Consultation Responses

CPW will respond to consultations, such as Welsh Government or General Pharmaceutical Council consultations, where the outcome of the consultation could have an impact, of any kind, on the delivery of the community pharmacy contractual framework or the viability of the community pharmacy network.  CPW will also respond to any consultations where there is an opportunity to make a case for a greater contribution from community pharmacy. Responses to consultations are listed below: 

The Standards for Competency Assurance of Non-Medical Prescribers in Wales consultation. 
CPW responded to this pan-professional consultation from HEIW on the evidencing of competencies for non-medial prescribers in Wales.  A copy of the CPW response can be accessed here.


Hub an Spoke Dispensing
 
The Department of Health and Social Care on behalf of the four home nations has consulted on proposed changes to legislation to allow hub and spoke dispensing between different legal entities.  CPW’s response to the consultation can be found here.


Developing a strategic mental health workforce plan for health and social care.
 
HEIW have consulted on the potential of developing a multi-professional workforce plan to support implementation of the Together for Mental Health Delivery Plan 2019-22   The plan sets out the requirement for Welsh Government to work with Health Education Improvement Wales (HEIW), Social Care Wales (SCW) and partners to produce a workforce plan for mental health services.  The CPW response to the proposals can be accessed here.
 


AWTTC The Care Home Medicines Optimisation Toolkit
The toolkit is currently in development. CPW responded to the draft toolkit and the Equality and Health impact Assessment (EqHIA). The aim of the document is to bring together a suite of guidance documents and useful resources, in one place, as an easy-access resource library that can be used by staff working in care homes.  A copy of the CPW response can be accessed here.


GPhC Consultation on remote hearings
 The GPhC have successfully held some hearings remotely by video link during the COVID-19 pandemic. Those taking part were positive about their experience. The GPhC have consulted on whether this should remain an option for the future.  The CPW response to the consultation can be found here.
 

Impact of the waiting list backlog.
The Health and Social Care Committee have held an inquiry into the impact of the waiting list backlog on people who are waiting for treatment.  CPW has responded to this consultation lobbying for a continued transfer of care into the pharmacy network.  A copy of the CPW consultation response can be found here.
 


RPS – Core Advanced Curriculum
 The Royal Pharmaceutical Society (RPS) have recently consulted on their proposed core advanced curriculum. The curriculum describes the expectation of entry-level advanced pharmacists and bridges the gap between the post-registration foundation curriculum and the consultant pharmacist curriculum. The CPW response to the consultation can be found here.
 


Consultation on original pack dispensing and the supply of medicines containing sodium valproate.
 
The Department of Health and Social Care, on behalf of the four home nations, has consulted on the provision of increased flexibility (+/- 10%) to support the supply of a greater number of medicines in original packs.  In addition the consultations looks at the mandatory supply of medicines containing sodium valproate in original packs.  A copy of CPW’s response to the consultation can be accessed here.


Health and Social Care Committee Inquiry into hospital discharge
 
Good patient flow improves the quality of care for patients, but a number of factors are likely to be causing delayed transfers of care, including capacity issues within the social care system, meaning that some patients who are ready for discharge remain in hospital. This has detrimental impacts on both the individual, and the flow of patients through the hospital, contributing to pressure on A&E departments and ambulance services. During the Sixth Senedd, the Health and Social Care Committee plans to explore how patient flow through hospitals can be improved.  The first part of this work is a short inquiry focusing on hospital discharge and its impact on patient flow through hospitals.  A copy of CPW’s response to the inquiry can be accessed here.


GPhC Consultation on changes to Independent Prescribing requirements
 

The GPhC have consulted on changes which will enable more pharmacists to begin their independent prescriber training.  The proposals are to:

• remove the requirements for registered pharmacists to have two years of clinical practice, before they can enrol on an accredited independent prescribing course.

• remove the requirement to have relevant experience in a specific clinical or therapeutic area, before they can enrol on an accredited independent prescribing course. 

• retain the requirement that course participants must identify an area of clinical or therapeutic practice to focus on during the course.

The CPW response to the consultation can be accessed here.

RPS Post-registration Pharmacist Foundation Curriculum
 
The RPS have consulted on a draft curriculum to support the Post-registration Pharmacist Foundation Programme.  CPW has responded to the consultation on behalf of contractors in Wales and a copy of the response can be accessed here.


GPhC Consultation: How we set fees
 
The General Pharmaceutical Council has conducted a consultation on how they should set fees for premises and registrants in the future.  CPW has responded to this consultation and a copy of the CPW response can be accessed here.


