The Society is pleased to respond to the Department of Health's consultation on generic substitution. The English Pharmacy Board (EPB) of the Royal Pharmaceutical Society of Great Britain (RPSGB) does not consider any of the options in the consultation fully acceptable.

Pharmacy has an important role and responsibility in making the best use of NHS resources. Generic Substitution could harness the expertise of pharmacists to help with this. Therefore the Society supports the principle of generic substitution. However, we do not consider any of the three options proposed to be the best course of action to achieve this. Howard Duff, Director of England, said: "The primary purpose of generic substitution should be patient safety. Generic substitution is a professional matter which should be left to the professional judgement of the pharmacist. Under the current proposals there is no opportunity for pharmacists, who are experts in the use of medicines, to be involved in the decision process of when to substitute generically".

The Society is also concerned about the additional workload the proposals could place on pharmacists' who will need to understand how the scheme operates in practice and then explain the process to patients.

The proposals are operationally extremely complex and there is a huge reliance on prescribers to get it right. The EPB have concerns about liability and the potential for misconduct or fraud because of communication failure between healthcare professionals, which needs to be addressed.

This could damage relations between general practitioners and pharmacists at a time when we are encouraging collaboration between healthcare professionals.

There is also scarce information on reimbursement issues within the consultation document. In a situation where the pharmacist chose not to make the generic substitution for the clinical benefit of the patient, it is not clear how remuneration will be addressed.

The EPB conclusion is that these proposals for generic substitution are a short term fix and not a long term solution. We strongly believe that the current proposals could harm both pharmacy / patient and pharmacy / GP relationships and that patient care could suffer and that pharmacists could face financial loss.

To access the full response please visit here.

Source
Royal Pharmaceutical Society of Great Britain

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