Last day to tell NHS England to drop plans to stop NHS prescriptions for over the counter items.

Update 13 August 2018 

Following the public consultation on stopping NHS prescriptions for over the counter items, NHS England seems to have fudged it by stopping short of an outright ban on GPs prescribing so-called over-the-counter medicines for 35 conditions described as minor and short term. Instead it has issued guidance to Clinical Commissioning Groups to curb these prescriptions.

A Briefing from the Barnsley Local Pharmaceutical Committee sent to Barnsley Save Our NHS gives reasons why we need to respond to the National consultation on stopping NHS prescriptions for over the counter items. Today (14 March) is the last day to do this.

Stopping NHS prescriptions for over the counter items might seem like a simple way to save the NHS £136m/year-  but it risks putting people on low incomes into medicine poverty and it undermines the key NHS principles that treatment is for everyone who needs it, free at the point of need, and based on clinical need not ability to pay.

While pharmacists don’t think much of NHS England’s proposals, the UK Trade Association of the manufacturers of branded over-the-counter medicines, self care medical devices and food supplements that can be sold without a prescription at pharmacies or retail outlets such as supermarkets and convenience stores,  has jumped on the bandwagon. Is this really in patients’ best interests?

Information about the consultation is on the NHS England website.

Here is the link to the online consultation which CLOSES ON WEDNESDAY 14th MARCH.

PLEASE read the Briefing (below) before filling in the consultation, as at first sight it may seem just a common sense measure to save money. However things are more complicated than it may seem, and there are several likely unintended consequences.

Overview

This is the last day of NHS England’s public consultation on reducing prescribing of over-the-counter medicines for 33 minor, short-term health concerns.

In the year to June 2017, the NHS spent approximately £569 million on prescriptions for medicines which can be purchased over the counter from a pharmacy and other outlets such as supermarkets, in order to treat conditions that:

  • are considered to be self-limiting and so do not need treatment as they will heal of their own accord;
  • lend themselves to self-care, i.e. the person suffering does not normally need to seek medical care but may decide to seek help with symptom relief from a local pharmacy and use an over the counter medicine.

Vitamins/minerals and probiotics have also been included in the consultation proposals as items of low clinical effectiveness which are of high cost to the NHS.

Of the £569 million,  24% (£136m) has been identified as a potential saving.  This implies that the government believes that the majority of prescribing for these conditions is already appropriate.

Set against this projected £136m saving,  unintended consequences of restricting prescriptions could increase costs to the NHS,  so a financial impact statement is needed (see section below: Unintended consequences require financial impact assessment).

NHS England has partnered with NHS Clinical Commissioners to carry out the consultation after Clinical Commissioning Groups asked for a nationally co-ordinated approach to the development of commissioning guidance in this area to ensure consistency and address unwarranted variation. The intention is to produce a consistent, national framework for Clinical Commissioning Groups to use. Subject to the outcome of the consultation, the commissioning guidance will need to be taken into account by Clinical Commissioning Groups in adopting or amending their own local guidance to GPs in primary care. The consultation aims to provide information about the proposed national guidance and to seek the public’s views about the proposals.

NHS England’s proposals are to advise Clinical Commissioning Groups to support prescribers in advising patients that specific items should not be routinely prescribed in primary care if they fall into these categories:

  • limited evidence of clinical effectiveness.
  • the condition being self-limiting, so it will clear up on its own without the need for treatment.
  • the condition being appropriate for self-care.

Comments- please read before filling in the consultation

Everyone would agree that NHS resources need to be used wisely and where treatment has no clinical evidence or is unnecessary then it can be safely eliminated.

For drugs of limited clinical effectiveness and self-limiting conditions the proposed exceptions are acceptable, although there needs to be better public education about when a condition is no longer self-limiting.

There are no routine exceptions for any of the conditions suitable for self-care, which means a prescriber has to consider whether a prescription is necessary or not, which is surely what should already happen in any consultation.

The difference now is whether the prescriber believes that the patient has sufficient funds to treat themselves. This is subjective, divisive and at odds with the three core principles of the NHS :
·         that it meets the needs of everyone,
·         that is be free at the point of delivery,
·         that it be based on clinical need, not ability to pay

The foreword suggests that NHS England has taken account of the need to reduce inequalities between patients in access to, and outcomes from healthcare services and to ensure services are provided in an integrated way where this might reduce health inequalities.

This does not seem to be borne out by the proposals.

The proposals may well lead to medicine poverty.

As there is an existing correlation and potentially causation between income and health inequality, this proposal will make that situation worse, since  self-care comes at a cost to the patient.

There should be consideration of the socio-economic aspects of the proposal.

In The Equality Act 2010 the Government decided not to include a provision of a public sector duty regarding socio-economic issues and therefore this proposal is unlikely to affect any protected groups. It will however affect a large number of people who are not covered by the Act but are currently facing food poverty and fuel poverty. This proposal may well lead to medicine poverty.

Patients who make an appointment to see a GP do not consider their condition to be a minor illness. They seek advice on a condition that is causing them physical or mental distress. The expensive part of the process is the GP consultation, not the drug cost. Limiting the choice of available medication for the GP will not reduce the number of appointments.

The proposals would lead to decommissioning Minor Ailment Schemes

Limiting the prescribing for the specified conditions will however lead to CCG’s decommissioning local Minor Ailment schemes (MAS); some already have done so of the back of this consultation.

Unintended consequences require financial impact assessment

The decommissioning of MAS will divert some patients away from seeking help at the pharmacy and back to the GP surgery – the opposite of what this proposal intends.

Appendix 3 already acknowledges other unintended consequences such as increased A&E attendance and prescribing more potent medication – but there has been no financial impact assessment included in the consultation.

Additional comments – The guidance as it stands legitimises restrictions to prescribing so that access to medicine is based on ability to pay and not clinical need.

The general exceptions would allow a prescriber to continue to prescribe where they believe the item to be appropriate. The guidance appears to have been developed for Clinical Commissioning Groups that wish to restrict prescribing so that it’s based on ability to pay and not clinical need. The guidance as it stands legitimises that position which is against the core principles of the NHS and allows Clinical Commissioning Group medicine management teams to apply pressure on prescribing budgets and cut Minor Ailment Schemes.

Here’s a sample response to the online consultation, for info.

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