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Quality Payments: How to avoid common mistakes

PSNC has examined the April Quality Payments declaration data from the NHS Business Services Authority (NHS BSA) to identify the most common reasons for contractors not initially passing the gateway criteria. There were nearly 800 contractors who appeared to have failed the gateway criteria for the Quality Payments Scheme at the first review point in...

1 day ago

Quality Payments: updating NHS Choices profiles – have you done it correctly?

Thousands of contractors have already updated their pharmacy’s profile on NHS Choices, in readiness for the November Review Point of the Quality Payments Scheme. However, this week’s data from NHS Choices shows that hundreds of contractors who have already edited their profile in the last few weeks, are not currently meeting the requirements of the...

2 days ago

Manufacturer & Wholesaler Christmas Opening Hours 2017

At this busy time of year manufacturers are working closely with wholesalers to ensure that sufficient stock is available at wholesalers for the Christmas period. A summary of customer service desk opening hours and order cut off /delivery schedules can be found below. Please note these times may vary according to staffing levels and are...

2 days ago

Dispensing

This page contains resources to support pharmacies in delivering Essential Service 1 – Dispensing Medicines.


7 Day Prescription Guide

Antibiotic Awareness

Anticoagulation Clinics

Antiviral Medicines

British National Formulary

Local CCG Dispensing Policies

Pharmaceutical Stationery Orders

New Rules for Instalment Prescription Endorsement (Methadone)

New Requirement for Prescriber Codes on NHS Prescriptions

Electronic Repeat Dispensing (eRD)

Repeat Ordering

Use of Emergency Salbutamol Inhalers in Schools

 

 

7-Day Prescription Guide

The 7-Day Prescription Guide is to assist you in deciding which of your patients may require 7-day prescriptions and will help you in your discussions with GPs.

If you are unsure about what you should be taking in to account when deciding whether to supply medicines to a patient in MDS then the recently published briefing from PSNC will be very helpful. It gives you and overview of the background to where community pharmacy currently finds itself with regards to this issues and some practical points for you to consider. The briefing can be found below.

PSNC Briefing 001.16 - Equality Act 2010

The briefing also contains some excellent FAQs which many pharmacy teams will find it useful to read. These have been reproduced below.

FAQs

Q. Must I always carry out an assessment under the Equality Act 2010, if a patient asks me to make an adjustment to the way in which I normally dispense, because of a disability?

A No.  The legislation does not require a formal assessment to be carried out, only that a reasonable adjustment is made to help a disabled person overcome the obstacles to the use of the service.  A pharmacy could provide compliance aids (such as easy open containers, reminder charts/alarms, dexterity aids, winged or plain bottle caps) if they decide with the patient, that this will assist the patient to use the service.

HOWEVER – if an adjustment is made, the pharmacist is responsible for the decision.  If the adjustment causes harm, the pharmacist could be liable – for example, providing a reminder chart that the patient is not able to understand, or an MDS which results in incompatibilities or deterioration of the medicines.

 

Q. Where can I find an assessment toolkit?

A. The Department of Health commissioned a resource kit, which appears on the PCC website but is not “officially” a DH or PCC document. The use of this resource kit is not mandatory but might be useful to inform process stages of requests from patients/carers for auxiliary aids.

 

Q. A patient in a care home has requested that we dispense medicines in easy open rather than child resistant containers.  If the home has staff able to assist, is this necessary?

A. If the patient wishes to manage their own medicines, and the arrangements have been made for the patient to retain their own medicines, then this may be an appropriate reasonable adjustment, because it allows the patient to maintain their independence.

 

Q. A patient has severe visual impairment, and has successfully used an MDS tray to be able to take their three medicines which are all similar sizes and shapes, so cannot be identified by touch.  The latest prescription includes two additional drugs - one is hygroscopic and must be dispensed in its original container, and the other is a PRN analgesic, so neither can be put into the MDS tray.  Is it still appropriate to use MDS, if the patient’s medicines are supplied in this plus two other containers?

