Written evidence submitted by The ABPI (PHA0022)

Executive Summary

• The ABPI welcomes moves for a greater role for pharmacists in delivering medicines and vaccines, including as set out in the Government’s recovery plan for primary care. This could help improve patients’ ability to access treatment and ease the strain on GPs.[i]
• The ABPI sees the potential for an even greater role for pharmacists than currently envisioned when it comes to the delivery of vaccinations. As such, a separate vaccination section has been included below.
• However, none of these changes will be possible without investment, greater connection between primary and secondary care and appropriate training.

Response to Questions – General

1. What does the future of pharmacy look like and how can the Government ensure this is realised?

1.1.   Community pharmacy represents a ‘strategically important setting with great potential to deliver services’ and it is in many ways, the most accessible healthcare provider to the general public.[ii] 89% of people in England are just 20 minutes’ walk away from their nearest pharmacy.[iii]

1.2.   As the think tank Policy Exchange has noted, community pharmacists are often available without an appointment; are open evenings and weekends; are located close to the majority of the population; and access is greater in areas of highest deprivation.[iv]

1.3.   Of the 33 million covid-19 vaccinations delivered in community pharmacy, over a third were delivered in the 20% most deprived areas of the UK.

1.4.   This strategic importance means the role for pharmacies should grow as the NHS looks to recover from the pandemic, address workforce challenges and tackle increasing ill health in the UK. Pharmacists should also play a key role in prevention, a public health drive which is critical to the sustainability of the NHS.

1.5.   The ABPI welcomed the publication of the ‘Pharmacy First’ report by the Royal College of General Practice (RCGP) and the Royal Pharmaceutical Society, which set out proposals to expand pharmacist role in managing minor issues.[v] This is an important issue to explore further, and the ABPI believes that sexual health and vaccines represent areas of particular promise.

1.6.   With the right structural and funding and training changes, there is also the potential that community pharmacy could be enabled to dispense certain specialist medicines.

1.7.   The NHS England recovery plan for primary care, published in May, set out that pharmacists could soon be eligible to prescribe antibiotics.[vi] To minimise the risk of antimicrobial resistance (AMR), the ABOI strongly recommends that pharmacists receive appropriate awareness training on the issue and that antimicrobial prescribing is tracked to ensure that use is appropriate. This might however require greater interoperability of digital systems (as explored below).

2. What are the challenges in pharmacy workforce recruitment, training, and retention, and how might these best be addressed?

2.1.   It is clear that there is a great deal of strain on the healthcare workforce, across all levels, including pharmacy. As outlined above, if pharmacists are to have a greater role in the prescription and delivery of medicines and vaccines, there will need to be increases in funding and appropriate training.

3. To what extent are digital systems used in pharmacy sufficiently interoperable with those in general practice and hospitals?

3.1.   The UK needs to move to a point where data is reliably and freely shared across secondary care, community pharmacy and general practice as there is currently an impasse on data sharing. This can create serious challenges, for example, for continuity of care for patients initiated in secondary care but managed in the community.

4. What innovations could have the biggest impact on pharmacy services and why?

4.1.   The biggest innovation on pharmacy service could be a move in the future to a greater role as an independent prescription service.

4.2.   The ABPI is broadly supportive of this, provided the appropriate safeguards are put in place, as it could improve patient access to medicines and help the UK to overcome our long-standing challenges around the use of new medicines. The UK currently lags behind other countries in the use of new medicines for at least 5 years after launch, with Uptake at half (56%) of an average of 15 comparator countries.[vii]A move to greater prescription by pharmacists could have particularly benefits for patients with long-term conditions.

4.3.   There is also the potential for improvement of management of patients initiated on treatment but maintained in a community setting, particularly through enhanced engagement and communication between pharmacy and consultants.

5. To what extent are funding arrangements for community pharmacy fit for purpose?

5.1.   Financial barriers currently exist for the transition of prescribing and dispensing from secondary care to community pharmacy settings, such as the unavailability in community settings of VAT exemptions available to hospital trusts.

5.2.   These financial barriers, and the appropriate and consistent levels of funding for new pharmacy services are currently, and will continue to, impede the development of novel models of care.  These barriers should be explored as part of the forthcoming negotiations for the next Community Pharmacy Contractual Framework.

6. What factors cause medicines shortages and how might these be addressed in future?

6.1.   Medicine supply issues can arise for a variety of different reasons including issues with the supply of active pharmaceutical ingredients, in-process manufacturing issues, batch failures, and distribution/logistic issues, amongst many others and only some of which remain fully in the control of suppliers.

6.2.   Globalisation of the pharmaceutical industry and healthcare system drive for efficiency and sustainability means that the manufacture of individual medicines or their active pharmaceutical ingredient is frequently limited to a small, defined number of sites worldwide. Production schedules are planned months in advance and this, together with the adoption of "just in time” manufacture and sustainable inventory control, means that manufacturing volumes are aligned to predicted demand with appropriate safety buffer stocks. Regulatory and logistical challenges can therefore often make it difficult to respond to unpredicted surges in demand, as these cannot easily or quickly be matched by increased production.

6.3.   The complexity of demand forecasting for multi-sourced, generic medicines - where one or more supply failures or changes in market conditions can significantly impact demand expectations on other suppliers - can be particularly challenging. This is especially true when market conditions do not support a company’s ability to enter or maintain a presence in a market or invest in manufacturing quality and redundant capacity. Suppliers of generic medicines to the NHS increasingly face intense price competition vi a ‘race to the bottom’ in pricing, uncertain revenue streams and high investment requirements, all of which limits its commercial attractiveness.

