The current rules on the establishment of NHS pharmacies in England have been updated and new guidance on their interpretation introduced.
One of the previous, most common routes of entry (opening a pharmacy that provided a counter service for at least 100-hours a week) will no longer receive automatic agreement. While this may seem like a hindrance for GPs hoping to open a pharmacy, most 100-hour pharmacies struggled to cover extensive staffing costs. More cost-effective possibilities are now available.
The ability for new integrated health centres to bypass rules and open an on-site pharmacy has also gone. Practices may have considered this option because the rental income from an on-site pharmacy can be substantial and help off-set some of the costs of building a new premises.
So if you are interested in opening a new pharmacy, or are keen for a new pharmacy to take space in your building, what will you need to do to secure agreement from your PCT?
Pharmaceutical needs assessment
Any new pharmacies will need to demonstrate how they can improve the current service. The bedrock for these considerations will be the pharmaceutical needs assessment (PNA).
PCTs, and their successors, must maintain an up to date PNA. This should detail the current level of service provision of pharmaceutical services in the area, including doctor dispensing. They need to be revisited and updated, usually every three years.
The PNA should also list any perceived gaps in the range or access to pharmacy services. It is these lack of services, whether explicit in the PNA or which can be demonstrated in other ways, that are the entry routes for new pharmacy applications.
New applications, with the exception of distance selling operations (see below), will in future be judged mainly against the current PNA.
Applications for new pharmacies
Some of the potential gaps in services that could facilitate a new pharmacy application are listed below, although there are differences relating to devolved national governments and local PCT-incentivised services.
Essential pharmaceutical services
The most basic gap allowing an application would be under provision of the defined Essential Pharmaceutical Services. These guidelines have been in place for some years and in reality it is unlikely that there will be many areas where such a dramatic lack of provision has not already been filled.
Specific directed services may also be detailed for an area in a PNA, for example supply of emergency contraception directly by a pharmacy in an area with a high level of unwanted pregnancies.
These will be clearly stated and although PNAs are part of a dynamic process with regular updating, again many potential applicants will have studied these over the last few years to look at any possible grounds to support a new pharmacy.
Greater access to a service already commissioned from local pharmacies would be another route of entry. This may, for example, be a wider delivery of smoking cessation services with longer opening hours where there is current under provision, or allowing greater access and communication in areas with wider ethnic diversity and language difficulties.
Perhaps the biggest area for any potential applications is what the new guidance calls ‘unforeseen benefits’ and this is likely to be the entry point for any pharmacy application involving GPs.
Whilst the PNA may be specific on new or improved services that would benefit patients in the area, the guidance has been left open for future imaginative ways of enhancing care. By the nature of the title, the NHS guidance cannot foretell the new benefits that such applications will demonstrate, but it does give some possible examples that are likely to be approved.
This includes an additional pharmacy following development of a new housing estate or conversion of buildings to university residences. Another suggestion is to cover increased opening times following longer GP opening hours relating to changes in extended hours.
This list is far from comprehensive and it is likely that this area will be the most controversial as potential new applicants try to justify and clarify the unforeseen benefits a new pharmacy could bring.
GP practices are in a prime position to recognise and develop the potential benefits of any new clinical service. Considering where current gaps in care exist and then looking to plug them through a new pharmacy providing this service would be a great bonus to everyone.
Distance selling pharmacies
The one area of exemption for pharmacy applications that remains in place is for remote pharmacies, although the rules governing them are now more explicitly stated. These pharmacies are situated usually some miles away from the patient and doctor, taking medication requests via mail order or the internet.
Because they do not deal solely with the local community they fall outside the PNA. This separation is reinforced in the new guidance, which states that distance selling pharmacies must have no face-to-face contact with the public nor any form of ‘shop-front’.
More imaginative services
The changes in the rules may allow more imaginative development of health services delivered by pharmacies without the previous dependence on entry through the often uneconomic 100-hour route. Decisions affecting these applications will be influenced by advice from CCGs and local GPs.
- Dr Phipps is a GP in Lincolnshire