Any reforms to reimbursement mechanisms for community pharmacies must not financially disadvantage contractors, the Pharmaceutical Services Negotiating Committee (PSNC) has warned.
The negotiator said that contractors could face ‘dispensing at a loss’, if proposed reforms for NHS prescription reimbursement in England were to go ahead, as the Department of Health and Social Care (DHSC) set out in its consultation published in July.
The reforms include changes to how drug tariff Categories A, C and M prices are set and to the reimbursement and procurement of unlicensed medicines, as well as splitting the discount deduction scale into one for generics and one for brands.
The Government is also proposing to include more products prescribed for medicinal purposes like food supplements in part VIIIA of the drug tariff and to use the manufacturer’s price list for reimbursing non-part VIIIA products rather than the supplier’s.
Out of pocket
Financial disadvantage is one of the possible ‘significant unintended consequences’ of the proposed changes to price setting for Category C, according to PSNC in its response to the consultation.
The negotiator said: ‘Contractors already dispense many medicines listed in Category C at a loss after discount deduction. Basing a reimbursement system for Category C medicines on averages would mean that pharmacy contractors who dispense a more expensive medicine against a generically written prescription due to patient need will further increase their risk of dispensing at a loss.’
To avoid increasing this risk, contractors should be reimbursed based on the price lists of wholesalers or the suppliers from whom they directly buy medicines rather than manufacturers, PSNC added.
However, pricing information provided on dm+d must be reviewed as it is ‘not always reflective of the market’, it said.
The consultation response added that all prices must be available to contractors before they dispense medicines.
It said: ‘It is not acceptable for pharmacy contractors to rely on the previous months’ reimbursement prices as an indication of the expected reimbursement for the current dispensing month; any blended or weighted prices calculated from multiple suppliers’ prices would need to be available in the month of dispensing.’
‘Supply issues’ are another possible consequence to the proposed Category A, C and M changes, according to PSNC.
The negotiator said: ‘Any reimbursement mechanism that introduces price volatility amplifies the risk of shortages and reduces the market attractiveness to new entrants. Avoiding sudden shocks to the market will help ensure uninterrupted supplies, reducing the risk of increased costs for the NHS and helping to ensure access for patients.’
It added: ‘There is a risk of exacerbating problems around drug availability and shortages by the reduction of medicine margin in individual Category M products’.
PSNC urged a cautious approach to any reimbursement changes due to ‘signs of fragility’ in the medicine supply chain and ‘Brexit looming’.
The negotiator also criticised the proposals for procurement and reimbursement of unlicensed medicines, saying they would place ‘additional burden’ on pharmacy teams.
It said: ‘The new community pharmacy contractual framework (CPFC) arrangements seek to create headroom for pharmacy teams to be more accessible to patients by moving pharmacy away from dispensing activity and into new services.
‘However, PSNC is concerned that options proposed for procurement of specials may further increase the time spent by pharmacy staff sourcing stock by increasing the administrative burden.’
The proposed changes to Category C reimbursement are also ‘likely to increase workload’, PSNC added.
The negotiator said it looked forward to its discussions with the DHSC and NHS England during the second stage of the consultation process.