6.4.   Early identification of a potential shortage by pharmacy is important, and it is also essential that pharmacies do not respond to supply issues in isolation but work collaboratively with suppliers, supply chain stakeholders, NHS and DHSC in line with the Guide to Managing Supply Shortages. [viii]

7. To what extent does community pharmacy have the resource and capacity to realise the ambitions in DHSC’s Primary Care Recovery Plan?

7.1.   Government should recognise that all of the changes set out in the Primary Care Recovery Plan for a greater role for pharmacists may require further investment (especially with pharmacies closing)[ix] and that there are several key issues which need to be explored, including: pharmacy access to patient records; IT systems and connectivity between community pharmacy, general practice and secondary care; and risk mitigation measures (e.g. training) to make sure that ‘red flag’ conditions – particularly in paediatrics – are not missed.

7.2.   While the move could also help to ease pressure on our GP workforce, Government must recognise that it cannot simply move patients around from one strained part of the NHS to another.

8. Are there the right number of community pharmacies in the right places and how can we ensure that this is the case across the country?

Response to Questions – Vaccination

1. What does the future of pharmacy look like and how can the Government ensure this is realised?

1.1.   Policy Exchange recently produced a report looking at the future for vaccines policy, which was supported by a research grant from the ABPI.[x] This report found that there is an opportunity for an expanded role for pharmacy in delivering national immunisation programmes, particularly for the adult population which is now familiar with this model of care.

1.2.   In recent years, pharmacists have been commissioned to provide adult seasonal flu and COVID-19 vaccination. Looking ahead, 80% of pipeline vaccine candidates are targeted towards adults and older adults. This reflects the growing importance of life-course immunisation for keeping working-age adults and older adults healthy and potentially offers further opportunities for pharmacy to play a bigger role. One example of this shift towards adults in the pipeline is the RSV vaccination, which the Joint Committee on Vaccination and Immunisation (JCVI) has recently advised should have an immunisation programme for older adults (age 75+) developed and which could be given in a pharmacy setting. Opportunities for pharmacists to join in delivery of the NHS adult pneumococcal and shingles programmes could also be considered. Many pharmacies also offer private travel vaccinations.

1.3.   In the short term, Pharmacy Technicians could be added to those able deliver vaccines through a Patient Group Directive (PGD) with an amendment to The Human Medicines Regulations 2012. It would be important however to ensure that any changes are accompanied by quality assurance measures.

1.4.   Pharmacists play a key role as information counsellors, supporting those with vaccine hesitancy. Studies have already found an increase in vaccine coverage when pharmacists were involved in the immunisation process, regardless of role (educator, facilitator, administrator) or vaccine administered (e.g., influenza, pneumococcal), when compared to vaccine provision by traditional providers without pharmacist involvement.[xi]

2. What are the challenges in pharmacy workforce recruitment, training, and retention, and how might these best be addressed?

2.1.   Retired pharmacists and pharmacy students should also be able to opt in and be trained to deliver immunisations except where there is a strong clinical rationale for not doing so (or adequate supervision cannot be assured). This approach should be formalised, with contracting and reimbursement for sessions delivered introduced.

3. To what extent are digital systems used in pharmacy sufficiently interoperable with those in general practice and hospitals?

3.1.   During COVID-19 enabling the responsible flow of data around the system and ensuring access to real time immunisation data informed strategies and approaches to address low vaccination uptake. There is much to mimic from the approach to data recording and transparency during COVID-19 whilst realising that the unique circumstances during the pandemic meant that good practice around co-design was sacrificed for speed. The Federated Data Platform creates an opportunity to build wide stakeholder support.

3.2.   It is critical there is a “single version of the truth” for an individual’s medical history as noted in the Hewitt Review, and the Primary Care Record is the best way to achieve this. All vaccination data must be captured in the Primary Care Record, with data fed through from community settings such as pharmacies. It is vital that all providers have access to their record, wherever this may be housed, so as to enable system-wide delivery that ensures no one falls through the cracks.

3.3.   As a priority, community pharmacy should be able to access patient records in order to support ‘opportunistic vaccination’ in the community. This move would also be a key component of a wider shift to ‘patient managed’ records, a move commensurate with commitments in the Government’s recent Plan for Digital Health and Care and the Integration White Paper, both of which call for the NHS App to offer a personalised experience and to encourage them to engage in tailored preventative activity (including immunisations and vaccinations).

3.4.   As almost all NHS vaccines are centrally procured, pharmacists will need access to ImmForm to enable them to order NHS vaccines beyond Flu and Covid.

3.5.   The Vaccine Data Resolution Service (VDRS) should become more accessible to users so they can help to ensure records are up to date.

3.6.   There may also be opportunities for pharmacists to help identify patients for clinical trials and those most at risk of inequity of access to treatments.

9. To what extent are commissioning arrangements for community pharmacy fit for purpose?

9.1.   As mentioned above, there is a need to explore commissioning arrangements and financial barriers further, including as part of the shift to Integrated Care Systems.

9.2.   With vaccinations in particular, the ABPI is very supportive of NHS England’s work on a vaccination strategy and believe this should include a focus on the contribution pharmacy could make to achieving high coverage rates and how local systems and providers will be encouraged to collaborate for success.