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GDPR Are You Ready?

STOP PRESS - First DDA and Dispex mini-conference is hailed asa great success - book now for our event at Newton Aycliffe,near Darlington or contact the office if you are interested in amini-conference in your area.

News and Updates on Dispensing Doctor IssuesGeneric Profitability, Training, News, Drug Tariff Changes and More Inside...

VOLUME FIFTY TWO MAY 2018

2 / MAY 2018

Monitored Dosage Systems

NEW EXCLUSIVE PRICES FOR ALL DISPENSING DOCTORS WITH WEB ORDERING FROM OMNICELL

In association with Omnicell Dispex has launched an easier way to order all your MDS trays online with the following benefits

Available to all dispensing doctor surgeries Lowest prices for all genuine quality Omnicell MDS trays. Special Online price of £74.95! [CL-01] No minimum order quantity No delivery charges Order by 6pm for next day delivery £10 discount from your first online order Easy to manage repeat orders and view your purchase history Easy registration and account opening for all Dispensing doctors Order your trays when you want to; open 24/7 If you have an queries about this offer phone 01604 859000 Please note orders can also be placed via 01604 859000

Order from

www.mdstrays.com

All orders fulfilled by Dispex

©Dispex 2017

MAY / 3

EDITORIAL

What’s Inside Page

DDA Update 4

Is Your Practice Ready for GDPR 5

Dispensary Training 6-8

Smart Purchasing 10-11

Drug Tariff News 12-13

NHS Pensions Update 15

CPD Zone - Drug Tariff 16

Interviewing - Top Tips 18

Interview with Richard Kay of PSS 19

Dispensary Practice Audits 20

GDPR - Data Protection is Changing 22-25

DDA News Update 29

GDPR for GPs 30

The Most Dispensed Generics 31

ell I hope you had some sortof break over Easter - Iknow that any Bank Holidayplaces an additional burden

on dispensing practice. It is easy for usto forget that, generally speaking,dispensing practice serves ruralcommunities as a top rate front linehealthcare service.

And with holidays comes tourists, andthose tourists are often heading to theserural areas to get away from theirurban spaces. This puts rural healthcareservices to the test, which dispensingdoctors rise to meet the challenge ofevery time.

Without the income from thedispensary, rural healthcare would beseverely compromised.

This month’s Gazette has a strongfocus on GDPR and what this meansfor dispensing practice. There are anumber of features and articles on thesubject. So whether you are fullyprepared or tweaking those final SOPsand procedures it is certainly worthtaking the time to read these articles inthe light of your own preparation.

As I write this the first Dispex/DDAmini conference in the Taunton areahas been and gone.

It was a great success all round withtalks from NHS Prescription Serviceson submitting prescriptions forpayment and some very useful talksfrom Dr Philip Koopwitz of the DDAon how to maintain margin whilstlooking after your drug spend.

Delegate feedback is impressive andwe will be looking to welcome you tothe next one in Newton Aycliffe soplease contact the office to see toenquire which spaces are left!

If you are interested in one in your areaplease contact the office as we willresume our DDA/Dispex mini-conferences after the summer break.

Best wishes and kind regards as ever,

CHIEF EDITOR / SENIOR CONTRIBUTOR Greg Bull gbull@dispex.net

TRAINING & MARKETING CONTRIBUTORSJane Norrey, Claudy Rodhouse and Michelle de la Bertauche

The Dispensing Doctor GazetteDispex Ltd, 7-8 Prospect Court, Courteenhall Road, Blisworth, Northamptonshire NN7 3DGEngland

Telephone 01604 859000

Fax 01604 859687

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The views of contributors and guest columnists are notnecessarily the views of Dispex Ltd.

Whilst every care has been taken to ensure the accuracy of thecontents of this magazine, the publishers cannot accept liabilityfor any errors or omissions or any incorrect interpretation on anysubject matter(s).

If in doubt, you should seek the appropriate professional advice.

All third party content, registered trademarks, logos and imagesare owned by the respective brands.

No reproduction of any part of this magazine is allowed withoutprior written consent from Dispex Ltd.

Copyright 2018 © Dispex Ltd. All rights reserved.

W

I don’t know about you, but it seemsto me that NHS England is operatingas a law unto itself. On MaundyThursday afternoon, it slipped out adecision to limit the prescribing ofover-the-counter (OTC) medicinesby GPs. You may recall the‘consultation’ and ‘listening events’about this during the early part of theyear.

The policy has not been ‘ruralproofed’ and does not appear to be

changing the regulations to allow dispensing doctors to sellthe medicines concerned to their patients. As a result, thepatients will be subject to the ‘double whammy’ of nothaving their GP prescribe them and be inconvenienced bytravelling elsewhere to purchase them.

Furthermore, on page 12 of the document, it states that:

"CCGs will also need to take account of their latest localPharmaceutical Needs Assessment (PNA) and consider theimpact of this guidance on rural areas and dispensingdoctors in particular.”

Given that CCGs have no locus over PNAs, unless theNHS (Pharmaceutical & Local Pharmaceutical)Regulations 2013 have been amended; this is odd as theDepartment of Heath and Social Care is to respond to thefive-year consultation on them shortly, it would beinterested to understand what is meant by this sentence.Perhaps NHS England means Health and WellbeingBoards?

If it does, the sentence is still unclear. Is NHS Englandsuggesting that PNAs be amended inviting applications toopen lots of pharmacies in rural communities so that OTCsmay be sold? This would destroy all dispensing practices,not just the dispensaries, and add huge strain to thepharmacy budget from which NHS England has justremoved 6%, allegedly to save money. This would seemcounter-intuitive and invite a tsunami of complaints fromrural communities akin to that which occurred in 2008…You can be assured that I have asked for urgentclarification!

In the meantime, I would advise you to write to your MPand local councillors about this policy. Please see ourwebsite for further information about this.https://www.dispensingdoctor.org/news/nhs-england-over-the-counter-prescribing/

Incidentally, the deadline for new PNAs is fastapproaching, so you need to check what it says about yourarea and whether there is any ‘unmet need’ forpharmaceutical services. If it does, this could trigger a

pharmacy application which could endanger some, or all,of your dispensing.

