Distance Selling Pharmacies (DSPs)
GMLPC Services Guide for Distance Selling Pharmacies (DSPs)
As always, we are keen listen to and help our contractors in any way that we can and tailor our support to target the current issues being faced.
Feedback gathered earlier in the year has indicated some contractors are unsure at to which services can be provided by a Distance selling pharmacy.
With this in mind, GMLPC have collated the relevant information and created an easy-to-use briefing guide for DSP contractors.
1. A distance selling pharmacy must not provide Essential services to a person who is present at the pharmacy, or in the vicinity of it. In addition, the pharmacy’s SOPs must provide for the Essential services to be provided safely and effectively without face to face contact with any member of staff on the premises. NHS England could ask for sight of the SOPs when considering an application to satisfy itself that the conditions will be met.
A distance selling pharmacy receives a prescription via post and dispenses it the next day, sending it via courier. The pharmacist telephones the patient to counsel the patient on the medicine’s correct use. This arrangement satisfies the conditions as no face to face contact has taken place on the pharmacy’s premises.
A distance selling pharmacy returns a prescription to the patient saying that because it orders a controlled drug, the pharmacy will not be able to dispense it. In this case, the pharmacy is in breach of the terms of service which requires all pharmacies to dispense any drug that is ordered, ‘with reasonable promptness’. NHS England could issue a breach notice, could order a withholding of remuneration, and could in some circumstances remove the pharmacy from the pharmaceutical list.
2. A distance selling pharmacy may provide Advanced and Enhanced services on the premises, as long as any Essential service which forms part of the Advanced or Enhanced service is not provided to persons present at the premises.
A distance selling pharmacy receives a prescription and dispenses it the next day, sending it via post with a consent form and explanatory leaflet about the New Medicine Service, inviting the patient to contact the pharmacy. The patient lives locally and so makes arrangements to visit the pharmacy, to complete the NMS. The pharmacy would need to be very careful not to provide or offer to provide any of the Essential services whilst the patient is at the pharmacy. The patient brings some unwanted medicine back to the pharmacy at the same time as attending for the NMS consultation. The pharmacy is therefore in a dilemma, as accepting the waste at the pharmacy would breach the conditions.
3. The pharmacy’s procedures and SOPs must allow for the uninterrupted provision of Essential services during the opening hours of the pharmacy to anyone in England who requests the service. NHS England could ask for sight of the SOPs, during the application process, to ensure that adequate arrangements have been made to satisfy this condition.
A distance selling pharmacy provides NHS England with a SOP detailing how the pharmacy will receive prescriptions from a drop box in the local GP’s practice, and will have an advice hotline which will operate between 5-6pm during the week. NHS England refuses the application on the grounds that only patients who are local to the GP surgery will be able to send prescriptions, and the advice hotline (and so the Dispensing, Signposting and Support for Self Care essential services) will only operate for a proportion of the pharmacy’s core hours.
4. Nothing in any written or oral communication such as a practice leaflet or any publicity can suggest, either expressly or impliedly, that services will only be available to persons in particular areas of England, or only particular categories of patients will (or will not) be provided for.
A distance selling pharmacy publishes a leaflet which states ‘Our delivery vans are available within a 25 mile radius. We can arrange for delivery by post outside this area, but cold chain products, such as insulin cannot be sent this way’. The pharmacy is likely to be found in breach of the conditions, as patients with diabetes requiring insulin who live outside the area would be unable to obtain their prescriptions from the pharmacy.