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CONSULTATION RESPONSE QUESTIONNAIRE

CCoonnssuullttaattiioonn oonn CCrriitteerriiaa ffoorr RReeccoonnffiigguurriinngg

HHeeaalltthh aanndd SSoocciiaall CCaarree SSeerrvviicceess

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CONSULTATION RESPONSE QUESTIONNAIRE

RESPONDING TO THE CONSULTATION

You can respond to the consultation document by e-mail, letter or fax using this

questionnaire. The questions in the Questionnaire Response Form may help you in

providing your views on the Criteria, but are not intended to limit your comments.

If this document is not in a format that suits your needs, please contact us and we can

discuss alternative arrangements.

Before you submit your response, please read Annex A about the effect of the Freedom

of Information Act 2000 on the confidentiality of responses to public consultation

exercises.

Responses should be sent to:

E-mail: Reconfig.criteria@health-ni.gov.uk

Written: Reconfiguration Criteria Consultation

Department of Health

Room C3.6

Castle Buildings

Stormont Estates

Belfast, BT4 3SQ

Tel: (028) 905 20020

Fax: (028) 905 22335

The closing date for responses is 20 January 2017

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PERSONAL DETAILS

I am responding: as an individual

as a health and social care professional

on behalf of an organisation

(please tick a box)

Name: Anne McAlister

Job Title: Representation Manager

Organisation: National Pharmacy Association

Address: Mallinson House 38-42 St Peter’s Street, St Albans, AL1 3NP

Tel: 07538192839

Fax: 01727840858

e-mail: a.mcalister@npa.co.uk

The National Pharmacy Association (NPA) is the body which represents the vast majority of independent community pharmacies (including independent multiples) in Northern Ireland and across the UK. We welcome the opportunity to respond to this consultation.

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Views are sought on Criterion 1:

Criterion 1

There is evidence that the outcomes for patients using these services are below

acceptable levels either in the services as a whole or in particular hospitals, or

where there are safety concerns.

Question 1. Do you agree with Criterion 1 as an appropriate factor to assess the

sustainability of health and social care services?

Yes No If ‘no’ please feel free to comment below, providing evidence to support any

alternative proposal.

If ‘yes’ please feel free to comment further below.

We agree that our health and social care services need to change in order to meet the

needs of the community and promote safe, effective and patient focused outcomes.

Whilst we agree with the Department’s proposals in relation to safety and effectiveness

we ask that this criterion is applied across the service, to include primary care sevices

such as GP and pharmacy services, and not predominantly in the hospital sector as

defined by the wording used.

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Views are sought on Criterion 2:

Criterion 2

There is a clear clinical pathway for the patient population. Co-created with patient

groups.

Question 2. Do you agree with Criterion 2 as an appropriate factor to assess the

sustainability of health and social care services?

Yes No

If ‘no’ please feel free to comment below, providing evidence to support any

alternative proposal.

If ‘yes’ please feel free to comment further below.

The National Pharmacy Association (NPA) supports a health and social care system which ensures appropriate provision of health and social care services for patients, with the best possible patient outcomes. It must therefore be patient centred. It is clear that the current HSC structures have multiple layers and unclear lines of accountability which means that the commissioning system is not working as effectively as it should and clinical pathways can be truncated by bureaucracy between different bodies. We support innovative work delivered by Integrated Care Partnerships1 on the development of clinical pathways in their area and call for this learning to be shared across the wider health and social care system and barriers to scale up and spread are addressed. We are supportive of the development of clinical pathways and within these personalised care plans that would be expected to make a significant contribution to a patient’s care. We believe that successful delivery of the pathways will demand that the Electronic Care Record (ECR) is accessible in parts by relevant HSC professionals to facilitate joint professional working and planning from a service user point of view. As medicines form a significant element of any clinical pathway and care plan we are keen that community pharmacists are provided with appropriate access to this record in a timely manner in order to provide appropriate patient centred care.

1 1 Integrated Care Partnerships, Health and Social Care Board www.hscboard.hscni.net/icps/

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Views are sought on Criterion 3:

Criterion 3

The service cannot meet professional standards or minimum volumes of activity

needed to maintain expertise.

Question 3. Do you agree with Criterion 3 as an appropriate factor to assess the

sustainability of health and social care services?

Yes No If ‘no’ please feel free to comment below, providing evidence to support any

alternative proposal.

If ‘yes’ please feel free to comment further below.

We agree with the Department’s observation that a lack of skilled healthcare

professionals, particularly doctors and nurses, as defined by criterion 3, 4 and 5 are key

factors which contribute to unsustainable services and therefore need to be addressed

in future service reviews. We urge the Department to take an innovative approach to

this, both in the development of services for prevention and early intervention, and the

use of existing skills within the workforce.