This months Gazette has some very good articles onanother area of public policy that practices need to beaware of. With only a matter of weeks until the 25 May2018 deadline, it is important for practices to preparethemselves for the implementation of the EU General DataProtection Regulation (GDPR). With significant coveragein the media about the GDPR, patients may well befamiliar with some of the changes to existing law. Twoareas in particular may be of interest and importance topatients: the patient’s right of access and confirming fairprocessing of their data. Please see the articles about thisand the DDA will publish guidance for practices on ourwebsite. The BMA, as the doctors’ Trade Union has alsopublished guidance that can be accessed at:

https://www.bma.org.uk/advice/employment/ethics/confidentiality-and-health-records/gps-as-data-controllers

In addition, the ‘2017/18 Data Security and ProtectionRequirements’ mean that all health and care organisationswill be expected to take steps to implement 10 datasecurity standards recommended by the National DataGuardian. From April 2018 the new Data Security andProtection Toolkit (DSP Toolkit) replaced the InformationGovernance Toolkit (IG Toolkit). It now forms part of anew framework for assuring that organisations areimplementing the 10 data security standards and meetingtheir statutory obligations on data protection and datasecurity. Please see the article about this too.

Given the recent revelations about the antics of CambridgeAnalytica and Facebook data, the public will inevitablybecome more concerned about what data is being heldabout them and who has access to it. Well, perhaps Ishould qualify that statement by saying ‘some’ members ofthe public will be concerned about these matters. Giventhe wealth of information that some, particularly young,people post about themselves on social media; if you don’tbelieve me just Google the name of somebody of youknow and see the results, it is not surprising that theauthorities are starting to change the law. The advice I wasgiven by my manager whenI first started working, whenemail was in its infancy was:

If you would not be happy tosee the contents of amessage you have sent onthe front page of thenewspapers, do not put it inan email!

Matthew

4 / MAY

DDA News Updateby Matthew Isom

DDA NEWS

MAY / 5

Is Your Practice Ready for GDPR?by Nick Stevenson of Moore and Smalley

PRACTICE MANAGERS

GDPR is arguably the most important data legislationchange of recent times and makes the task of keepingdata safe more vital than ever before.

From 25 May 2018 the new regulations come into placewhich will require some new elements to be consideredand some significant enhancements to the originalregulations, so you will have to do some things for thefirst time and some things differently.

The GDPR regulations largely apply to personal data heldby an organisation. This includes: names, photos, emailaddresses, bank details, posts on social networkingwebsites, medical information and computer IP addresses.It is therefore vitally important to ensure that you collectand store confidential data including patient and staffcontact data in accordance with the GDPR. NHS Digitalwill be publishing a checklist to help practices implementthe requirements of the new GDPR.

All practices must also maintain a business continuityplan, which should include details of how it will respondto data and cyber security incidents. Practices must alsoreport data security incidents and near misses toCareCERT (An NHS digital system to deliver essentialcyber security updates across the whole NHS).

The GP IT services should help practices report andmanage such incidents.

What can practices do to prepare for the 25 May 2018deadline?

•Make sure you monitor, save and know who you sharedata with and where that information is held and stored atyour practice.

• Let your employees know why you require theirpersonal data and that of the patients, the legalrequirements, justifications and the application ofconsent. Ensure staff are fully trained in all aspects of thenew legislation.

•The Information Commissioners Office (a public bodywhich reports to government and upholds informationrights in the public interest), recommends that anyoneprocessing data at ‘large scale’ should have a DataProtection Officer, who is a person responsible forverifying that you are complying with data protection.

•Subject access requests (SAR) under the new rules differfrom how you have been dealing with these under thecurrent Data Protection Act, you will no longer be able tocharge patients coming to you with an SAR. Whereas youhad 40 days to deal with these types of requests before,you now have a month to comply with the request.

•The GDPR has higher requirements for consent. Youwill need to devise clear opt-out options and good recordsof consent.

Overall, the GDPR will be an administrative burden forpractices, but in so many ways it’s all about processesand procedures and isn’t as daunting as it perhaps seemsat first glance.

Useful links:

NHS data protection training – https://www.e-lfh.org.uk/programmes/data-security-awareness/

Data security protection requirements –https://www.gov.uk/government/publications/data-security-and-protection-for-health-and-care-

If you would like to discuss the impact of GDPR on yourpractice, or you would like to speak with a member of ourteam, please contact Nick Stevenson on 0115 972 1050.

6 /MAR 20176 / MAY

DISPEX TRAINING Dispex Training Updatesby Claudy Rodhouse

May 9th-Controlled Drugs-WARWICKSHIRE, Walton Hall, Wellesbourne Warwick CV35 9HG16th-Monitored Dosage Systems “Best Practice”-BUCKS, BW Garden Court, Watermead, Aylesbury HP19 0FY17th-Practical Dispensary Management-DORSET, George Albert Hotel, Evershot, Dorchester DT2 9PW17th-Practical Dispensary Management-HEREFORDSHIRE, Talbot Hotel, Leominster, Hereford, HR6 8EP23rd-Drug Tariff & Endorsing-AVON, Thornbury Golf Centre, Bristol, BS35 3XL23rd-Monitored Dosage Systems “Best Practice”-OXFORDSHIRE, Witney Lakes Resort, Witney OX29 0SY

June 6th-Controlled Drugs-SUFFOLK, The Riverside House Hotel, Mildenhall IP28 7DP6th-Monitored Dosage Systems “Best Practice”-NORTHAMPTONSHIRE, DISPEX Office, Blisworth NN7 3DG7th-Maintaining Dispensary Accuracy-SHROPSHIRE, The Lord Hill, Abbey Foregate, Shrewsbury SY2 6AX13th-Maintaining Dispensary Accuracy-DEVON, Highbullen Hotel, Chittlehamholt EX37 9HD13th-DRUMS & Audits-GLOUCESTERSHIRE, Stratton House, Gloucester Rd, Cirencester GL7 2LE20th-Monitored Dosage Systems “Best Practice”-HAMPSHIRE, Gray Manor Hotel, Cholderton SP4 0EG21st-Practical Dispensary Management & Drug Tariff & Endorsing-HAMPSHIRE, as above21st-Maintaining Dispensary Accuracy-WILTSHIRE, Marsh Farm Hotel, Royal Wootton Bassett SN4 8ER27th-Monitored Dosage Systems “Best Practice”-NORFOLK, Congham Hall, Grimston, Kings Lynn PE32 1AH27th-Controlled Drugs-GLOUCESTERSHIRE, The Kings Hotel, The Square, Chipping Campden GL55 6AW28th-Maintaining Dispensary Accuracy-WORCESTERSHIRE, Evesham Hotel, Evesham WR11 1DA

TRAINING COURSE ANNOUNCEMENTSWe are pleased to reveal our JULY course dates on page 7. During July we wil bedelivering our acclaimed Controlled Drugs, Business Management and Drug Tariffcourses in many counties.