A. Where the reason for dispensing in MDS is not because of confusion, and alternative methods can be used to allow the patient to identify their medicines correctly, then the MDS remains appropriate.  But, if the purpose of the MDS is because they need the ‘reminder’ of which medicines to take at particular times of day, then supplying other medicines (in this case, the hygroscopic medicine) may be inappropriate, since that may be missed by the patient.  The dispensing of a separate container for PRN medicines may be appropriate alongside the MDS, if the level of confusion is not great, and the patient understands that ‘when required’ medication is in another container.  If the medicines (one hygroscopic to be taken regularly and one to be taken PRN) are excluded from the MDS and the patient has confusion such that MDS is the adjustment necessary to overcome the obstacles to taking the medicines, then there may be confusion over which is the regular medicine and which is the analgesic.  The pharmacist should discuss with the patient, what their needs are, and determine whether the patient’s treatment or safety will be compromised.

 

Q. A housebound patient’s care worker has asked me to dispense the patient’s medicines in a compliance aid i.e. MDS, because the care worker finds this easier and quicker to use than individual manufacturer’s containers.  Do I need to comply with that request?

A. It is the patient’s needs that must be addressed. The pharmacist will need to be satisfied that the request for a compliance aid would constitute a “reasonable adjustment” in terms of actually helping a disabled person to overcome the obstacles to the use of the pharmacy. If so, patient’s medicines are likely to be appropriately dispensed in an MDS.

However, it is not for the care worker to determine the appropriateness of whether to dispense patient medicines in a compliance aid. Care workers tend to be employed to provide care to people (for example in their own homes or in care homes) and are not directly regulated. Though as indicated above organisations employing the care worker are subject to CQC’s regulations and the outcomes which CQC expect people using a service will experience if the organisation is to be compliant with CQC regulations.

In March 2015, the Care Certificate was introduced and is an identified set of standards that health and social care workers must adhere to in their daily working life.  The aim of the Care Certificate is to provide everyone the confidence that care workers have the same introductory skills, knowledge and behaviours to provide compassionate, safe and high quality care and support.  Any person (individual, partnership or organisation) who provides a “regulated activity” in England must be registered with CQC.  As part of registration, CQC expects that those who employ care workers should be able to demonstrate that staff have, or are working towards, the skills set out in the Care Certificate, as a benchmark for staff induction. 

One of the key standards which care workers must adhere to is to understand medication and healthcare tasks (see Care Certificate Standards).  Therefore, if the care worker is engaged to administer medicines, then they must have sufficient knowledge, experience, qualifications and skills to be able to undertake that activity.  The convenience of the care worker could be a valid practical consideration, but this would not be funded under existing NHS arrangements.  If care workers make repeated requests for MDS, try to ascertain why, and if appropriate, consider contacting the care worker’s employer or CQC if you believe that the level of experience, knowledge, qualifications and skills appear inadequate.

Ultimately, it is the pharmacist’s decision as to what is the appropriate “reasonable” adjustment/s for the individual patient, not a care worker or other healthcare professional. 

 

Q. I have decided to dispense a patient’s medicines in an MDS because the patient has a disability, and between us we have determined that the MDS provides the best way of allow the patient to access their medicines.  Unfortunately, due to intolerance of one of the medicines, the GP has prescribed an alternative and has asked that I replace this in the previously dispensed medicines.  Can I do this?

A. Once a medicine has been dispensed, the NHS pharmacy terms of service do not require any further adjustments.  Therefore, unless the GP has instructed the patient to ignore any of the discontinued medicines from the MDS, and is confident that the patient will do this and be able to take the separately dispensed replacements, the whole MDS container should be discarded, and a new one produced.  As the decision to dispense in an MDS was on disability grounds, it is possible that the patient will not be able to handle a separately dispensed item, and if this is the case, there is no alternative but for the GP to issue a new prescription for all current medicines, so that they can be dispensed together in a replacement MDS.

This is wasteful of the medicines already dispensed, and is the reason why GPs may prefer to prescribe on a weekly basis if the patient is likely to have changes made to the medication.

Indeed, pharmacists can charge patients for repackaging (if they are not entitled under the Equality Act) but many pharmacists and GPs have come to a pragmatic solution using seven day prescriptions.  This does not provide any additional funding to the pharmacy – he/she still carries out one dispensing activity per prescription, but now does so four times more often than once a month.  Pharmacies with under-utilised staff may have the capacity to handle seven day prescriptions, but a pharmacy at or near capacity may not be able to safely dispense these additional prescriptions (i.e. these more frequent prescriptions) without engaging more staff.

 

Q. In the Drug Tariff, the practice payment is stated to include 6.6 pence ‘contribution in Practice Payment for EA’.  What is this payment for?

