups who visit them to obtain their views on NHS services.
Community pharmacies are located in the heart of local communities and are accessed by 2 million people every day. People who are at work during normal office hours can find pharmacies more easy to access than other health services because of their convenient locations and extended opening hours.
Young people who do not normally visit their GP will often go to pharmacies, and a recent pilot of Chlamydia screening and treatment in London pharmacies showed the readiness of people in the 16-24 age bracket to access pharmacies.
Some pharmacies have also had great success in engaging people who do not speak English and may struggle to access services. An example of this is the Green Light pharmacy in Camden which employs many local people who speak Bengali, to help reach the local Bangladeshi population. This initiative has helped support a successful diabetes screening service.
Q4: How can we shape the duty of Joint Strategic Needs Assessment to have the greatest impact on health and well-being?
We believe that the Pharmaceutical Needs Assessment should feed into the Joint Strategic Needs Assessment. There is considerable potential for joint NHS-local authority commissioning of pharmacy services. Community pharmacies are well placed to support local authority goals by providing smoking cessation services, obesity clinics, reducing teenage pregnancies (through supply of emergency hormonal contraception) and supporting drug addicts in treatment programmes.
According to the framework, the Joint Strategic Needs Assessments should be made available to all current or potential providers, who may have additional relevant information or innovative proposals for meeting needs. No assumptions should be made about the parameters of community pharmacy’s role and community pharmacies should be among those to receive the Joint Strategic Needs Assessment and related documents.
Q7: Is the legal position with regard to information and data sharing for the purposes of commissioning clearly set out here? Is there any need to review the current rules in order to facilitate information and data sharing?
Gaining sufficient access to the electronic care record will be an essential requirement for new providers to run a service. All community pharmacists already need appropriate baseline read and write access to the electronic care record to complete their roles within the existing pharmacy contractual framework. If community pharmacies take on new roles, additional access to the electronic record may be required. PCTs will have the responsibility for authorising additional access rights. We believe that PCTs must have robust procedures in place to ensure that health care professionals are provided with additional appropriate access in a timely manner.
In Manchester, pharmacists are already offering point of care diagnostic testing to people with diabetes and cardiovascular disease. In the North-East a pharmacy-based anticoagulation clinic provides care closer to home for patients who used to have to make very regular trips to the local hospital. Such services could become more efficient and widespread with better integration of community pharmacy into the electronic care record – encouraging information sharing and continuity of care for patients.
Q10: Will these proposals support commissioners to assure a range of high quality providers for all services?
The ‘Practice based commissioning: practical implementation’ guidance (November 2006) re-stated the policy of encouraging a plurality of provision of health services. Indeed, it included community pharmacy in a list of providers from whom services might be commissioned.
In order to maximize this range of providers, local commissioners will need to manage the commissioning landscape in such a way that all providers, new and old, have an equal opportunity to deliver a service. Consequently, there needs to be a clear entry point into the commissioning process so that new providers have an opportunity to contest service provision with established providers. Commissioners must publish service specifications and sufficient time should be allowed for new providers to prepare their proposal. All relevant demographic data and information on current service provision must be provided.
Genuinely inclusive PBC governance structures should be regarded as mandatory and their implementation robustly monitored. Only then will the skills and expertise of all those who work in, with and for the NHS be effectively marshalled.
Q17: What further measures might be required to clarify accountabilities for commissioners?
In order for new providers to be brought into the market, commissioners will have a responsibility for providing relevant information and ensuring transparency of process. Commissioners should therefore explain to the provider forum how it will discharge these responsibilities. There should be some mechanism to allow providers to hold commissioners to account if they are not offering support to new providers.