We still have a few places available on our May-June courses, however some datesare nearly fully booked! Therefore to avoid disappointment we highly recommendreturning your booking form to us this week

COURSE DATES & LOCATIONS

MAY/ 7

Three Easy Ways to Book:OBTAIN a booking form from the Dispex office and return a SIGNED copy to:-E:training@dispex.net F:01604 859687 OR submit your booking online www.dispex.net/training-services

2018 DELEGATE PRICES & BOOKING METHODS

Full Day prices*:Members: £135+vat Non-Members: £250+vat

COURSE TIMES: 9am-5pm (includes a light lunch)

Half Day prices: Members: £85+vat Non-Members: £160+vat

COURSE TIMES: 1-5pm(includes tea,coffee & biscuits)

*All courses are half days unless stated otherwise

Dispex Training Updatesby Claudy Rodhouse

Dispex Ltd reserves the right at any time to change any course date/or venue or to cancel it altogether if we deem it necessary for any reason or cause beyond our control. Booking/cancellation terms apply please see a booking form for details.

JULY 4th-Drug Tariff & Endorsing-CAMBRIDGESHIRE, HI Express Peterborough, PE2 6HE4th-Controlled Drugs-LEICESTERSHIRE, Ullesthorpe Court, Lutterworth LE17 5BZ5th-Controlled Drugs-DORSET,Royal Chase Hotel, Salisbury Road, Shaftesbury SP7 8DB11th-Drug Tariff & Endorsing-DEVON, Muddifords Court, Cullompton EX15 2QG11th-Business Management of a Dispensary-SOMERSET, Monks Yard, Ilminster TA19 9PT12th-The Confident Dispenser-GLOUCESTERSHIRE, Hatherley Manor, Hatherley Lane, GL2 9QA

Our latest hands on course is aimed at dispensers who arelooking at embarking on offering a Monitored Dosage Systemfor patients or dispensers who are already offering this service,but want to make sure they are dispensing safely, accuratelyand within the law.

TOPICS INCLUDE:What is a Monitored Dosage System?, The Dispensing process, 7 day prescribing and the law, Practical, “hands on” dispensing test and check, Medicines unsuitable for MDS Discussion- best practice, Changes topatients medication

REVIEWS“Good practical exercises” Dispenser from Avon“Very relevant information, new tips given” Dispenser from Dorset“The course taught us things we didn’t know!” Dispenser from Dorset“Content easy to follow, good length of time” Dispenser from Avon

Monitored Dosage Systems “Best Practice”

INVITATION

Dispensing Doctor Master Class! Have You Booked Your Places Yet?

The following companies will be supporting the event by the purchase of an exhibition stand: Takeda UK Limited, Lexon UK Limited and Pharma Storage Solutions

Roadshow Agenda9.00 – 9.30 Registration

9.30 – 10.25 Back to basics, Personal Administration and VAT:Dr Philip Koopowitz

10.30 – 11.25 NHSBSA – Improving prescription returns:Philip Edwards MRPharmS and Kerry Frenz MRPharmS

11.25 – 11.45 Tea & coffee

11.45 – 12.40 Regulations, regulations, regulations – FMD, Mergers, CQC, DSQS:Dr Philip Koopowitz

12.40 – 13.20 Lunch

13.20 – 14.15 How Best to Use Your Practice Space:Richard Kay of Pharma Storage Solutions

14.15 – 14.30 Tea & coffee

14.30 – 15.45 Improving margins;Practical advice on smarter dispensing:Dr Philip Koopowitz and Gregory Bull

15.45 – 16.00 Question and Answer Session - Dr Philip Koopowitz and Gregory Bull

16.30 Close

Redworth Hall Hotel, Newton Aycliffe, near Darlington, DL5 6NLTuesday 8 May, 9am-4pm

Speakers include Dr Philip Koopowitz DDA Board Member, Philip Edwards MRPharmS BusinessDevelopment and Principle Pharmacist of NHS Prescription Services, Kerry Frenz MRPharmS SeniorSpecialist Pharmacist of NHS Prescription Services, Richard Kay of Pharma Storage Solutions andGregory Bull Commercial Manager Dispex Limited.

Who should attend?

The full day of seminars is aimed at dispensary managers, practice managers, dispensers and especiallythe GP in charge of the dispensary.

Why should you attend?

if you want to make sure you are purchasing wisely, make sure you aren’t over endorsing, aren’t losing outon your prescription returns, want to know where to find useful information online, want to increase yourprofitability whilst maintaining probity, then this is the event for you!

The cost is £79 + VAT per delegate for DDA or Dispex Members and includes light lunch, plus servings oftea/coffee and biscuits.

10 / MAY

DISPENSARY MANAGERS Smart Purchasing - Wholesaler Solutions?by Gregory Bull

Remember, dispensing doctors have the clawback [usually11.18%] applied to all medicines and devices which youdispense.

This means that where the total discount given to you is lessthan the clawback, your dispensary will lose moneydispensing that prescription item.

In recent years many pharma companies have turned awayfrom offering Manufacturer Discount Schemes [MDS] todispensing doctors. Where there was a benefit to using theUK brand, due to generous discounting, quite often now itmay be that the UK brand discount isn’t as good as aparallel import discount.

But it isn’t all bad news as there are still companies outthere who do offer an MDS scheme. It is vital that youcontact your wholesaler or buying group to ensure you aresigned up to ALL available schemes. There are someschemes which you are automatically entitled to, and someyou must actively sign up to. You should be in regularcontact with your wholesaler representative to keep up tospeed on the latest deals.

It is also essential that you are told/find out when an MDSscheme is discontinued. It is important that your wholesalerprovides you with great service, not just delivery but interms of information on your rebates, discounts and schemesyou are signed up for. Your wholesaler should be addingvalue to your dispensing business by supporting yourdispensary and your dispensing staff wherever possible. Itmight be that you ask your wholesaler to support a trainingday or an independent practice audit or some in housetraining. Your wholesale spend is one of your largestoutgoings on a monthly basis, make sure you get as muchvalue out of that spend as you can!

Generics

In recent times the generic market has been volatile, withmanufacturers suspending production and other suppliersbeing temporarily closed down or some even going out ofbusiness. The knock on effect of this has been a sharp rise inthe market cost to purchase certain generics which are nowin short supply.

You must keep an eye on the purchase price of your generics– a great simple way to keep up to speed is to utilise yourDispex membership and login to check the list of GenericsWhich May Be Above Drug Tariff which is publishedmonthly and compares the generic purchase price with theDrug Tariff price and is a great indicator of which genericprices to keep an eye on. A wise and experienced dispensarymanager should have a rough idea of purchase price of thefast moving generic lines and be able to spot a sudden pricehike.