RPS Consultation: A Competency Framework for all prescribers.
 
On behalf of NIHCE and Health Education England the RPS are pulling together a set of competencies for all prescribers.  As the competencies are likely to be adopted in Wales CPW has responded to the consultation on behalf of contractors in Wales.  The competency framework has been developed and updated to support prescribers to expand the knowledge, skills, motives and personal traits, to continually improve their performance, and to work more safely and effectively. A copy of the CPW response can be found here.

 
Professional Standards Authority: Learning from Covid Review
 
The Professional Standards Authority has undertaken a review of the regulators it oversees (which includes the GPhC) to review their responses to the first phase of the coronavirus pandemic up to July 2020. The aim of the review is to help the sector in developing its strategies for responding to the ongoing situation, to learn for further crises in future, and to learn for future ‘business as usual’.   A copy of the CPW response can be accessed here.


Delivering Value Through Disinvestment Consultation

The All Wales Therapeutics and Toxicology Centre (AWTTC) have been consulting on guidelines on Delivering Value Through Disinvestment: an exploration and analysis of appropriate disinvestment in medicines considered low value for funding by NHS Wales.  The initiative will aim to put in place a process by which a medicine may be considered to be a medicine that is a low priority for funding and how the assessment on future funding will be made.  A copy of the CPW response to AWTTC can be found here.
 


National Minimum Standards for Medication Review – July 2020
 
The All Wales Toxicology and Therapeutics Centre (AWTTC) have consulted on the National Minimum Standards that should apply to Medication Reviews.  A copy of the CPW response to the consultation can be accessed here.


Enquiry into the Covid-19 Outbreak in Wales

Community Pharmacy Wales response to the Welsh Government Health, Social Care and Sport Committee Inquiry into Covid-19. A copy of our response can be found here. 


Draft Leadership Principles for Health and Social Care in Wales April 2020

Health Education and Improvement Wales (HEIW) have recently consulted on proposed leadership principles for leaders in the health and social care sectors.  A copy of the CPW response to the consultation can be found here.


GPhC Premises Fees Consultation January 2020

The GPhC recently consulted on proposals to significantly increase registration fees for Pharmacy premises from £262 to £365 per annum. There was no proposed fees increase for Pharmacists and Pharmacist Technicians.  The consultation can be accessed here. 

CPW has responded to the consultation on behalf of contractors in Wales and a copy of the CPW response can be viewed here.


February 2020: National Institute for Health and Care Excellence: Community pharmacies: promoting health and wellbeing
 NICE has recently consulted on a quality standard which covers how community pharmacies can support the health and wellbeing of the local population. It describes high-quality care and services in priority areas for improvement and is primarily aimed at commissioners, service providers, health, public health and social care practitioners, and the public.  CPW has responded to this consultation on behalf of contractors in Wales and our response can be accessed here.


November 2019: Welsh Government consultation on Drug Reimbursement Reforms
 
This was an important consultation by the Welsh Government, which followed on the heels of a similar consultation in England’ which put forward a number of key changes to the way that contractors in Wales would be reimbursed for the medicines they dispensed to patients.  The response from CPW to this consultation can be viewed here.
 
November 2019: National Health Service (Pharmaceutical Services) (Wales) Regulations 2020
 
This important consultation proposes changes to market entry arrangements moving away from the current ‘necessary and expedient’ requirements to a mechanism of market entry based on Pharmaceutical Needs Assessment.  The draft regulations also proposed to introduce sanctions for contractors who are in breach of their contractual requirements.  A copy of the CPW response to the consultation can be viewed here. 
 
August 2019: The Substance Misuse Delivery Plan 2019-22
 
The Welsh Government consulted on its plan for the improved delivery of services to people who misuse substances.  CPW has identified in its consultation response the ability of the community pharmacy network in Wales to make a mire meaningful contribution to the support of this vulnerable group of people. A copy of the CPW response can be viewed here.
 
July 2019: Quality and Engagement (Wales) Bill
 
On the 17 June 2019 the Welsh Government introduced the Health and Social Care (Quality and Engagement) (Wales) Bill which will:

• strengthen the existing duty of quality on NHS bodies and extend this to the Welsh Ministers in relation to their health service functions;
• establish an organisational duty of candour on providers of NHS services, requiring them to be open and honest with patients and service users when
• things go wrong;
• strengthen the voice of citizens, by replacing Community Health Councils with a new all-Wales Citizen Voice Body that will represent the interests of people
• across health and social care; and
• enable the appointment of Vice Chairs for NHS Trusts, bringing them into line with health boards.

 
CPW’s response to the consultation can be viewed here