Recent comments from Keith Ridge, England’s chief pharmaceutical officer, and the much publicised open letter of 17 December 2015 to the Pharmaceutical Services Negotiating Committee (PSNC), the negotiating body for community pharmacy contractors in England, suggested the future of pharmacy lay with an online model — for example, “large-scale automated dispensing, such as hub and spoke”, or ‘click and collect’ models with home delivery. Alistair Burt, minister of state for community and social care, followed this by suggesting there are too many pharmacies and up to 3,000 may close as a result of the funding cuts outlined in the letter.
The rise in pharmacy numbers from 9,748 in 2003 to 11,674 in 2015 is in part because of the increase in applications for 100-hour and, more recently, internet or distance selling pharmacies. But do these distance selling pharmacies enhance patient care and pharmaceutical services?
The application process for a distance selling pharmacy requires applicants to agree to provide the full range of essential services during opening hours across the whole of England in response to a patient request, but without face to face contact and at no cost to the patient. In addition, there should be nothing to suggest that these essential services are only for particular geographical areas or for specific categories of patients (for example, those in care homes).
All pharmacies are required by the clinical governance requirements for community pharmacy, published by the PSNC and NHS Employers in 2012, to publicise the essential services and any advanced services that are available at or from the pharmacy premises, produce a practice leaflet, and publish the results of their annual ‘Community pharmacy patient questionnaire’.
From 1 July 2015, the Medicines and Healthcare products Regulatory Agency (MHRA), the UK medicines safety regulator, requires all distance selling pharmacies supplying pharmacy, general sales list or prescription-only medicines on the internet to apply to the MHRA and display the EU common logo on each page of their website.
According to the MHRA, a “retail seller of medicine online cannot legally trade without the EU common logo” and “it is an offence not to display the EU common logo”. The guidance from the General Pharmaceutical Council, the UK pharmacy regulator, for distance selling pharmacies also requires them to display this logo on their websites.
A search on the NHS Choices website for internet pharmacies reveals 169 internet pharmacies, 5 of which had no website listed and 36 of which had websites were not functioning or were “under construction”. Many of these are operating without the EU common logo. There are many more internet pharmacies that are not even listed on NHS Choices.
So how can a distance selling pharmacy satisfy their NHS contractual requirements without a fully functioning website and continue to operate a website without the EU common logo?
It may be suggested that a substantial number of distance selling pharmacies made false claims on their original applications and have no intention of providing a national service. They may have been set up to provide a local service or services for specific categories of patient (for example, dispensing monitored dose tray systems to care homes) in direct contradiction their NHS contract applications.
Far from enhancing pharmaceutical service provision to patients, “internet” pharmacy applications may pose a risk to the existing community pharmacy network by seeking to circumvent the regulations and provide pharmacy services to a specific geographic area in direct competition with local ‘bricks and mortar’ pharmacies.
The inference from Keith Ridge that automated distance selling pharmacies are the future is also at odds with recent publicity surrounding an online pharmacy that not only sold patient data to a third party but subsequently failed to dispense patient medicines for a three-week period over Christmas and New Year 2015–2016.
Despite the numerous rules and standards that have been issued in regard to the provision of medicines “at a distance”, there seems to be little appetite from NHS England or pharmacy regulators to ensure that they are properly applied.
Community pharmacists, Lincolnshire