Again – ask your wholesaler how they can help with this,can they indicate on invoice when a generic is above DrugTariff price?

Can they guarantee to sell all generics at a price below DrugTariff?

Probably not, but its worth a conversation to see how yourwholesaler can help.

Typical items which usually attract no discount include:

• Air Cylinders (Medical Grade)• Most Borderline Substance Foods• Most Controlled Drugs in Schedules 1, 2 and 3 of Misuseof Drug Regulations 1985• Drugs available only on a named patient basis• Homoeopathic Products• Made to measure elastic hosiery and trussesNearly all of the following:• Eye Drops (cold chain)• Ear Drops (cold chain)• Nose Drops (cold chain)• Most Fridge Lines• Most Injections• Powders for reconstitution• Cytotoxics• Palliative Care Medicines• Most Enteral Nutrition products• Sip Feeds• Most Gluten Free products• Special Diet products• “Make Up” Listed in the Drug Tariff

Or basically anything for which you do not receive adiscount

It is a good idea for dispensing doctors to check the DrugTariff Part II in order to find out if the drug is listed underthe “Discount Not Given” list. Whilst dispensing doctors arenot allowed to endorse DNG [and therefore not have theclawback applied to that item] this is a useful bench-marklist of items which may not attract discount.

If in doubt you should have that conversation with yourwholesaler and find out exactly which items they don’t giveyou a discount on.

Your wholesaler statement is a good place to start with this –do you understand where your discounts are coming from?Do they show you your PA items separately? Is theretransparency of discount? As a dispensary manager youshould utilize any help your wholesaler can give you and ifthere is no added value coming from your wholesaler thenwhy are you still using them?

MAY/11

Smart Purchasing - Genericsby Gregory Bull

DISPENSARY MANAGERS

Last month I wrote about the Drug Tariff and how itinfluences and affects dispensing practice income.

The primary role of the Drug Tariff is:

To define the NHS terms of reimbursement for pharmacyand appliance contractors. [The situation for dispensingdoctor contractors is primarily set out in the Statement ofFinancial Entitlement and overrides the Drug Tariff.]

By

Determining the basic reimbursement price of drugs andother devices, oxygen, dressings, appliances and reagents[This is very relevant to dispensing doctors and you shouldmake sure you are aware of Part VIIIA and Part VIIIB as aminimum requirement!]

So it is the Drug Tariff which determines the money youget back for dispensing an item of medicine to a patient.This is the very basic purpose of the Drug Tariff. And youwill be aware that the price of generic medicines can godown as well as up and generic dispensing should make upthe majority of your volume dispensing.

So smart purchasing of your generics is essential.

In this case by “smart” we are asking you to look at yourdiscount from Drug Tariff. Do you know the actual priceyou are paying for the items listed on the infographic to theright? Those medicines will be a major part of your genericdispensing and if you don’t know the discount you aregetting on them you won’t know what your profitability is!

It has been a popular tactic for some generic suppliers tocreate a discount scheme where you need to buy a certainamount of medicines to get your discount. Or sometimesdiscounts are hidden behind rebate schemes, where if youbuy a certain generic at a certain price you get a rebate ordiscount from another, different generic. It might beconsidered that some generic discount schemes are set upto be deliberately hard to understand, I can’t comment onthat. But what I can say is that discount from invoice priceis by far my preferred way to buy generics.

My analogy is always if I am shopping in a supermarket, Iwant my discount at the till, not money off my next shop,or coupons for money off things I don’t want.

Take a look at the discounts on the medicines on the right,plenty of them are running at a discount of above 50% -can your generic supplier match these levels of discount?Its worth asking them. Its also worth shopping around onyour top twenty generics. You could send them out totender and go with the best offer.

Buy your generics wisely, as they are still very profitable ifpurchased correctly!

DISPENSARY MANAGERS Drug Tariff News May 2018 - Additionsby Gregory Bull

12 / MAY

Medicine Pack Size[s]

Acetylcysteine 2g/10ml solution for infusion ampoules 10Category C MartindalePharmaceuticals Ltd

Adrenaline (base) 150micrograms/0.3ml (1 in 2,000) solution forinjection pre-filled disposable devices 1 and 2 Category C EpiPen Jr.

Bimatoprost 300micrograms/ml / Timolol 5mg/ml eye drops 0.4ml unitdose preservative free 30 (6x 5) Category C Ganfort

Cefuroxime 125mg/5ml oral suspension 70ml Category C Zinnat

Diltiazem 120mg modified-release capsules 28 Category C Adizem-XL

Diltiazem 120mg modified-release capsules 56 Category C Adizem-SR

Diltiazem 180mg modified-release capsules 28 Category C Adizem-XL

Diltiazem 180mg modified-release capsules 56 Category C Adizem-SR

Diphtheria / Tetanus / Poliomyelitis (inactivated) vaccine (adsorbed)suspension for injection 0.5ml pre-filled syringes 1 Category C Revaxis

Enoxaparin sodium 300mg/3ml solution for injection vials 1 Category C Clexane

Estradiol 500micrograms / Dydrogesterone 2.5mg tablets 84 Category C Femoston-conti

Glucose powder for oral use BP 1980 500g Category C Thornton & Ross Ltd

Hepatitis A (inactivated) / Hepatitis B (rDNA) vaccine (adsorbed)suspension for injection 1ml pre-filled syringes 1 Category C Ambirix

Imatinib 100mg tablets 60 Category A

Insulin degludec 100units/ml / Liraglutide 3.6mg/ml solution forinjection 3ml pre-filled disposable devices 3 Category C Xultophy

Insulin lispro biphasic 50/50 100units/ml suspension for injection 3mlcartridges 5 Category C Humalog Mix50

Insulin soluble human 100units/ml solution for injection 3ml cartridges 5 Category C Humulin S

Methotrexate solution for injection pre-filled syringes [variousstrengths] 1 Category C Zlatal

Nifedipine 20mg modified-release tablets 28 Category C Adalat LA

Nifedipine 20mg modified-release tablets 56 Category C Adalat retard

Somatropin (rbe) 10mg powder and solvent for solution for injectionvials 1 Category C Zomacton

Somatropin (rbe) 4mg powder and solvent for solution for injectionvials 1 Category C Zomacton

Somatropin (rmc) 8mg powder and solvent for solution for injectionvials 1 Category C Saizen

Timolol 2.5mg/ml eye drops preservative free 5ml Category C Eysano

Timolol 5mg/ml eye drops preservative free 5ml Category C Eysano

Ulipristal 5mg tablets 28 Category C Esmya

Drug Tariff News May 2018by Gregory Bull

DISPENSARY MANAGERS

Every month in The Dispensary Gazette we highlightupcoming changes to the Drug Tariff via the preface,which can be viewed online a few days BEFORE the endof the previous month.

