New methodology to map controlled localities based on postcode units and Ordnance Survey urban area definitions is being introduced in South East England.
As part of the preparation, practices in Kent have been asked to comment before the end of May on an interactive map showing the newly delineated controlled localities boundaries. This has involved mapping the boundaries to an electronic map on the Health GIS system. There has been some adjustment to best fit the existing boundaries, which were hand drawn in black marker pen ink on paper OS maps, to the postcode unit boundaries shown on the interactive map.
A formal consultation to review the updated boundaries is then expected later this year.
DDA members have expressed concern that the default position will be that many currently controlled areas (ie ‘rural in character’) will be classed as non-controlled (‘urban in character’) despite no significant change having occurred since any previous review was conducted.
One DDA member is aware that his practice’s dispensing area has been affected by the transfer to the new system. “This GIS mapping system is a blunt instrument and cannot replace the local approach that has always been used,” he said.
In addition, Department of Health guidance from 2013 states: “When determining questions of rurality, it is essential that NHS England undertakes site visits.” The DDA points out that this software ‘solution’ will not deliver that and, indeed, could end up generating demands for site visits everywhere.
The formal consultation process will be conducted by NHS England and NHS Improvement South East Region under Section 36(2) of The NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013. This says the NHS Commissioning Board “may at any time consider and determine whether or not any locality, because it is rural in character, is to be, or to be part of, a controlled locality.”
Section 36(3) adds that a review cannot be conducted in relation to an area within five years of the determination of a controlled locality unless “there has been a substantial change in circumstances in relation to that area since the question was last determined.”
While there has not been a whole-of-Kent review since the Regulations were introduced, it is not clear at this stage that whether any more recent pharmacy applications have involved a controlled locality consideration since 2013, or, if they have, whether there would be an exemption from the formal consultation under the five-year rule.
The NHS South East (Kent, Surrey, Sussex) Pharmaceutical Services Regulations Committee has been developing its plans to move to the new methodology for some time. The Local Medical Committee and Local Pharmaceutical Committee were invited to attend the PSRC’s April meeting to discuss the proposals.
The letter to practices and other NHS contractors emailed out on May 1st describes the range of factors used when determining whether a location is rural or not. This has resulted in different methodologies being used nationally “to produce maps to reflect the determination of controlled/non-controlled areas in different parts of the country.”
The letter says the PSRC’s “preferred method [is] to use postcode units (with reference to existing rurality maps, where they exist) to delineate the borders of controlled/non-controlled localities within Kent, Surrey and Sussex.
“We consider that this methodology provides the most accurate, low-level method and uses Ordnance Survey data. The postcode unit is the geography criteria that is used most frequently on a day-to-day basis when dealing with individual patients, thus ensuring transparency and ease of understanding for GP surgery staff and the public when determining where a patient is residing and thus their potential entitlement to dispensing services.”
Practices can view the Health GIS map by logging in with the username NHS_SE and the password WhiteCliffs3040. Layers on the map can be used to show the controlled localities as at December 2018, along with CCG boundaries, the siting of GP practices and community pharmacies, and postcode sectors and postcode units. Details available on each layer include the information source. It is also possible to search by postcode to see whether a locality is classed as rural.
A guide to using the interactive map, sent out with the consultation review letter, points out that using Google Chrome to view the map offers maximum functionality.
Comments “will be considered by the PSRC when determining the controlled and non-controlled status of the areas; we will write out formally with the Committee’s decision and giving right of appeal against the decisions,” says the consultation letter.
The DDA is asking its members in Kent to check the map and submit their comments on the new methodology by May 31st, as well as if any specific local issues have been identified. The DDA is also raising the matter with the GPC.