| • Statutory Committee
• EHC
• The profession
• WCPPE
• CPD
• Premises fee
• Retention fees (2)
Letters to the Editor
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Premises fee
Call for a more realistic apportionment of costs
From Mr R. Darracott, MRPharmS
I cannot let the Treasurer’s
further repetition of his claim that the members of the Royal Pharmaceutical
Society “subsidise” the
premises fee (PJ, 8 December 2007, p654) go unanswered.
In the
cost recovery model submitted by the Society in support of its claim
for a 56 per cent
rise in the premises fee for 2008, revenues are set against the costs
of collecting the fee, the full costs of 18 of the Society’s inspectors
(with an associated overhead), and an apportionment of the costs of significant
elements of the Society’s Fitness to Practise Directorate, including
35 per cent of the costs of all investigations and the Society’s
statutory committees (including disciplinary and health).
Sticking purely
to the financial modelling, I do not accept that the Society incurs £3m
costs annually related to the collection of the premises fee or its enforcement
activities related to premises. Inspectors undertake a variety of duties
over and above those related to premises.
And given that I could find
only one Statutory Committee Notice of Inquiry in 2006 that includes
any reference to problems with “premises” in the citation,
I am struggling to see how 35 per cent of the costs of investigation,
prosecution and adjudication borne by the Fitness to Practise Directorate — or
almost £1m annually — can justifiably be linked to premises.
And
why is the cost of collecting the premises fee forecast to more than
double between 2006 and 2008?
I suggest that the application of a more realistic apportionment of costs
would remove the Treasurer’s “subsidy” and might even
mean that premises fees are a net contributor to the Society’s
coffers. Rob Darracott
Chief Executive
Company Chemists’ Association
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ANDREW GUSH, Treasurer of the Royal Pharmaceutical
Society, responds:
Mr Darracott has had the advantage of having seen
the detailed financial analysis we supplied to the Department of Health
to support our argument
for a substantial increase in premises fees. I am surprised therefore
at the inaccuracies contained in his letter.
The Society does not, as Mr Darracott argues, “subsidise” the premises
fees but our members do, any shortfall in recovery of our costs which we feel
justifiably attributable to the regulation of premises have to be made up by
a higher retention fee paid by pharmacists.
The costs attributable to premises regulation have not doubled between 2006
and 2008. The analysis supplied indicated an increase, based on our budgets
for 2008
of 34.7 per cent. The fee proposed for 2006 of £243 represented an increase
of 62 per cent over the corresponding fee for 2006 of £150. The higher
increase in fees than the rise in costs results from our desire to eliminate
the subsidy paid by our members that has existed for many years.
Mr Darracott remarks that there is only one citation (a Statutory Committee
Notice of Inquiry) in 2006 that made reference to premises. In doing so, I
believe he
has been rather disingenuous. The premises fee is paid by the owners and operators
of pharmacy premises. In these days of consolidation, the dominance of multiples
and corporate responsibility it would seem appropriate that owners take responsibility
for safe operating procedures, the provision of appropriate staffing levels,
the appointment and supervision of suitably skilled and qualified staff rather
than, as they would seem to argue, that the consequences of any failures should
fall entirely on the shoulders of the pharmacist who in many cases could well
be a self employed locum.
I have the privilege of quoting from detailed statistics for 2008: The Disciplinary
Committee ordered the removal from the Register of 12 pharmacists, three superintendent
pharmacists who were directors, four sole proprietors and four joint owners
of pharmacies; it also issued reprimands to 12 pharmacists, four superintendent
pharmacists who were not directors, four sole proprietors and one limited company.
During the same period, the Disciplinary Committee heard applications for interim
orders against five pharmacists and two superintendent pharmacists who were
not directors, while the Health Committee imposed interim suspension orders
on two
pharmacists and one superintendent pharmacist who was not a director. I am
sure that I do not have to remind Mr Darracott that superintendent pharmacists
must
be appointed by the owners of pharmacies which trade as limited liability companies.
The Society is acutely aware that the legislation surrounding pharmacy premises
is old and in urgent need of overhaul. We hope that the forthcoming legislation
that will establish the General Pharmaceutical Council will address such matters.
In the meantime we hope that an adult debate on the why and how of regulation
can take place with a view to promoting high standards in the operation of
pharmacy premises for the protection of the public and the pharmacists working
therein.
We believe that every responsible and professional pharmacy owner has
a vested interest in ensuring that premises regulation is maintained at a
high standard
and that those premises which fall below the high standards of the majority
of community pharmacies are not allowed to undermine the reputation of community
pharmacy as a whole. |
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The
Pharmaceutical Journal