So at the end of MARCH it is possible to see APRIL’sDrug Tariff which will also contain MAY’s changes.

It is vital that anyone who wants to use smart purchasingis aware of this. This advance notice gives yourdispensary, which is a business, at least some time tomake purchasing adjustments.

When change is coming you may wish to purchase morestock if the likely purchase price is going to rise or orderless stock if the purchase price is likely to fall.

How do you know what the purchase price is likely todo?

Usually when a product goes from Cat C to Cat A or M,the purchase price will almost certainly fall.

On the page opposite we have listed the additions to theMay 2018 Drug Tariff as proposed.

So, what do MAY’s additions tell us?

Very little really.

The most interesting point is that Diltiazem modified-release capsules 120mg and 180mg in differing packsizes are finally being added as Category C items.

Various formulations and strengths of diltiazem havebeen listed in the Drug Tariff for years and it seems to bean anomaly that certain formulations and strengths seemto take longer to get listed in the Drug Tariff than others.

The other curiosity is the addition of Nifedipine 20mgmodified-release tablets, also after many years of beingavailable.

With all these additions you should prescribe by genericname [where this is deemed appropriate by the prescriberand should be a clinical decision first and foremost] andonly endorse the pack size and you can give the brandknowing that your reimbursement will be based upon thebrand NHS list price which should be the same as theDrug Tariff price.

Medicine Pack Size[s]

Emulsifying ointment 50% / Liquid paraffin 50% ointment 100gCategory CEmulfin

Drug Tariff Deletions May 2018

In the table above, which is the deletions from the May 2018 Drug Tariff only one medicine is listed as going to bedeleted so little or no news here.

14 / MAY

DISPENSARY MANAGERS Drug Tariff News May 2018 - Changesby Gregory Bull

Medicine Pack Size[s]

Imatinib 400mg tablets 30 Category C Glivec will be:

30 Category A

Pramipexole 1.05mg modified-release tablets 30 Category C Mirapexin will be:

30 Category A

Pramipexole 1.57mg modified-release tablets 30 Category C Mirapexin will be:

30 Category A

Pramipexole 260microgram modified-release tablets 30 Category C Mirapexin will be:

30 Category A

Pramipexole 2.1mg modified-release tablets 30 Category C Mirapexin will be:

30 Category A

Pramipexole 2.62mg modified-release tablets 30 Category C Mirapexin will be:

30 Category A

Pramipexole 3.15mg modified-release tablets 30 Category C Mirapexin will be:

30 Category A

Pramipexole 520microgram modified-release tablets 30 Category C Mirapexin will be:

30 Category A

Now this should be your focus as a dispensary managerplanning for your stock purchasing in the next few weeks.

As you can see from the table various strengths of Pramipexolemodified-release tablets are moving from Category C toCategory A – this means the reimbursement price will changefrom the current brand NHS list price [Mirapexin] to a pricecalculated on a basket of prices [more on that elsewhere in thisissue].

This new Category A price is hard to predict with all the recentstock shortages in the generic supply line.

So, what should you be doing?

Talk to your colleagues in other surgeries, talk to yourwholesaler, talk to specialist generic suppliers and find outwhat the market currently looks like. Find out what the currentgeneric purchase price is and ask your suppliers if they thinkthe price will go down or up, be proactive and most of all be

prepared for what is most likely to happen in May of this year.It may be that the feedback you get on this is minimal, but atleast by being proactive you help to minimise your risks onthis.There may also be clinical concerns here – the prescribershould make the decision about whether to prescribe by brandname and ensure continuity of supply or write the prescriptiongenerically and allow the dispensary manager to purchase atbest possible price to maximise income.

From studying the Prescription Cost Analysis figures from2017, it is clear that this medicine isn’t going to be in your top20 by items dispensed, but it is very expensive and shouldwarrant your attention.

At the time of writing [March 28th 2018] there were genericsavailable at significant discounts from Drug Tariff price soplease be proactive on this!

NHS PENSIONS – ELECTING FOR THE SCHEME TO PAY YOUR ANNUAL ALLOWANCE TAX BILL

For GPs, the amount to measure against the annual allowance is the ‘growth’ in their fund in the NHS scheme - not the GPs superannuation payments collected from the practice each NHS year. These growth figures are provided by NHS Pensions but aren’t available before the tax return deadline each year. For example, the likely charge for 2016/17 tax year had to be estimated and marked on the tax return as provisional so the return could be submitted by the 31 January 2018 deadline.

If a GP has no unused annual allowance from earlier years, the calculations involve testing all contributions made in the year against the actual annual allowance that the GP is entitled to for the year (potentially less than £40,000 where annual earnings exceed £150,000). A GP can elect for such tax charges to be paid from the NHS pension fund under the ‘scheme pays’ facility. This facility is only available where the growth in the NHS benefits itself is above £40,000 and the tax payable is at least £2,000: any tax charge on growth below £40,000, or where the tax is less than £2,000 must be paid by the GP personally. And it cannot be used where the GP has retired and is receiving their pension.

The deadline for electing to use the scheme pays facility for 2016/7 is 31 July 2018 but again it is unlikely that the NHS will have sent out the relevant annual allowance statements by that date. Fortunately, you can make a provisional election and amend it when the statements become available.

Where the GP elects to use the scheme pays facility a revised tax return must be filed to report the final tax charge. GPs that don’t elect must amend their tax return and pay the tax as soon as possible because interest is charged by HMRC from the due date (ie 31 January 2018 for 2016/17). A tax charge also triggers payments on accounts so consideration needs to be given especially if the GP has become a deferred member or retired.

It is vital to remember that even if you can use the scheme pays facility, it may not make sense in pension terms. Such payments from the scheme are treated a ‘negative contributions’ which will have a long term impact on final pension benefits so take specific advice from a qualified independent financial adviser before making the election.

This is a complex area so please contact our team if you wish to discuss your position.

By now, GPs should be familiar with the concept that tax relief on pensions contributions made for (and by) them can trigger a tax clawback charge because of their level of annual earnings. If the annual allowance is exceeded tax will be payable on the excess.

