In the recently published five year pharmacy funding agreement, the Department of Health (DoH) said (amongst other things) that it will help to accelerate a reduction in pharmacy numbers by encouraging pharmacies to close and merge branches. I really hope that the DoH consults on this proposal as there are a number of problems with the current consolidation regulations that can be easily addressed and would help pharmacy contractors whilst also being in line with the DoH's own objectives.
What I would like to see are proposals that would:
- Allow pharmacies that use the new consolidation Regulations to choose which pharmacy’s core hours they keep. At present you have to keep the longer core hours and there is no good reason for this. My suggestion would allow a reduction in the number of 100 hour pharmacies, but would also give NHS England the power to refuse a consolidation if it would adversely affect patients - ie there was no other 100 hour pharmacy around and it was seen as essential.
- Allowing consolidations over long distances as long as no gap in provision is created. This would allow poorly performing pharmacies to be sold to 100 hour operators under the point above rather than closed down and the new owner could reduce operating hours.
- Set a specific number of years during which applications in the relevant area would be refused following a consolidation. This could be tricky to put into writing as it needs to have the "relevant area" defined and we could see ourselves back to defining neighbourhoods again.
These are three fairly small suggestions but they would have a massive impact. The first one would mean that there was a far greater demand from existing 100 hour pharmacies to find a pharmacy that they could buy and consolidate with. Contractors who have seen the value of their businesses significantly reduced would be able to sell them to consolidators instead of just closing down and potentially facing financial ruin. The second one is really important as, at present, both pharmacies involved in the consolidation have to be located in the same Health and Wellbeing Board area. Most contractors wrongly believe that the two pharmacies need to be close together (rather like the relocation rules) and I am quite sure that this has been a major barrier to consolidations so far. There is no reason why the pharmacy that is closing could not be at the other end of the country from the pharmacy that wishes to consolidate with it. As long as the relevant NHS Area Teams agree that there is no gap created in provision to patients then why not allow this? The third one would give those who use the Consolidation Regulations the confidence they need that their investment is worthwhile and all businesses need that.
The DoH doesn't always have to be seen to hurt the interests of pharmacy contractors and our message to them is "You Can Help!"... and it won't cost you anything.