| For the past six months primary care trusts have been tasked
with monitoring contractors’ compliance with the new
community pharmacy contract. The importance of differentiating this role from that
of pharmacy inspectors
has been something PCTs have been acutely aware of during the implementation
process.
John Carr, professional executive committee pharmacist at East Staffordshire
Primary Care Trust, along with the PCT’s primary care manager,
has conducted eight monitoring visits so far. He sees the visits as an
extension of clinical governance, not as inspections. “We were
sensitive to this feeling of threat, fear and anxiety that we were experiencing
from group meetings with community pharmacists,” he says. “The
monitoring visit is purely to make sure that the service is being dealt
with. The PCT cannot withdraw a contract on the basis of a visit,” he
adds. He believes that it is important to gain people’s confidence
and says that the worst thing PCTs can do is to go in with a “we
can close you if you are not up to scratch” approach.
Shailen Rao, medicines management pharmacist at Hillingdon Primary Care
Trust, is the lead for community pharmacy contract monitoring for the
PCT and has accompanied the PCT’s pharmacy development manager
on monitoring visits. He advises PCTs to keep visits simple and be realistic
about their expectations. “There is a real danger of being perceived
as being heavy handed if we are not careful. We need to differentiate
the role of the Society inspector and our obligations in the contractual
monitoring process — it is difficult to separate the two.”
Pilot visits
Mr Carr decided to conduct pilot visits before rolling out monitoring
to the rest of the PCT, a strategy that he recommends to other PCTs. “Go
to a friendly, knowledgeable pharmacist with whom you have a good relationship
and who you are confident is likely to be an exemplar,” he suggests.
His first visit was to a pharmacy owned by the chairman of the local
pharmaceutical committee. During the visit, Mr Carr used a document
that combined the NHS Primary Care Contracting community pharmacy assurance
framework (available from www.primarycarecontracting.nhs.uk) with a
framework that had already been developed by the LPC. “That was
one of the first things we changed. There was a lot of duplication
across the whole document and the first visit took four hours,” explains
Mr Carr. He revised and consolidated the framework and developed a
detailed portfolio of evidence that he would need to look for during
each visit.
Both the framework and the evidence portfolio are sent to each contractor
before the monitoring visit takes place and Mr Carr offers to visit pharmacies
informally to explain the process. He also asks contractors to fill in
the self-assessment tool (available as part of the community pharmacy
assurance framework) before the visit. This is not essential but it does
speed up the process, he says. He would also advise PCTs to read the “Top
ten tips for conducting visits” available from the NHS Primary
Care Contracting website.
During the visit, Mr Carr and his colleague work through the questions
in the toolkit, examine the evidence provided and talk to members of
staff. This is followed by a brief discussion and verbal feedback. Verbal
feedback is backed up with a written report, which must be signed by
the contractor and returned. “The very organised pharmacies we
can now do in about two and a half hours,” he says. Issues arising from visits
“Issues that have arisen so far have generally been minor and have
usually involved missing standard operating procedures,” explains
Mr Carr. He advises those monitoring the contract to make sure that SOPs
are not
just pieces of paper that are left on the shelf.
No major problems have been identified during the Hillingdon PCT visits,
either. However, Mr Rao comments: “I get the feeling that pharmacists
are starting to do things that they have never done before. Some of the
systems are there but it is quite apparent that they are newly set up.
I think in future years we will expect to see a bit more evidence that
they are actually being followed.”
He believes that although pharmacists may have been following the correct
procedures before, it has been fairly informal. “Some clinical
governance issues have already been highlighted, particularly around
standard operating procedures for errors and incident reporting,” he
says. Action points
Pharmacy contractors receive a written report which details any action
that needs to be taken. Both PCTs say that the timeframe for this action
is dependent on the nature of the missing evidence.
Mr Carr will revisit a pharmacy only if it is perceived that there
is a danger to patients. “Unless we see something dangerous there
would be no further action or immediate follow up,” says Mr Carr.
Hillingdon PCT allows contractors three months to comply with any action
points; less time if a serious omission has been identified. Improvements
“I have heard of visits taking seven or eight hours, where PCTs
have gone through every SOP in great detail. I do not think that is our
role. If
people start setting up processes this year then that is enough for a
first step,” says Mr Rao.
Mr Carr is convinced that the process of monitoring visits has changed
pharmacy services for the better. “I believe that a lot of pharmacy
services have improved by virtue of the preparatory work they have done
for this because they have recognised what they do well, and what they
did not do so well, and have addressed these issues.”
IT developments
Some PCTs plan to use webtools in order to
make the monitoring process more efficient. Hillingdon PCT has
a secure website, which
can be accessed via NHSnet. It was originally set up so that community
pharmacists could update information about their services for the
PCT’s pharmaceutical needs assessment but has been developed
further and is now used as a forum for sharing information. “All
of the pharmacies in the PCT have access to the forum,” he
says. It is used to post all new information, such as strategies,
advice, documents and tools, and for the pharmacists to communicate
with the PCT and with each other, he adds.
The PCT also plans to transfer all paperwork relating to pharmacy
services on to the website, including monitoring documentation,
such as the community pharmacy assurance framework and the Pharmaceutical
Services Negotiating Committee new contract workbook. Mr Rao explains
that pharmacists will be able to log on with a password and fill
in a pre-assessment form in advance of a monitoring visit. The
PCT will then be able to update this form during the visit, and
later produce an action plan electronically. “The website
can also be used to share examples of good practice, such as SOPs,
with other pharmacists within the PCT,” says Mr Rao. He hopes
to begin using the site for monitoring purposes during the next
financial year.
A similar approach is being developed by Pritpal Thind of Caregrange
Pharmacy in London. Pharmacies are able to record information about
services they offer under the new pharmacy contract and submit
that information to their PCT via a secure website. One benefit
for PCTs is that much of the monitoring work can be undertaken
before the visit and data provided by pharmacies does not have
to be re-entered. For pharmacies, another version of the tool can
be used to manage aspects of the contract that are subject to monitoring,
such as recording and auditing clinical governance requirements
or developing and updating SOPs. |
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The
Pharmaceutical Journal