A. In 2005, the funding agreed for the pharmacy contractual framework included a sum towards the

pharmacist’s compliance with the then Disability Discrimination Act (now the Equality Act).  This sum is not distributed specifically for any adjustments made, but is distributed on a flat rate basis, towards any adjustments that the pharmacy makes.  It is therefore towards the funding for easy open containers, large print labels, reminder charts, MDS etc.

 

Q. In that case, would it be right to say that I am funded for providing MDS on request?

A. No.  The funding is towards compliance with the Equality Act.  If a patient requires an MDS because they have a disability, and the MDS is the only reasonable adjustment for overcoming the obstacles to using the dispensed medicines, then that will be funded by the Equality Act element of the practice payment.  It will not cover MDS provided as a convenience, or where the MDS is being used for a purpose other than Equality Act support.

 

Q. Can the GP insist that I dispense a medicine in an MDS?

A. No.  It is the responsibility of the pharmacist to comply with their obligations under the Equality Act and, ultimately, the courts will definitively determine whether the pharmacist has complied with their duty to make “reasonable adjustments”, if challenged.  The final decision whether or not to use MDS for a patient with a disability rests with the pharmacist.

Nevertheless, if a GP is supportive of MDS to provide greater convenience for the patient, or to improve concordance, then the GP could ask if the pharmacist is willing to dispense in an MDS.  Because of the additional costs of equipment and time dispensing in an MDS, particularly on a monthly basis, and the risks of wastage (if medicines are changed), the agreement of the pharmacist may be dependent on the GP prescribing on a weekly basis.

 

Q. The GP has agreed to provide prescriptions on a weekly basis so that I can supply MDS.  He has provided four weekly prescriptions at once – can I dispense all four weekly MDS together?

A. No.  The purpose of weekly prescriptions is to support the supply of MDS containers on a weekly basis, and to minimise waste i.e. if there were to be a change to the patient’s treatment.  Dispensing all four MDS containers at once would defeat the purpose, and likely create unnecessary waste.

 

Medicines Compliance Aid Database launched by UKMi

UK Medicines Information (UKMi) has launched a Medicines Compliance Aid database, which makes recommendations on the suitability of transferring solid dose formulations from the manufacturers’ original packaging into multi-compartment compliance aids (MCAs).

The database, which is open access, makes recommendations based on physico-chemical stability and characteristics of the medicine and formulation, information received from manufacturers, and data (where available) on the storage in MCAs.

The database can be searched by the brand or generic name of the medicine, although most entries will be based on the brand leader.  Once searched, the product is given a traffic light colour-coded UKMi recommendation as to whether it is suitable or not to be placed in a MCA.

UKMi recommend using the database alongside the Royal Pharmaceutical Society’s Guidance Improving patient outcomes through the better use of multi-compartment compliance aids.

 

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Antibiotic Awareness

Antibiotic Campaign – Keep Antibiotics Working

The Keep Antibiotics Working Campaign was launched by Public Health England this month (October 2017) and will run for 8 weeks.  This is a national campaign designed to support the government’s efforts to reduce inappropriate prescriptions for antibiotics by raising awareness of the issues of antibiotic resistance and thereby reducing demand for these medicines from the public. 

Research has shown that inappropriate prescribing of antibiotics is, in part, due to patients expecting or demanding antibiotics, without understanding that they may not be effective for their illness. The focus of the Keep Antibiotics Working campaign is to tackle this lack of understanding and thereby help to reduce patient pressure for antibiotics. 

Please help support this important campaign by:

  • Displaying the “Keep Antibiotics Working” resources in a patient-facing area of your pharmacy (you should have received a poster with your “Stay Well this Winter” campaign pack).
  • You can order additional campaign resources which have been designed for pharmacy use.  This includes a campaign leaflet and checklist poster (images below).  These can be ordered free of charge from the Public Health England campaign resource centre here.
  • Discussing with patients’ key messages about antibiotics not being required for viral infections, the usual cause of most coughs, colds, earache, sinusitis, flu and sore throats. 
 

 

Additionally, if your pharmacy has an information screen / TV monitor in the waiting area, Public Health England has produced the Keep Antibiotics Working TV adverts which are available in both subtitled and sound versions and are in an MP4 format.  These can be viewed via the links below.  If you would like to download the videos, please click here.

Public Health England Keep Antibiotics Working Screen Animation

Public Health England Keep Antibiotics Working TV Ad

 

Other Antibiotic Resources

The South West Yorkshire Area Prescribing Committee (www.swyapc.org) has developed an antimicrobial campaign pack which contains some links to some great resources which pharmacy teams may find useful.  This is available below. 