BDO LLP is authorised and regulated by the Financial Conduct Authority to conduct investment business.© April 2018 BDO LLP. All rights reserved.

www.bdo.co.uk

SARAH MOSS+44 (0)121 352 6365sarah.moss@bdo.co.uk

HB010599

FOR MORE INFORMATION:

NORTH HILARY SHARPE+44 (0)161 833 8302hilary.sharpe@bdo.co.uk

SOUTH WEST AND WALESSHIRLEY WHITTLE+44 (0)117 930 1642shirley.whittle@bdo.co.uk

MIDLANDSSARAH MOSS+44 (0)121 352 6365 +44 (0)7791 397 696 (mobile)sarah.moss@bdo.co.uk

LONDON AND SOUTHIAN DODGE +44 (0)1483 408 063ian.dodge@bdo.co.uk

EAST ANGLIASARAH ELMS+44 (0)1473 320 732sarah.elms@bdo.co.uk

SCOTLANDANDREW MCNAMARA+44 (0)141 249 5249 andrew.mcnamara@bdo.co.uk

NHS PENSIONS – ELECTING

NHS PENSIONS – ELECTING

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16 / MAY

ALL DISPENSARY STAFF

Drug Tariff Definitions as Listed in The Drug Tariff

As part of your ongoing Continued ProfessionalDevelopment plan working in the dispensary, it would be agood idea to increase your knowledge of the Drug Tariff. Asthis is a vital part of understanding the reimbursementprocess by which your dispensary gets paid for dispensingmedicines to your patients.

Over the recent months, and elsewhere in this issue of TheDispensary Gazette, there are articles on the Drug Tariffwhich you should always read.

As part of your CPD take some time to read the followingdefinitions AS WRITTEN in the Drug Tariff concerning thevarious categories of medicine listed in Part VIIIA. Thenreflect on the meaning and take some time to answer thequestions below. Keep a record of this work for your CPDfolder.

Category A - Drugs which are readily available.

Broken Bulk may be claimed for those products whosesmallest pack size has a price greater than or equal to £50, ifnecessary.

The prices listed in this Part of the Drug Tariff are indicativeof the prices determined by the Secretary of State for Health.The following pack sizes are considered when calculatingCategory A prices:

• for tablets and capsules, all prescription only medicinepack sizes up to and including 120 unit doses:

• for liquids and some creams (including special containers)up to and including 500ml/500g.

Where a pack size for a product listed in this Part exceedsthe quantities stated above, the listed pack size is the onlypack size considered when calculating the price.

The Secretary of State determines the prices for Category Adrugs to be the average of the price calculated for the packsize listed in the Drug Tariff weighted by the following fourmanufacturers and suppliers; AAH, Alliance Healthcare(Distribution) Ltd, Teva UK and Actavis/Accord on orbefore the 8th of the month being reimbursed.

In the weighted formula, AAH and Alliance Healthcare(Distribution) Ltd prices have a weighting of 2, the pricesfrom the other suppliers have a weighting of one (EitherActavis or Accord’s list price is used in the weightedformula; in circumstances where a product is listed byActavis and Accord, then Accord’s list price is used in theweighted formula).

Category C - Drugs which are not readily available as ageneric, where the price is based on a particular proprietary

product, manufacturer or as the case may be supplier.

Endorsement of pack size is required if more than one packis listed.

Broken Bulk may be claimed, if necessary.

Where the price of the product is based upon a non-proprietary product the price listed in this Part of the DrugTariff is indicative of the price determined and in this casethe Secretary of State determines the price to be the pricelisted by the manufacturer or as the case may be supplier onor before the 8th of the month being reimbursed.

Category M - Drugs which are readily available.

Broken Bulk may be claimed for those products whosesmallest pack size has a price greater than or equal to £50, ifnecessary.

The Secretary of State determines the price based oninformation submitted by eligible suppliers participating inScheme M. The following pack sizes are considered whencalculating Category M prices:

• for tablets and capsules, all prescription only medicinepack sizes up to and including 120 unit doses;

• for liquids and some creams (including special containers)up to and including 500ml/500g.

Where a pack size for a product listed in this Part exceedsthe quantities stated above, the listed pack size is the onlypack size considered when calculating the price.

Questions to consider:

Which four manufacturers and suppliers prices contributetowards Category A reimbursement prices?

Explain the weighting formula used in the pricing ofCategory A reimbursement prices.

If AAH, Alliance Healthcare (Distribution) Ltd, Teva UKand Actavis/Accord ALL had a product listed at £10 whatwould be the Drug Tariff reimbursement price of thatCategory A generic?

When can you claim broken bulk on a Category A item?

What is a Category C reimbursement price based on?

Should you endorse the pack size of a Category C item ifonly one pack size is listed?

Where can you find the basic prices for “Specials”?

Do you understand the pricing formula for “Specials”?

CPD ZONE - Drug Tariffby Gregory Bull

MAY/ 17

CONSIDERING INSTRUCTING AN EXPERT WITNESS?

1. Civil and criminalpharmaceutical cases.

2.Liability and negligence inprescribing or dispensing.

3.Pharmacy valuations.

4.Forensic matters.

5.NHSLA matters.

For a no obligationcomplimentary quotation onany related topic please

contact:-

N V Morley MRPharmS01604 859000

office@nvmholdings.com

Low cost and discounts applyfor Dispex members.

EXPERIENCE COUNTS

PHARMACYVALUATIONS

Do you need a valuation of yourpharmacy because a

Partner/Shareholder is leaving ?

For specialist advice regarding the value of your pharmacycontact

Help and advice is available from Nigel Morley MRPharmS

who assists many practices with obtaining a WDL and/or pharmacy licenceand his recent many successes in

fighting predatory pharmacy applications as reflected inthe National statistics.

N V Morley MRPharmS01604 859000

office@nvmholdings.com

Low cost and discounts apply for Dispex members.

EXPERIENCE COUNTS

18 / MAY

“It is a depressing reality that, when it comes to the rights ofpregnant women and new mothers in the workplace, we arestill living in the dark ages.”

This was the damning conclusion reached by the Equalityand Human Rights Committee (EHRC), after it asked over1000 employers about their opinions on pregnancy andmaternity discrimination.

The survey showed that 36% of employers think it’s fair toask female interviewees about their plans to have children.Almost half think it’s fine to ask applicants if they alreadyhave children.

It seems that a lot of employers don’t realise there are somethings you just can’t ask someone during an interview.Why can’t I ask anything I like?

Because if you reject a candidate after asking themquestions related to protected characteristics, they couldclaim that you put them at a disadvantage and take you to anemployment tribunal.

