The Pharmaceutical Services Negotiating Committee (PSNC) has published a guidance for community pharmacies to help them in the implementation of the new Prescription Prepayment Certificate (PPC) for hormone replacement therapy (HRT).
The new policy will rollout from 1 April 2023, patients who are not already exempt from NHS prescription charges will be able to purchase an annual HRT PPC for the cost of two single prescription charges
Major concern raised by PSNC is that the NHS systems have not kept pace with policy, as the certificate is launching without the IT in place to support it.
PSNC has been clear that this is totally unacceptable, including raising this with Ministers directly and warning them that introducing the PPC without this infrastructure risks causing confusion for some patients and adding to the burden for pharmacy teams.
“Government recognises the challenges but is determined to move forwards with the policy, said the committee. “DHSC has recognised the impact this will have on pharmacies and we are still pressing for appropriate financial compensation. We have also sought guidance for GPs, and now published our own guidance to try to make the launch go as smoothly as it can for pharmacy teams.”
Ahead of the launch of the HRT PPC, PSNC Chief Executive Janet Morrison said: “The HRT PPC being introduced by Government next month is a positive development for patients – indeed, we argued that these medicines should have been made available for free – but NHS systems have not kept pace with policy, meaning the certificate is launching without the IT in place to support it.
“This is totally unacceptable: community pharmacies cannot on the one hand be subjected to funding cuts, but on the other hand be expected to keep picking up the pieces when DHSC and the NHS launch policies without having the infrastructure in place to effectively implement them.
“We have warned Ministers directly – both by writing to them and in meetings – that rolling out the HRT PPC at this point risks causing confusion for some patients and that it will add to the burden on pharmacies, but to no avail. Government recognises the challenges but is determined to move forwards with the policy.
“DHSC has recognised the impact this will have on pharmacies we are pressing for appropriate financial compensation for pharmacy owners. We have also sought guidance for GPs, and now published our own guidance to try to make the launch go as smoothly as it can for pharmacy teams.”
Key Issues Identified by PSNC
As a consequence of its limited scope, a patient with an HRT PPC will continue to pay the prescription charge for any other (non-HRT) medicines (unless another exemption reason applies). While GPs will be required to write HRT items on separate prescriptions, on occasion both an HRT medicine and another item will be prescribed on the same prescription – a ‘mixed’ prescription. This presents a problem for a patient who has an HRT PPC and the for the pharmacy because a prescription cannot be processed as both ‘exempt’ and ‘paid’ within the NHS prescription processing and pricing systems, explained PSNC.
Regulations have been put in place seeking to avoid such ‘mixed’ prescriptions and to give options to contractors/pharmacist facing ‘mixed’ prescriptions presented by patients with an HRT PPC. DHSC is advising pharmacies to refuse to dispense ‘mixed’ prescriptions to patients with an HRT PPC, unless the patient needs one or more of the prescription items urgently.
“This may be appropriate due to the problems and potential financial risks with processing of ‘mixed’ prescriptions for patients with an HRT PPC.”
PSNC warned the DHSC at the earliest opportunity that suppliers need advance notice to better fit new IT development plans into their roadmaps. The Government’s digital solution involves prescribing systems automating the issuing of listed HRT medicines as single-item prescriptions, but DHSC has not yet confirmed the associated completion timescales.
PSNC remains concerned that ‘mixed’ prescriptions may continue for some time. DHSC has also recommended development work on PMR systems be completed ahead of HRT PPC implementation date of 1 April 2023 to introduce HRT PPC categories within PMR systems.
“As guidanace passage 6.1 (quoted above) makes clear, the Department recognises that there will be associated costs for pharmacy owners until IT solutions are in place. We are in discussion with them about appropriate financial compensation for this.”