Antimicrobial Campaign Pack

 

To link in with European Antibiotic Awareness Day (information below) Department of Health have produced a number of MP4 format videos for GP practice/pharmacy screens.  These can be viewed via the links below. 

Don't get prickly if your doctor won't prescribe you antibiotics

Feel like a lame duck?

Looking for a purrfect remedy for your cough

Sick as a parrot?

When you’re ill you’ll do anything to feel better

PHE will you be an Antibiotic Guardian?

 

National and International Antibiotic Campaigns

The dates for these awareness campaigns in 2017 are:

  • European Antibiotic Awareness Day: 18th November 2017
  • WHO World Antibiotic Awareness Week: 13th – 19th November 2017

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Anticoagulation Clinics

Below is a list of anticoagulant clinics in the West Yorkshire and surrounding area.

Anticoagulant Clinics

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Antiviral Medicines

The Department of Health has given authorised primary care prescribers authority to prescribe antiviral medicines for the prophylaxis and treatment of influenza.
 
Full details can be found in the Antiviral Medicines Letter. Pharmacy teams should remember that prescriptions can only be dispensed if the prescriber has annotated it 'SLS'. Pharmacy staff can not make the SLS endorsement themselves. If the SLS endorsement is missing, prescriptions will not be paid by BSA.
 
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The latest edition of the British National Formulary (BNF) is now available.

Pharmacies with one registered Pharmacist will receive a single copy of the BNF, and Pharmacies with two or more registered Pharmacists will receive 2 copies of the BNF. Any Community Pharmacists needing to register to receive copies should contact Binleys by email BNF@Binleys.com or by telephoning 01268 495 609.

Please note that BNF and BNFc content can also be accessed online here. For further information, please visit the NICE website.

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Local CCG Dispensing Policies

Calderdale

Gluten Free Formulary

Gluten Free Guidelines

Coeliac UK List with CCG Formulary Choices

Hayfever Guidance

Children's Pathway for Vitamin D

Key Prescribing Messages Letter

Key Prescribing Messages 2017/18


Kirklees

Flyer for Patients to Outline CCG Prescribing Policies

Hard copies of this leaflet can be ordered from: Dawn.Toothill@greaterhuddersfieldccg.nhs.uk

 

North Kirklees

North Kirklees CCG has commissioned PriDerm to provide community dermatology services.  Community pharmacies may be asked to dispense prescriptions for Isotretinoin and the Pharmacist's Guide to Dispensing Isotretinoin provides information on dispensing Isotretinoin in accordance with the Pregnancy Prevention Programme (PPP).

 

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Pharmaceutical Stationery Orders

EPS tokens and other NHS stationery can be ordered via the Primary Care Support England (PCSE) portal.  Click here for further details of how to register for the portal.

 

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New Rules for Instalment Prescription Endorsement (Methadone)

The endorsement and payment rules have recently changed for oral methadone prescriptions submitted from April 2013.

A prescriber no longer needs to state ‘daily does bottles’ or similar. Pharmacists are able to use their professional judgement as to the most appropriate way to safely supply methadone and will be paid accordingly.   

It is important that all pharmacies are aware of the new rules of endorsement to ensure that they are paid correctly and pharmacy staff should familiarise themselves with the guidance below. 

PSNC Endorsement Guidance for Liquid Methadone April 2013

Changes to Liquid Methadone Fee Arrangements FAQs - March 2013 

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New Requirement for Prescriber Codes on NHS Prescriptions

The changes to the NHS have made it even more important for the Prescription Pricing Authority (NHS BSA) to identify where to charge prescription costs to when it prices prescriptions. Therefore, from 1st April, there is a new requirement to ensure prescriptions contain a prescriber code. 

Failure to do this may result in the return of prescriptions and delayed payment. 

PSNC Guidance on Prescriber Codes

The NHS BSA document Changes to April 2013 Drug Tariff - FAQs contains further information about this and other significant changes made to the drug tariff in April 2013.

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Electronic Repeat Dispensing (eRD)

In our discussions with CCGs we are promoting the use of electronic Repeat Dispensing as we see this as the preferred method of managing the timely and efficient supply of repeat medications to patients.  Electronic Repeat Dispensing enables the prescription collection process to be simplified without compromising patient care, as well as reducing the burden of repeat prescribing on GPs.