Protected characteristics are parts of a person’s identity thatyou can’t use to discriminate against them. In UK law, thereare nine of them:

•Age•Being or becoming a transsexual person•Being married or in a civil partnership•Being pregnant or on maternity leave•Disability•Race including colour, nationality, ethnic ornational origin•Religion, or lack of one•Sex•Sexual orientation

Let’s say you ask a candidate if she plans on having childrenin the next six months and she says yes. If you then give thejob to someone else, she could accuse you of rejecting herbecause you didn’t want an employee going off on maternityleave soon after they’ve joined.

What other questions are unacceptable?

Some other examples of unacceptable questions are:

•“Are you a British citizen?”•“Will you need time off for Ramadan?”•“Are you comfortable working for a femaleboss?”

Questions about health may be acceptable if the rolerequires the candidate to be in good physical shape. You’llneed to provide solid evidence for this, though.

Keep the interview professional

If the interviewee is chatty, it can be easy to go off ontangents that aren’t related to the role in question. Oneminute you’re going through their CV, and the next you’rediscussing your mutual love for the latest Netflix drama.

While it’s fine to be informal, don’t forget why you’rethere—to find out whether the candidate has the right skills,experience and attitude for the job.

Make special adjustments if necessary

The law states that you must remove any barriers thatdisabled candidates may face during the interview. It’s agood idea to ask the candidate about any requirements theyhave before the interview takes place.

For example, if you know that the candidate uses awheelchair, make sure you hold the interview in anaccessible room.

If you ask candidates to complete a written test but theyaren’t able to, you could allow them to do a spoken versioninstead.

Don’t go it alone

We all judge people—it’s human nature. But if youinterview a candidate by yourself, your subjective feelingscould lead to a discrimination claim.

Having two or more interviewers makes things moreobjective. It also makes it easier to be thorough. Yourcolleague might remember to ask a question that you’dforgotten about.

And if two people come to the same conclusionindependently, it’s likely to be true.

Anthony Macey is Director at Portfolio GroupPortfolio is a market leading recruitment consultancyfocusing in 4 Specialist areas including Payroll, HR &Reward, Credit Control and Procurement recruiting forprofessionals at all levels of the market, across the whole ofthe UK and into a multitude of Industry Sectors. Establishedfor 29 years, they have a wealth of experience in theindustry and an amazing record of accomplishment to suit.

Interviewing - Top Tipsby Anthony Macey - Director at Portfolio Group

PRACTICE MANAGERS

MAY/ 19

Interview with Richard Kay of PSSby Gregory Bull

DISPENSARY MANAGERS

What do you think is the most important aspect ofdispensary design?

Gaining the best efficiency for key processes within thespace available. Better and more efficient stock control,expand work top space and bring efficient control to scriptswaiting collection.

Where do you most often see problems with dispensarylayout?

Finished script storage along with poorly designeddispensary hatches. The best practice would be to create afast grab and go scenario for script waiting.

What is the one single thing that you change most oftenin a dispensary?

Layout. Always looking to condense stock to the smallestfootprint and expand working areas.

GP practices are seemingly growing in size and arealways looking for ways to find more space – is there asimple solution to that?

Best use of space is vital. Making sure all areas are valuedrequires a proper survey of the premises. A few recenttransformations we have been involved in include swappingthe Nursing rooms around to create a bigger dispensary andin some cases even swapping GPs consultation rooms toexpand dispensary services.

Another solution we have been involved with is to movePatient records into a Porta Record storage container.Moving records out of the practice into the grounds of thebuilding, can free up vital space that can be converted intogeneration of better improved services and income.Containers such as these are strong, safe and space efficient.

So it is possible and legal to store patient records in aPorta Record storage container?

Yes, many practices have already started this process on thesurgery site. Our Porta Storage containers are incrediblystrong and secure. Located within the building grounds,connected to the power supply for lighting and security,these units are an ideal solution to the problem of how todeploy a record storage system.

How long have you been refitting out dispensaries for?

10 years

What do you most enjoy about your job?

Helping a practice realise their goals of a better dispensary.Working closely with the practice can be very rewarding.

And finally a few personal questions – what footballteam do you support?

Born in Salford Manchester it had to be Man Utd

Favourite food? Chinese

Our services and product refit includes both modularand traditional systems.

Our design team excel in offering 3D CGI floor plansand scaled layouts to carefully plan all theequipment required to deliver the optimumdispensary and work environment.

For a better safer environment call us on

01704 823600 for a FREE consultation

Email: richard@pharmacystoragesolutions.co.uk

Is Your Dispensary Safe and Efficient?

Pharmacy Storage Solutions special services:

•Script storage and retrieval systems

•Counters and joinery services

•Building, ceiling and flooring solutions

20 / MAY

Dispex is pleased to bring a new contributor to theservices we provide, Alastair Carmichael, RegisteredPharmacist. Not only will he be tutoring our courses butalso providing a Dispensing Practice Audit Service.

Alastair explains, “In clinical practice, we often reviewwhat we do in patient care by way of a structured audit toensure that the practice is still delivering the best care forits patients, and thus it’s a good idea to review how yourdispensary business operates in terms of effectiveness,efficiency and profitability.”

Dispex has teamed up with Alastair Carmichael to offeryou access to his services at a reduced rate. Over the pasttwo years Alastair has reviewed the dispensing businessmodel of over 55 different practices and helped many ofthem to achieve greater profitability, logistical efficiencyand even safety in dispensing.

Alastair Carmichael is a Registered Pharmacist with awealth of experience, having been working in the arenaof Dispensing Practices for the last 4 ½ years. His wide-ranging career experience as a Practice Pharmacist, CQCPharmacist Specialist Advisor, Area Manager for aCommunity Pharmacy group and European BusinessDevelopment Executive stands him in an excellentposition to assist and advise practices on their futuresustainability and explore all options open to dispensingpractice.

A Dispensing Practice Audit could cover some or all ofthe following areas, depending upon the needs of theindividual practice:

•Gross profitability of the dispensary

•Advice on dispensing choices and practice formulary

•Assessing the balance of CCG pressures and commercialreality

•Clinical governance of the dispensary and audit ofDSQS

•Logistical analysis of the dispensary processes andefficiencies

•Strategic and business development

•Utilisation of pharmacists in General Practice

•Preparation for a CQC Inspection

The reviews have been designed to be completed in one

day, followed by a written report for the practice toconsider further. This report will give the practice theopportunity to benchmark their dispensing profitabilityand cost against similar practices across England &Wales.

