Main Paper and updates...

The main DH White Paper Consultation was released on the 27 Aug 08
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The original paperwork DH - White Paper - Pharmacy in England: building on strengths - delivering the future  was released back on 3 Apr '08
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DH Source DH - Press Release - Millions to benefit from improved access to treatment, check-ups and health advice from pharmacists
White Paper Outlines Bigger Role for Pharmacists in Treating Sickness and Promoting Good Health 3 April '08 Local Copy
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• Option 1 is no change. This has the advantage of maintaining the status quo, does not remove services from patients and does not put any jobs at risk. It does not, however, address the financial issues or the inequities within the current system identified earlier and in particular, whether GP dispensing can be justified when there is a pharmacy in close proximity.
• Option 2 is that whilst continuing with current arrangements where GP dispensing applies in controlled localities, the existing specific distance criteria would be removed. This would allow PCTs to determine the rural localities where GP dispensing is appropriate on the basis of their PNA. This option could address the current anomalies of a rigid national scheme and empowers local communities to make decisions appropriate to their needs. It aligns with the longer-term strategic direction for commissioning and pharmaceutical services generally, based on PNAs.
• Option 3 would mean that, instead of the distance between the patient’s home and the pharmacy, the determining factor should be a distance between the dispensing surgery and the nearest community pharmacy. Such a distance could be put at less than the current 1.6 km, for example, at 500 m or at 1000 m. This removes the anomaly of a doctor dispensing to some of his/her patients where there is a community pharmacist in close proximity and also removes the question of a practice having dispensing and non-dispensing patients. Such a `cliff edge’ effect is less pronounced than under the current arrangements although there may still be such cut-offs where there are nearby practice boundaries.
• Option 4 is a variation of Option 3. It would mean that a GP would not dispense where there is a pharmacy within 500 m or 1000 m of the GP practice and a second pharmacy within 1500 m. Those who are permitted to dispense may do so to all their registered patients regardless of the distance between their home and the surgery or pharmacy. This option maintains an element of choice for patients when having their drugs dispensed and has a less pronounced effect on GP dispensing.

(P36) The Department has identified four possible options to reform the current arrangements regarding dispensing by doctors. 
• Is the Department right in believing that there are inequities and anomalies within the current procedures under which patients can obtain their medicines and appliances directly from their surgery rather than from a community pharmacist? 
• Have you any personal experience of any such inequities and anomalies? If so, please briefly set them out. 
• Do you believe that having a local choice between two or more local dispensers when having a prescription dispensed is important to you? Could you quantify how important this is for you on a scale of 1-5 where 1 is exceptionally important and 5 is of no importance? 
• Is it right for the Department to publish a national set of rules setting out when a doctor can provide dispensing services or should the local NHS, for example your PCT, consulting with others, have more say?

• Do you agree that the four options set out in this consultation document relating to dispensing by GPs are appropriate options for consideration? Are there others that should be considered? 
• If you have a preference between Options 1-4, please indicate which is your preferred option and why. 
• If there were to be change, what issues do you believe the Department should take into account when implementing any new system? 
• Are there other factors to take into account – for example, how well do these options or your preferred option link to the proposals below for a common regulatory route for all applications?

(P39) The Department proposes to amend the 2005 Regulations (and associated primary medical legislation) to introduce a single regulatory route to authorise dispensing by doctors for patients in rural areas.
Do you agree:
• the proposal to align the regulatory route for dispensing doctor applications with those of pharmacies and appliance contractors?
• dispensing by doctors should, as now, apply to those patients who live in designated rural areas?
• the approval of doctors’ dispensing premises should continue?
• the ‘serious difficulty’ rule should be retained to enable a PCT to authorise dispensing for any patient who has serious difficulty getting to a pharmacy?
• Are there other factors which need to be taken into consideration?

(P42) The Department proposes to allow, where there is no convenient alternative, dispensing doctors to supply over the counter medicines to all of their patients, subject to the MHRA’s review and forthcoming informal consultation on the current medicines legislation.
• Do you believe that it would be beneficial for patients and consumers if dispensing doctors were able to sell general sale list (GSL) medicines to their patients where there is no convenient alternative?
• Do you believe that it would be beneficial for patients and consumers if dispensing doctors were able to sell pharmacy (P) medicines to their patients where there is no convenient alternative?
• How might the term ‘convenient alternative’ best be defined? For example, should a distance limit of, say 500 m, be set, or should this be left to local determination?
• If dispensing doctors were to sell P medicines, do you agree there should be safety provisions regarding such supply - for example, similar or equivalent to those that govern the sale and supply of P medicines through pharmacies?
• Are there any risks not identified here