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OFT pharmacy competition proposals

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UKHRA response to OFT competition proposals

To Peter Dunlevy, Department of Health (07/03/03)

Dear Peter,

The main problems concern syringe distribution and exchange and methadone dispensing should there be a shift from community pharmacy shops to supermarket pharmacies.

Please forgive this hurried response and I hope an email will suffice in lieu of a letter

Syringe distribution and exchange
The majority of the 30 million or so syringes used by injecting drug users are obtained from pharmacies. Many areas rely heavily on community pharmacies for delivering needle/syringe schemes and we need to increase activity not restrict access.

Our modelling of HCV (at Imperial College) indicates that syringe distribution needs to expand significantly in order to have an impact on HCV incidence. A major concern must be that pharmacists relocated into supermarkets will restrict access. It is unlikely to be a priority in any business plan to increase the number of drug users using supermarket based pharmacists. Any reduction in local availability is likely to result in increased inconvenience to drug users which is unlikely to be offset by increased opening hours. Has OFT and DH considered the impact on needle exchange activity and public health in its exit scenario modelling? If the proposals are accepted, what provision can be made to preserve local supply and exchange of needles and syringes?

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Methadone and other substitution treatment
NTA estimates that there are about 85,000 people getting methadone prescriptions, mostly from community pharmacies. Some of these prescriptions will be dispensed for consumption supervised on site by the pharmacist. A major concern is that supermarket pharmacies may be unwilling to dispense methadone. Apparently this happens already with some community pharmacies.

Will there be provision for all pharmacies including supermarkets to dispense all NHS prescriptions? Para 1.25 of the OFT report states "this would mean that all registered pharmacies with qualified staff may dispense NHS prescriptions." - it does not say that they 'shall' do so. We need to clarify whether or not this means that pharmacists will have a choice over which prescriptions they choose to dispense.

Currently under the NHS contract they have to dispense all NHS prescriptions. Supermarkets will not want to increase the number of drug users using their facilities solely to obtain prescriptions, often on a daily basis, and not purchasing other products within the shop. Given that the NTA target is to get 100% more drug users into treatment by 2008, this could mean a considerable increase numbers using these facilities. And what will happen with supervised consumption? Given that the NTA is pushing for increased use of supervised consumption the proposals may have a major impact on acceptability to drug users and their privacy.

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It is hard to imagine that supermarkets would be willing to allow supervised consumption. And whilst the longer opening hours of supermarkets may make it easier for some patients to collect methadone, there will for some be the problem of access, particularly if a visit to a supermarket is only possible by private transport.

I could, given more time. back up these points with more data on syringe distribution and methadone - but you probably have this in any case from within DH and the NTA.

Our HIV, HBV and HCV prevention and our drug treatment strategies rely heavily on the participation of community pharmacists. It has often taken local drug services many years to establish good working relations with community pharmacies and to persuade them to deliver services to drug users. It would be a pity if much of that was destroyed for the sake of a notional saving to consumers of about £30 million a year. Indeed, there might be considerable costs to offset against this and borne by government in making alternative arrangements for delivering the above mentioned parts of the drug strategy.

With regards

Gerry

Prof Gerry Stimson
Department of Social Science and Medicine
Faculty of Medicine
Imperial College School of Science Technology and Medicine
Reynolds Building
St Dunstan's Road, London W6 8RP
Telephone: +44 (0) 20 7594 0776
FAX: +44 (0) 20 7594 0852

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