Dear Colleague,
The emergency supply during a pandemic service, permissible under Regulation 226 Human Medicines Regulations (HMRs) 2012, commenced on Monday 6th April 2020 and operates during all the pharmacy’s opening hours.
Emergency sale etc by pharmacist: pandemic diseases
HMR Reg 226.—(1) Regulation 214 (1) does not apply to the sale or supply of a prescription only medicine by a person lawfully conducting a retail pharmacy business if conditions A and B are met.
(2) Condition A is that the supply is made whilst a disease is, or in anticipation of a disease being imminently,—
- (a) pandemic; and
- (b) a serious risk, or potentially a serious risk, to human health.
(3) Condition B is that the pharmacist by or under whose supervision the prescription only medicine is to be sold or supplied is satisfied—
- (a) that treatment with the prescription only medicine has on a previous occasion been prescribed by a relevant prescriber for the person to be treated with it; and
- (b) as to the dose which in the circumstances it would be appropriate for that person to take.
It is for the responsible pharmacist to use their professional judgement, based on the above regulations, to decide if and when a supply should be made, the length of supply, and if it’s in the patient’s best interests.
The service aims to ensure that patients can access an urgent emergency supply of their regular prescription medicines, where reasonable steps have been taken but they are unable to obtain a prescription. As the most accessible healthcare professionals, community pharmacists are ideally placed to help support vulnerable patients during this COVID pandemic. The service also ensures equity of access to medicines irrespective of the patient’s ability to pay, helping address health inequalities in the local community.
Contractors should be aware that the emergency supply provisions previously available under Regulations 224 and 225 are still in place and, where supply under 226 (outlined above) is not applicable, consideration may be given to using 224 or 225 (remembering the associated requirements on supply and on record keeping).
When can a supply be made?
If a patient/representative presents at the pharmacy, requesting an urgent supply of their regular medication which they are short of, after reasonable steps had been taken to obtain a prescription, a supply through the service can be made. There may be instances where there has been a delay in the GP surgery printing the prescription or during collection by the pharmacy.
It is vital your patients, especially those who should not miss doses of medicines, such as patients with epilepsy, continue to receive a supply of their medicines and the emergency supply during a pandemic service is available to support that.
The HSCB has produced an FAQ document to support the service which is available at: http://www.hscbusiness.hscni.net/services/3135.htm
As with all new services there may be some operational issues and we are aware that some GP practice staff are querying some instances of when medicines were provided to patients under ESS. If you are having issues with individual GP practices, in relation to the service, please contact your local HSCB office to discuss. Similarly, if you have any further queries about the service or are unsure about when the ESS can be used please do not hesitate to contact Kerry Grimes kgrimes@communitypharmacyni.co.uk.
Feedback
The service is a great opportunity to demonstrate how community pharmacists have the clinical expertise and are best placed to support patients, especially those most vulnerable, in a professional manner. To illustrate its value and the positive impact on the patient and the wider health service, we are keen to gather community pharmacy case studies, particularly again in respect of those in vulnerable groups.
When a patient has received their medication through the service, it would be helpful to get some patient feedback. What did they think of the service? Did they find it efficient/useful? Would they wish to see the service continue? To demonstrate its value, the pharmacist could encourage the patient to let a local MP/MLA know how beneficial it was, particularly during this time of crisis.
This feedback and information gathering is vital to help support CPNI in future service development.
If a patient has accessed the service and would be interested in talking about their experience, please get in touch with Jude Austin – judea@communitypharmacyni.co.uk or call the CPNI office on 028 9069 0444.
Yours sincerely
SENT FOR AND BEHALF OF GERARD GREENE | Chief Executive