Brexit: An Update on our Contingency Planning

Friday, December 7, 2018

This update is intended to provide a little reassurance over some of the news coverage that our community pharmacy teams may have seen today (December 7th) on Brexit contingency planning.

As this is a reserved matter, it is the UK Government which is putting any contingency plans into place and there will be no divergence on plans implemented in Scotland.

In preparation for a no-deal scenario, the Department of Health and Social Care (DHSC) has already advised that a six-week stockpile of prescription medicines should be held in the UK by manufacturers – this advice has already been widely publicised in the media. Beyond this, the DHSC has been consulting on other measures which may be necessary to ensure the adequate supply of medicines to those who need them in the UK.

A concern of the community pharmacy sector as a whole is how we can work together to manage any shortages of medicines which could occur as a result of a no-deal Brexit.

The current proposal is to introduce a ‘serious shortage protocol’ which would enable pharmacists (and other dispensers) to dispense an appropriate alternative prescription in the event of a serious national shortage of medicines. This alternative supply would be done on the basis of the pharmacist’s professional judgement and would not require contact with the GP who wrote the original script.

DHSC Priorities

The Department of Health and Social Care has identified two areas which would require a change to legislation as they are part of the Human Medicines Regulation 2012, these are:

  • The introduction of a national ‘serious shortage protocol’ to provide dispensers with more flexibility in case of serious shortages of POMs, to be introduced whether there is a Brexit deal or not; and
  •  An amendment to the Human Medicines Regulation 2012 to allow regulation making powers, to safeguard the continuity of supply in case of a no-deal (this change is required as the current regulation making powers come from EU legislation).

Speculative Shortages and Medicines Pricing

CPS is also concerned about the potential impact of Brexit on medicines pricing and the ability of pharmacies to source medicines below or at Drug Tariff prices.

As well as potentially impacting on patient safety and care, a dramatic increase in medicines shortages and price increases could overwhelm the capacity of the price adjustment system in Scotland, causing delays in adjustments being granted.

If medicine prices increase significantly post Brexit, there could be a huge impact on individual pharmacies which dispense large volumes of any affected lines, particularly where the difference between purchase price and reimbursement price is significant. CPS is concerned about the impact that shortages on a significant scale could have on pharmacies’ cashflow and workload at a time when many pharmacies are already under significant pressure.

To help to mitigate against some of these risks, we are committed to continuing to work with stakeholders in Scotland and the UK such that:

  • measures to ensure that community pharmacies have quicker and clearer reimbursement and stock availability information are put in place;
  • A review of the resilience of the adjustment pricing system so that pharmacies can ensure the supply of prescription drugs to patients; and
  • reimbursement for pharmacies of any additional costs incurred to help them to cover their costs and continue to offer the full range of patient services.

To help manage speculative shortages, we would like Department of Health and Social Care to use the new Information Disclosure Regulations to monitor and communicate stock availability issues to pharmacies so that timely interventions can be made to minimise delays in procurement.

We also suggest that the Department of Health and Social care could relax the restrictions on pharmacy-to-pharmacy wholesale dealing without wholesaler dealers licenses. This would allow pharmacies to trade stock between them at a local level, helping to allow medicines to reach those patients who most need them without regulatory barriers.

We are pleased that DHSC is now consulting on legislative changes which, in the event of a no-deal Brexit, would assist with implementing many of the measures that we have suggested. We will continue to work closely with them and our sister organisations across the UK on the detail of that and we have committed to assisting their work in the event of there being a significant impact on the medicines supply chain after Brexit.

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