If you are in discussions with your local GPs about repeat prescription ordering, we would encourage you to discuss electronic Repeat Dispensing.  The Pharmacy Voice FAQ document includes information on electronic Repeat Dispensing and includes important considerations that GP practices need to think about before implementing.  The document can be shared with practices and can be accessed at:

http://psnc.org.uk/wp-content/uploads/2016/08/Managed-repeats-FAQs-Aug-2016.pdf

 

There is a move both nationally and within West Yorkshire to increase the use of electronic Repeat Dispensing.  Some CCGs are encouraging practices to meet with local pharmacies to discuss the implementation of repeat dispensing and this would be a good opportunity for partnership working and to discuss the logistics of the service. 

Links to useful information / resources are included below.

 

NHS Digital resources 

 

PSNC resources 

 

Information for Calderdale

Calderdale Repeat Dispensing Update Letter - August 2017

Template Letter to GP Practices

 

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Repeat Ordering

The CCGs within West Yorkshire have been discussing stopping community pharmacies ordering repeat prescriptions on behalf of patients.  The rationale given for these changes are concerns about medicines waste and the mismanagement of non-NHS repeat medication services such as “managed repeats”.  Several CCGs have now implemented policies for GP practices to end community pharmacy ordering on behalf of patients with the remaining CCGs seriously considering implementing the policy.

Community Pharmacy West Yorkshire does not support the proposed changes to repeat ordering and have made this position clear to the CCGs.

 

What is happening in your area? 

 

Policy implemented from

Fully implemented by

CCG information available:

NHS Bradford City CCG

1st November 2016

31st January 2017

www.bradfordcityccg.nhs.uk/bradford-city-ccg/be-informed/policies-and-procedures/repeat-prescribing/

NHS Bradford District CCG

www.bradforddistrictsccg.nhs.uk/be-informed/policies-and-procedures/repeat-prescribing/

NHS Greater Huddersfield

September 2016

31st March 2017

www.greaterhuddersfieldccg.nhs.uk/changes-repeat-prescription-ordering/

NHS North Kirklees

www.northkirkleesccg.nhs.uk/news/changes-to-repeat-prescription-ordering/

NHS Wakefield

September 2016

31st January 2017

www.wakefieldccg.nhs.uk/news/prescription-services-in-wakefield-are-changing/


All Leeds CCGs, Calderdale CCG, Airedale, Wharfedale and Craven CCG

These CCGs have not currently implemented a CCG policy for changing the repeat ordering systems within practices.  However, all these CCGs are seriously considering this policy. 


Community Pharmacy West Yorkshire Support

In order that pharmacies can record the impact on patients we have designed a Repeat Prescription Ordering Audit Tool.

Click here to download the tool.

The data from these forms needs to either be faxed to Community Pharmacy West Yorkshire on 0113 3410351 every week OR be added once a week onto PharmOutcomes www.pharmoutcomes.org in the PharmOutcomes Repeat Ordering Data Collection Service.

ACTION- If you wish to record issues caused by changes in repeat ordering policies onto PharmOutcomes please email info@cpwy.org with your pharmacy name, address and ODS code

If you need any support in using PharmOutcomes please contact info@cpwy.org

Use of this audit tool is optional but we will use the information gained to share with the CCGs the level of issues the change is creating for patients and community pharmacy.  Recording this data is not likely to change the GP / CCG policy, however, it will allow us to keep abreast of the level of issues this is causing patients and pharmacies and highlight problems to the CCG.  Pharmacies will not be identified in information sent to the CCG.

 

Keep us informed

If you have any local issues which you would like to raise or you would like help to facilitate discussions, please email ruth@cpwy.org or Ruth 07718 192 287.

For example, if a local GP practice implements an immediate change to the repeat ordering system without giving the pharmacy any notice, or, a GP practice refuses a reasonable request for the pharmacy to order for a vulnerable patient (eg a patient who has medicines supplied in a monitored dosage system (MDS).  Please DO NOT share patient details with us.

 

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Use of Emergency Salbutamol Inhalers in Schools

From 1st October 2014 the Human Medicines (Amendment) (No. 2) Regulations will allow schools to keep a salbutamol inhaler for use in emergencies. 
 
The Department of Health has written guidance for schools which will be of interest as schools are advised to discuss the use of inhalers and spacers with their community pharmacist. 
 
The guidance can be found here.
 
School Inhaler Request Form

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