Written evidence submitted by Company Chemists' Association
About the CCA
Established in 1898, the CCA is the trade association for large pharmacy operators in England, Scotland and Wales. The CCA membership includes ASDA, Boots, LloydsPharmacy, Morrisons, Rowlands Pharmacy, Superdrug, Tesco, and Well, who between them own and operate around 5,000 pharmacies, which represents nearly half the market. CCA members deliver a broad range of healthcare and wellbeing services, from a variety of locations and settings, as well as dispensing almost 500 million NHS prescription items every year. The CCA represents the interests of its members and brings together their unique skills, knowledge, and scale for the benefit of community pharmacy, the NHS, patients and the public.
The CCA welcome the changes made by the Health and Care Act 2022 to allow statutory NHS commissioners and providers to work better with primary care (including community pharmacies), local authorities and other partners to agree priorities and ensure better outcomes for patients. We have long said that legislative change alone will not ensure integrated and collaborative working at a local level – and other changes explored throughout our response must follow to ensure effective joint-working between different parts of the health and social care system.
ICB establishment, governance and functions:
Since the establishment of statutory integrated care systems (ICS) on 1 July 2022, NHS England (NHSE) has had the power to delegate the commissioning of primary care services to Integrated Care Boards (ICBs). Whilst delegation agreements are in place with all ICBs for the commissioning of general practice, a much smaller number of ICBs have taken on responsibility for commissioning community pharmacy services. It is our understanding that it is NHSE’s intention for ICBs to take responsibility for commissioning all primary care services from 1 April 2023. When commissioning functions for primary care are delegated, the additional funding ICBs receive must be ringfenced to ensure it is not used for other purposes.
We remain opposed to any proposals to move all of NHSEs national commissioning functions to ICBs. Whilst also being less efficient, we believe this will result in increased variation and will risk widening health inequalities. However, we recognise the value of supplementary and enhanced services to meet specific, identified local needs.
To allow ICBs to commission pharmacy services effectively, it will be vital for non-medical primary care professionals to be represented at a senior level. To that end, we are pleased to see the recent appointments of Chief Pharmacists/Directors of Pharmacy at several systems across England. NHS England should mandate that all ICBs have formal representation of pharmacy at the appropriate levels.
It is vital that these individuals represent the entire pharmacy profession within their system, including those working outside of the NHS in community pharmacy. This will ensure appropriate representation of pharmacy when commissioning decisions are being made, ensuring that community pharmacy is best placed to improve population health, reduce inequalities and ease pressure on other NHS services.
As ICS’ develop, it will be important for national bodies to continue their role in monitoring compliance with nationally-set strategic objectives. We particularly agree with the NAO that NHSE should ensure its annual assessments of ICBs’ performance include an evidence-based assessment of the effectiveness of joint working and delivery with partners beyond the NHS.
Integrated Care Partnerships:
We would urge the Department of Health and Social Care, when refreshing their Integrated Care Strategies guidance in 2023, to consider the inclusion of requirements to involve local representational bodies such as Local Medical Committees, Local Dentistry Committees, Local Ophthalmology Committees and Local Pharmaceutical Committees within the ICP governance structure to ensure ICPs do not become distracted by the highest profile issues such as A&E waiting times and access to general practice.
Funding and workforce:
Despite our support for the removal of silos which prevent community pharmacy teams from collaborating with other health and care services, we remain concerned that the current financial pressures and chronic workforce shortages will severely inhibit our ability to work with the local NHS and transform the way care is delivered in the community.
The current funding model for community pharmacy is economically un-viable, we therefore encourage community pharmacy leaders and ICBs to work closely together when agreeing local priorities and enhanced services beyond those commissioned under the nationally negotiated Community Pharmacy Contractual Framework (CPCF) – backed by sufficient funding.
We also encourage ICBs, working alongside Health Education England and NHSE, to make the most effective use of their people functions to deliver commitments made in the 2021 People Plan. ICBs should make use of the data coming from the 2022 HEE Community Pharmacy Workforce Survey to inform their local workforce plans.
They should ensure that appropriate consideration is given to workforce planning for professionals outside of NHS organisations, including pharmacists and pharmacy technicians working on the high-street.