3.1 Prevention and early intervention is widely recognised as essential to improving population health and well being and in securing a sustainable health and care system for the future. A range of current national policies, including Sir Michael Marmot’s report on health inequalities (‘Fairer Society, Healthy Lives’ February 2010)1 and the recent DHSSPS consultation on “Fit and Well – A ten year public health strategic framework for NI”2 have given renewed emphasis on the promotion of wellbeing, the prevention of ill health and early intervention. As community pharmacists we consider the case for change in our health and social care services is clear and believe that community pharmacies, sitting as they do where health and social care meet, can make a significant contribution to promoting health and well-being and reducing the burden on existing services

3.2 Community pharmacies are frequently the first port of call for patients when they are unwell and they are also visited by people when they are in good health. Pharmacists and their staff typically see patients more frequently than any other health care provider

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with an estimated 123000 people visiting community pharmacies in Northenr Ireland each day6 This makes them well placed to offer public health advice and support Indeed pharmacists and their teams have been undertaking this role formally and informally for years. Some of the first services commissioned from community pharmacy, in addition to the safe supply of medicines and appliances, were public health services. These include stop smoking and substance misuse services. 3.3 Pharmacies provide services in the heart of neighbourhood communities where they are within reach of the people who need them most– poorer people, older people and people with a disability or chronic condition. In addition to many people who do not have ready access to transport they provide a lifeline and are sometimes the only accessible contact with the Health Service. For many, community pharmacy is the primary source of patient and public information about medicines, the number one healthcare intervention. Those who are not registered with GPs are known to visit community pharmacies.

3.4 The location of community pharmacies has a relationship with deprivation, 164 (32%) of pharmacies are located in disadvantaged areas3. As above, 123,000 adults, equating to 9% population both healthy and sick, visit community pharmacies in Northern Ireland every day. Many of these people are older people, vulnerable or socially disadvantagedi. This provides a significant opportunity for improving services that will further protect or improve the health of the population. Physical accessibility of pharmacies, by virtue of their locations and opening hours, provides a key resource/asset to the community. 3.5 Medicines are the most frequently used health care intervention and pharmacists are the health care professionals who are experts in medicines. We encourage the Department to optimise the delivery of services to promote best use of medicines such as Medicines Use Reviews, Managing your Medicines Scheme, and a roll out of the current Emergency Supply Service pilot, 4 which has successfully reduced the number of requests OOH centres receive for prescriptions of emergency supplies of routine repeat medicines. 3.6 If the Department is to deliver on its vision within Health and Wellbeing 2026 it cannot continue to ignore the potential of community pharmacy to release capacity in GP practices and primary care, and to bring on board much needed additional services from community pharmacies to patients in their local areas. 3.7 We welcome the ongoing work to deliver the Community Pharmacy Strategy

“Making it Better”, in conjunction with the formation of a Pharmacy Alliance for Health

Improvement from HSCB to progress the Health +Pharmacy programme5. We hope

that these proposals for reconfiguring health and social care services, along with these

significant frameworks, and with a new community pharmacy contract from the

Department, HSCB and CPNI, will enable a coherent framework to be developed

around which a wide range of effective community pharmacy services will be delivered.

1. Marmot, M & Wilkinson, R.G. (2006) (eds). The Social Determinants of Health, 2nd

edition.

Oxford: Oxford University Press. Preview available at

http://books.google.co.uk/books?id=x23fpBPC3_gC&dq=social+determinants+of+health&source

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=gbs_summary_s&cad=0

2. http://www.dhsspsni.gov.uk/fit-and-well-consultation-document.pdf

3. DHSSPS Comparison of deprived areas and the Northern Ireland Average for Accessibility

Indicators, http://www.dhsspsni.gov.uk/equality_inequalities_ap4.pdf

4. http://www.hscbusiness.hscni.net/services/2712.htm

5. http://www.hscbusiness.hscni.net/services/2443.htm

6. https://www.health-ni.gov.uk/publications/making-it-better-through-pharmacy-community

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Views are sought on Criterion 4:

Criterion 4

The permanent workforce required to safely and sustainably deliver the service is not

available/cannot be recruited or retained, or can only be secured with high levels of

expensive agency/locum staff.

Question 4. Do you agree with Criterion 4 as an appropriate factor to assess the

sustainability of health and social care services?

Yes No If ‘no’ please feel free to comment below, providing evidence to support any

alternative proposal.

If ‘yes’ please feel free to comment further below.

As per comments recorded under criteria 3

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Views are sought on Criterion 5:

Criterion 5

The training of Junior Doctors cannot be provided to acceptable levels.

Question 5. Do you agree with Criterion 5 as an appropriate factor to assess the

sustainability of health and social care services?

