The Department of Health and Social Care (DHSC) has today laid regulations affecting community pharmacy contractors as well as indicating the Government’s decisions on the Community Pharmacy Contractual Framework (CPCF) for 2023/24.
These changes and decisions have been imposed on the sector as PSNC’s clear view remains that the sector’s finances and capacity are in a critical state, and that DHSC and NHS England have run out of money for new pharmacy services or activity.
These changes do not reflect any changes that might be negotiated pending the outcomes of the Primary Care Recovery Plan (PCRP) which has been considered by Government separately to the CPCF and is likely to be published soon.
Summary of the changes
On the CPCF, the Government has decided that:
The Pharmacy Contraception Service (Tier 1) will start on 24th April 2023 (this has previously been announced by NHS England).
The Community Pharmacist Consultation Service (CPCS) will be expanded to include referrals from Emergency Departments and Urgent Treatment Centres from 15th May 2023.
These changes have been made by DHSC and NHSE in contradiction of our warning to Ministers that no new or expanded services can be rolled out in 2023/24 unless extra funding is put into community pharmacies.
In 2023/24 there will be a reduced Pharmacy Quality Scheme, compared to the scheme originally planned last year. This means a reduced list of activities for contractors with a value of 60% of the originally planned PQS – £45m. The remainder of the PQS funding (the additional £30m) will be used as an alternative to reducing fees to help ensure that there is no over-delivery of fees in this financial year. As the reduced PQS contains a clinical audit, DHSC and NHSE have agreed to PSNC’s request to remove the clinical governance requirement for contractors to undertake two clinical audits in 2023/24.
The decision to go ahead with a PQS this year without an urgent injection of extra funding is in contradiction of our warnings to Ministers that there is not enough money to pay for the current services and dispensing delivered by the sector; let alone for new activities to be rolled out. However, we do recognise the importance of some elements of the PQS to patients and the NHS, and the fact that the scheme continues to demonstrate pharmacy’s commitment to, and exceptional performance on, quality. We note the concessions that Ministers have made in response to our submissions – both in reducing the scope of the PQS to reduce the burden on contractors, and in avoiding a reduction in the SAF which was previously mooted.
Overall, this is an improvement on their original position, safeguarding the funding for PQS and reducing the activity required, notwithstanding our belief that the funding and capacity constraints which apply to the whole sector mean the scheme is currently unaffordable.
A flat fee of £70m will be paid out to contractors on a monthly basis from April.
This is as negotiated by PSNC last autumn, allocating up to £70m per year in recognition of the pressures on the sector.
Regulatory changes will come into force on 25th May 2023 to allow some flexibilities for contractors to a) close for rest breaks and b) manage closures through ICB local hours plans. Changes will also allow 100-hour pharmacies to reduce their core hours and the regulations will require all pharmacies to ensure that business continuity plans to deal with temporary suspensions of service are in place to address circumstances when pharmacies have to close on a temporary basis.
PSNC requested that DHSC and NHSE consider regulatory easements to reduce the pressures on community pharmacies and made over 30 suggestions of changes that could help improve the operating environment.
The package of regulatory changes now being introduced was opposed by PSNC on the basis that it is wholly inadequate to address these crippling pressures. The proposals to ease requirements for 100-hour pharmacies, devised by DHSC and NHSE, is not matched, in PSNC’s view, by equivalent easements for 40-hour pharmacies. While some of the changes being introduced have some merit and will assist contractors, the overall package does not go far enough and does not show that DHSC and NHS England have recognised the severity of the situation for over-worked and under-funded community pharmacies.
Further information on the imposed CPCF services and the regulatory changes will be published by DHSC and NHS England.
DHSC has published the full details of the PQS on the NHSBSA website, which will give contractors as much time as possible to consider whether they want to take part in this work.
PSNC’s position remains that we do not think contractors will have the capacity to take on additional services or work.
We have today published a briefing on the Department’s regulatory changes to help contractors to understand what these mean for them ahead of their introduction on 25th May 2023.
PSNC met last week and once again considered the impossible pressures facing community pharmacy. Without a funding lifeline the Government and NHS will be presiding over the collapse of the sector and we are continuing to focus on this in our political, influencing and national media work, as we well as in our ongoing discussions with the DHSC and NHS England.
We still believe that a fully-funded Pharmacy First service would be a good route to get additional funding into the sector quickly, while also delivering on Government’s ambitions and supporting patients and our wider primary care colleagues. This is the most likely route to gain additional funding in the short-term and we are continuing to work very hard – as we have been since September – to ensure that this is included in the Government’s upcoming Primary Care Recovery Plan.
Commenting on the DHSC and NHSE decisions, Janet Morrison, PSNC Chief Executive, said:
“As reported a number of weeks ago, we have been clear with Government and the NHS that their money has run out – there is simply not enough funding available for pharmacies to deliver new services in year 5. It’s incredibly frustrating that these warnings are not being heeded – there is simply no point in NHS England rolling out services that pharmacies cannot afford to provide or deliver to the standard patients deserve.
“That said, we recognise that Ministers have made helpful concessions on the PQS – reducing the scope of the work involved, including the removal of the two clinical audits this year, and rerouting some of the funding into core funding. This is an improvement on previous years, although I know that in reality it is far too little to help ease the crippling pressures that contractors are grappling with.
“The regulatory changes that are being introduced are divisive. While the allowance to change core hours may bring some small relief to contractors of 100-hour pharmacies, PSNC was clear that any change like this needed to be matched with provisions for all other contractors who are facing the same pressures. We believe that it is unwise for the NHS to interfere with the level playing field for contractors in such a crushing economic climate.
“PSNC put forward more than 30 proposals for wider regulatory easements to help relieve the pressure on contractors: the package that has been arrived at does not go nearly far enough to recognise the severity of these pressures. We can see no excuse for not making more impactful changes that would make a real difference to hard pressed contractors.
“As I said a few weeks ago, Government and the NHS have all the evidence they need to show them that without urgent action they – and the public – will lose significant parts of the community pharmacy sector, and soon. This would be catastrophic for pharmacy, patients and for primary care and we are doing everything within our power to prevent it from happening.
“Our best hope of getting additional funding into the sector remains the bid for a fully-funded Pharmacy First service which PSNC put forward last March and has been lobbying for ever since both in our public affairs work, supported by LPCs and others, and influencing behind the scenes. The Primary Care Recovery Plan must deliver this, or another funding lifeline, to community pharmacies, and quickly.”