Having read all 79 pages of the OFT Report on the regulation of Pharmacies I have found significant dangers in it for dispensing doctors as dispensing doctors but advantages to them should they wish to open pharmacies.   

The danger comes in Chapter 5 paragraph 8:

"in rural areas where there are no pharmacies GPs can dispense prescriptions and we would expect this to continue.  However, the "prejudice" test in England and Wales which dispensing doctors may use to object to the entry of some pharmacies acts as a constraint on competitive supply.  this should fall away together with regulations establishing the "controlled areas" to which the test applies."

This makes the much disputed "loophole", which some people used to wreck the DDA, small beer indeed.    Should the Report be agreed unchanged by government the possibility, if not probability, is that chemists will flood into rural areas and then demand the Essential Small Pharmacy Allowance for survival.    Elsewhere the Report emphasises the existence of the ESPS as a means of supporting pharmacies which may become uncompetitive following deregulation.

The rest of the relevant and interesting parts of the Report

Chapter 1, para 22 (1.22)
"Moreover, in areas where there are no NHS dispensing facilities, dispensing by GPs offers a further mechanism to ensure appropriate access to prescription medicines.  We would expect this important safeguard to be maintained under the de-regulation of community pharmacists".

As DD's will have seen from 5.8. above, they should not raise their hopes too high.  There is to be no protection mechanism just because they are dispensing doctors.

1.25
"We recommend that the control of entry regulations for community pharmacist in the UK should be ended.  This would mean that all registered pharmacists with qualified staff may dispense NHS medicines"

It would also mean that all dispensing doctors, or any other doctor, who employed a registered pharmacist and qualified staff would be able to continue to dispense or start to dispense.  The costs to the existing dispensing practice would be around £42,000/year more (see below).   

This does mean that any dispensing practice who fears or foretells a threat from an incoming pharmacy should be in a position to open its own pharmacy company also without regulation.  What's more, the practice will already have the premises and simply needs an unemployed pharmacist to run it as their employee.

2.12
Statistics:
There are 22,300 pharmacists of whom 12,125 (57%) dispense NHS prescriptions.

2.13
Of these there are:   9,765 in England, 1,141 in Scotland, 706 in Wales and 512 in Northern Ireland.

2.14
That is:   1:5000 people in England; 1:4,400 in Scotland;  1:4,100 in Wales and 1:3,300 in NI.

2.16
Market share:

The number of chains of 5 or more has risen over recent years from a third to half.

2.19
Dispensing Doctors
In 2001 there were 1,565 dispensing practices in the UK:

2.29
The combined market for all retail pharmaceutical products (POMs, OTCs) is not less than £8.6 billion.
The Report is under the misapprehension that DDs cannot sell OTCs.  They may not be doing so but they can - and should.
There are 340 pharmacies claiming the ESPS allowance.

3.13
The dispensing regulations are described together with a mention of the loophole (not by name) mechanism.

3.29
Some research has been carried out into the cost to pharmacy of obtaining an NHS contract to dispense prescriptions.   The figure is put at £0.5million, as a quote from ASDA.   So DDs who are approached in future by chemists now have a ball-park figure.  Further details in Chapter 3.

3.34
"The cost of employing a pharmacist or locum can be £42,000/year"

5.8
This is the danger paragraph mentioned earlier.

The greater part of the Report is of no real direct interest to dispensing practices as it deals with the minutiae of pharmacy and why community pharmacy will not be affected by deregulation.

Comment
Superficially and listening to the many news reports there would seem to be nothing but advantages to dispensing practices but as seen above there are just as many, if not more, dangers than there are to pharmacies if the practices do not seize the opportunity provided.

Putting it simply, deregulation means just that.   Any pharmacy company, even if owned by a doctor, would be allowed to open a pharmacy anywhere - and that includes rural areas.

Some may wish to join with the pharmacists in putting in objections to the Report.    Sadly, the DDA and the BMA did just that.

The multiples won't be too upset because they will see just as many opportunities as disadvantages.  Those opportunities will be in rural areas where they can usurp dispensing practices at a whim.   The supermarket chains are very pleased with it because it says what they want it to say.   As for the small, independent chemist, then he, too, will now turn his eager gaze on rural areas in an attempt either to survive or to empire build.

One thing all dispensing doctors can be sure of if the government accepts the OFT Report is that all the brown-nosing and cosying up of Ward, Tennant and friends of the DDA Ltd to the chemists over past years will not stop a single chemist, large or small, ripping in to any dispensing practice their gleaming eyes settle upon.   Ward and the cabal were wrong in 1997 when they wrecked the original DDA and they are wrong now and chickens are coming home to roost at the expense of the dispensing doctors they claim to support.

The DDA Ltd's misguided attempts to change the present regulation, in cahoots with the chemists, to throttle market town dispensing applications look like being still-born if the Report is adopted by government.   And we can all be thankful if that idiocy comes to naught for it is that kind of practice which should grasp the opportunity (unless the DDA Ltd's efforts have not already treacherously prevented them).    The market town practices should be large enough to employ a pharmacist and staff to be able to set up their own, in-house pharmacy.   If the Report is adopted they should grasp the opportunity immediately.

The small country practices will have to keep their ears wide open for signs of an ingress and be prepared to form a pharmacy company and call for the Essential Small Pharmacy Allowance to make it viable.

If any dispensing practice is in need of help, please contact me, David Roberts, directly, as described above under the title - or through Feedback.  I would be delighted to attend meetings of groups of dispensing doctors or even single practices.

David Roberts
17/1/03

Amended 23/7/03

Government response to OFT Report, July 2003