Dispensing doctors with pharmacy contracts will not have to register under the new scheme requiring pharmaceuticals supply chain organisations to provide quarterly purchase invoice information.
The DDA has expressed its gratitude to the Department of Health and Social Care for the speed and pragmatism with which it responded to the DDA’s concerns about the requirements of Health Service Products (Provision and Disclosure of Information) Regulations 2018.
The regulations have been introduced so the Department can gain a better understanding of medicines costs to drive better value for money. It means wholesalers are required to provide information about their purchase and sales to NHS primary care service providers, such as community pharmacies and GPs.
DDA members who operate a pharmacy contract from their premises with a wholesaler dealers licence (WDL) received a letter on July 13 from the DHSC. This requested information about the quarterly sales and purchases of generic medicines, as required under the new regulations. The communication had been sent out to all manufactures, importers and wholesalers of generic and special medicinal products.
In raising the matter with the DHSC, Matthew Isom, the DDA chief executive, explained: “The affected practices have to hold a wholesaler dealers licence (WDL) because they are both a dispensary and a pharmacy contract. Even though the physical space is often the same, they are required to hold the WDL in order that their stock can be moved seamlessly between the two entities.”
Practices are “not selling to anybody; it is simply because of the two legal entities and the need to move the stock between the two,” he emphasised. “The ‘hybrid’ practices are those who are trying to act as a dispensing practice and a pharmacy for all their patients. They need contracts because of the regulations.
“They act as one dispensing outlet as far as patients are concerned. They need a WDL to move stock from one contract to the other. The stock normally does not leave shelf never mind the building during the wholesaling …”
While the regulations do not allow for exemptions for wholesalers, the DHSC has now informed the DDA that if there are no sales involved in the transfer of stock then there is no need to provide information or register with the scheme.
While the Department has said that “there is no need for dispensing doctors with pharmacy contracts to provide quarterly information,” this will be kept under review.