Control of entry exemptions should not be the norm
Proposed exemptions to control of entry should be “exceptions and not the norm” and greater clarity is needed on the Government's proposals for changes to the control of entry regulations in England, if the existing pharmacy network is not to be badly affected, according to the main pharmacy bodies.
In their responses to the Department of Health, the Royal Pharmaceutical Society, the Pharmaceutical Services Negotiating Committee and the National Pharmaceutical Association all express concern about how patients, particularly
in deprived areas, might be affected by any changes.
The Society notes that there is a finite pot for pharmacy remuneration
and adds: “We would be concerned if pharmacies in areas of deprivation
or in rural areas were driven out of business by attrition, and inequalities
increased as a result.” The NPA says that rapid expansion and then
contraction of the market could result in a skewed distribution of pharmacies.
The Government has proposed a new test of “choice and competition”.
The NPA wants this to be “a proper test assessed against realistic
criteria”. It says that primary care trusts should make a full
assessment of the adequacy of pharmacy services in their areas as part
of their strategic services development plans. Existing contractors should
be invited to fill any gaps in the service identified by this and only
then should new entrants be considered. The proposed exemptions from
control of entry should also be considered in light of the adequacy assessment.
All three bodies consider that the exemption categories are arbitrary
and poorly defined. Other points include:
• 15,000 sq m The exemption for shopping developments over 15,000 sq
m would take in many redeveloped town centres and the figure chosen does
not fit in with existing planning guidance.
• 100 hours For pharmacies that intend to open for more than 100 hours
a week, clarification is sought on what would happen if contractors did
not open “as intended”.
• One-stop centres Nearly every medical practice in England could be
designated as a one-stop primary care centre under the proposed definition
and the consortia that might run pharmacies at such centres are not clear.
• Internet Providing internet or mail order pharmacy services from an
existing pharmacy should not be used to allow deregulation by the back
door.
Comment, p730 |