Yes No If ‘no’ please feel free to comment below, providing evidence to support any

alternative proposal

If ‘yes’ please feel free to comment further below.

As per comments recorded under criteria 3

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Views are sought on Criterion 6:

Criterion 6

There is an effective alternative ‘out of hospital’ care model or an alternative ‘shared

care’ delivery model.

Question 6. Do you agree with Criterion 6 as an appropriate factor to assess the

sustainability of health and social care services?

Yes No If ‘no’ please feel free to comment below, providing evidence to support any

alternative proposal

If ‘yes’ please feel free to comment further below.

The NPA believes that there is significant opportunity to take an pioneering approach to the delivery of services and believe that community pharmacists have an important role to play in this. In particular the NPA calls for a greater number of pharmacists to be trained as independent prescribers and work in the community pharmacy setting with access to the patient ECR. We are happy to share experiences of models of care already being delivered in other regions such as community pharmacist’s involvement in delivery of unscheduled and emergency care in Scotland1.

1 http://www.communitypharmacy.scot.nhs.uk/unscheduled_care.html

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Views are sought on Criterion 7:

Criterion 7

The delivery of the service is costing significantly more than that of peers or of

alternative ‘out of hospital’ alternatives due to a combination of the above factors.

Question 7. Do you agree with Criterion 7 as an appropriate factor to assess the

sustainability of health and social care services?

Yes No If ‘no’ please feel free to comment below, providing evidence to support any

alternative proposal

If ‘yes’ please feel free to comment further below.

We are supportive of the Department’s aims to prevent hospital admissions and reduce

overall stays. We believe that community pharmacists have a significant role to play in

this, in particular facilitating safe discharge.

To make certain transitions of care are safer, best practice would involve a full

medicines reconciliation service in the community pharmacy using discharge

information, information on the pharmacy Patient Medication Record (PMR) and the

Electronic Care Record. This would allow for early identification of discrepancies and

prompt action to ensure the patient receives all their prescribed medicines. A Discharge

Medicines Use Review (DMUR) service (similar to that in Wales1) would be appropriate

and would also support patient adherence.

1http://www.wales.nhs.uk/sites3/Documents/498/Discharge%20Medicines%20Review%20Service%20%20Flowcharts.pdf

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Please use the text box below for any additional comments you wish to provide

regarding the proposed Criteria as appropriate factors to assess the sustainability

of health and social care services.

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EQUALITY OF OPPORTUNITY QUESTIONS

The Department aims to advance equality of opportunity for a range of groups in respect

of the proposed criteria for assessing the reconfiguration of Health and Social Care

services. Under Section 75 of the NI Act 1998; nine groups of people are identified and

consideration of their different needs is important. These groups are:

1. Age (older and younger people);

2. Gender (including transgender and men and women generally);

3. Marital Status (including Civil Partnership);

4. Religion;

5. Ethnicity;

6. Political Opinion;

7. Dependant Status;

8. Disability; and

9. Sexual Orientation.

Question 8. Based on belonging to any of the Section 75 groups, do you have any

particular requirements with regard to the proposals?

Yes No

Comments:

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Question 9. Generally, do you think there are any particular requirements for any

of the Section 75 groups? If so, what would you consider as a potential solution?

Yes No

Comments:

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ANNEX A

FREEDOM OF INFORMATION ACT 2000 – CONFIDENTIALITY OF CONSULTATIONS

The Department will publish a summary of responses following completion of the

consultation process. Your response, and all other responses to the consultation, may

be disclosed on request. The Department can only refuse to disclose information in

exceptional circumstances.

Before you submit your response, please read the paragraphs below on the

confidentiality of consultations and they will give you guidance on the legal position

about any information given by you in response to this consultation.

The Freedom of Information Act gives the public a right of access to any information

held by a public authority, namely, the Department in this case. This right of access to

information includes information provided in response to a consultation. The Department

cannot automatically consider as confidential information supplied to it in response to a

consultation. However, it does have the responsibility to decide whether any information

provided by you in response to this consultation, including information about your

identity should be made public or be treated as confidential.

This means that information provided by you in response to the consultation is unlikely

to be treated as confidential, except in very particular circumstances. The Lord

Chancellor’s Code of Practice on the Freedom of Information Act provides that:

The Department should only accept information from third parties in confidence if it is

necessary to obtain that information in connection with the exercise of any of the

Department’s functions and it would not otherwise be provided;

The Department should not agree to hold information received from third parties “in

confidence” which is not confidential in nature;

Acceptance by the Department of confidentiality provisions must be for good

reasons, capable of being justified to the Information Commissioner.

For further information about confidentiality of responses please contact the Information

Commissioner’s Office (or see their website at: www.ico.org.uk)