We asked Alastair how best to look at this kind of serviceand he told us, “When considering whether such an auditwould be beneficial for a practice, it is essential to engagewith all interested parties in the practice/business to allowfor everyone to have input and therefore also ensuringthat those same people have interest in the output of theaudit. To this aim, a short meeting with the practice team,such as the Dispensary Manager, Practice Manager andLead Dispensary GP tends to lead to a more effectiveaudit and successful outcome.”

Some of the key findings from recent audits include:

- Lack of compliance to the practice formulary and thusreduced profitability – considers new clinicians that maynot be aware of the consequences of their prescribing

- Unopposed input from CCG Medicines Managementteam which has led to reduced dispensing profitability –designing alternative options for better win-win scenarios

- Poor prescription administration identified from fullanalysis of Open Exeter statements, and leading to anoverhaul of counting and checking processes and reducedlosses

- Missed discounts from new manufacturer discount dealsthat have not been signed up to

- Reduced purchasing discounts from varied genericbuying methods, including issues around PriceConcessions

- Improvements in the logistics of the repeat prescriptionprocesses, leading to more efficient working patterns andimproved safety in dispensing

- Review of the operational effectiveness of combiningPharmacy and Dispensing businesses into a Hybridbusiness

If you think your practice would benefit from aDispensing Practice Audit or to discuss your needs inmore detail then please contact Dispex on 01604859000 or email michelle@dispex.net for more detailsand to book your audit.

Dispensing Practice Auditsby Greg Bull and Alastair Carmichael

DISPENSARY MANAGERS

IN-HOUSETRAINING

w w w . d i s p e x . n e t

Did you know we can come to you?

If our current classroom training courses are just too far from your practice, or on thewrong day of the week, or its just not convenient to send your dispensary team out on an

away day - then why not get us to come to you?

We charge a flat rate to DISPEX members to train up to 6 delegates on site, at your surgeryof

£350 + travel at cost + VAT.

If you are considering re-joining Dispex please contact michelle@dispex.net for details of our current re-joining scheme.

Dispensing For Profit

For more information visit our website or call

01604 859000

22 / MAY

Data protection law is changing on the 25th May. Dr RachelBirch, Editor-in-Chief of the Medical Protection Society’sPractice Matters magazine, outlines what practices shouldhave been doing to prepare themselves for this change

On 25 May 2018, the EU General Data Protection Regulation(GDPR) will come into force and will have a direct effect inevery European country. It will supersede existing dataprotection laws, including the UK Data Protection Act 1998.It has been written to reflect the increasingly digital world andwill allow people to take greater control of their own personaldata.

Main changes

The list of changes outlined below is taken from theInformation Commissioner’s Office’s (ICO) guidancePreparing for the General Data Protection Regulation(GDPR) – 12 steps to take now1. It is important to note, asMay 2018 approaches, that these recommendations andchanges are not completely finalised; ICO guidance will besubject to further changes and updates.

CONSENT AND LEGAL PROCESSING: The GDPR sets avery high standard for consent in relation to the processing ofpersonal data. However, rather than relying on consent toprocess patient’s data, practices are likely to be relying onanother appropriate legal basis for the processing of data.

In general, a GP practice will be providing a service to thepatients. Therefore, since it is necessary to process that data toprovide the service, then the practice can rely on that legalbasis rather than consent.

The following are the legal bases for the processing ofpersonal data:

•Consent

•Necessary for the performance of a contract or the provisionof a service

•Necessary in relation to a legal obligation

•Necessary in the vital interests of the data subject

•Necessary for a task carried out in the public interest or in theexercise of official authority

•Necessary for the purposes of a legitimate interest unless

overridden by the rights and freedoms of the data subject.

In relation to special categories of data (formerly sensitivepersonal data, which includes health data), there are specificprovisions that allow data to be processed in order to providemedical care, and in relation to social protection laws.

In general, practices will rely on the above provisions and notconsent. However, if no other processing condition appliesand consent is required then it must be freely given, specificand informed. It should constitute an unambiguous indicationof the patient’s wishes, by a clear affirmative action to theprocessing of his/her data. Pre-ticked boxes will not count asconsent and there must be a positive opt-in process, separatefrom other terms and conditions. There should be an easy wayfor patients to withdraw their consent. The ICO has publishedhelpful guidance on GDPR2.

TRANSPARENCY AND FAIR PROCESSING: Practicesmust inform individuals what they are doing with their data.Privacy notices should be used to inform patients at the timeof collecting their data3. These could be available on thepractice website and as posters in the practice.

The following information must be provided within suchnotices:

•the data controller’s identity

•the data protection officer’s contact details

•the purpose of the processing

•the legal basis for processing

•the categories of personal data concerned

•the potential recipients of personal data

•how long the data will be retained

•a list of the data subject’s rights

•any safeguards that will be used if data is to be transferred toa country outside the EU.

In addition, patients must be informed that they can complainto the ICO if they believe there is a problem with how theirdata is being handled.

Data Protection is Changingby Dr Rachel Birch

PRACTICE MANAGERS

MAY / 23

SUBJECT ACCESS REQUESTS: The timescale forcompliance with a patient’s subject access request will bereduced from 40 to 30 days. Practices will no longer be ableto charge, unless the request is manifestly excessive orunfounded. If practices refuse a subject access request, theymust tell the patient why they have done that and inform themthat they have a right to make a complaint to the ICO.

DATA BREACHES: In the event of a data breach affecting apatient’s privacy rights (for example, breach ofconfidentiality), data controllers will be required to notify theICO without undue delay, and where feasible no later than 72hours after becoming aware of the breach. This is in additionto the duty of candour to inform patients of such breaches.

The ICO will have the power to impose higher fines forbreaches of the regulation.

DPIAs: Data Protection Impact Assessments (DPIAs) arerecommended as a way of assessing the level of protection inplace to safeguard patients’ personal data. They were formerlyknown as Privacy Impacts Assessments. Whilst consideredgood practice in any case, DPIAs will be legally requiredwhere the processing of personal data is likely to involve highrisks to the confidentiality of individuals. They are likely to berequired when practices introduce new technology, forexample a new computer system or a new system of sharingdata.

DATA PROTECTION OFFICER: Certain organisations willbe required to have a Data Protection Officer (DPO),including those deemed to be public authorities. The UK DataProtection Bill 2017 has defined a public authority as thoseorganisations subject to the Freedom of Information Act 2000and the Freedom of Information (Scotland) Act 2002.Therefore, practices will require a DPO.

The DPO’s role is an advisory and monitoring role, andcannot be someone who takes decisions about data protection.It is unlikely that the practice manager could take on this role,as there would likely be a conflict between advising on how tocarry out processing in compliance with the GDPR, andtaking decisions about how that should be done.

PATIENTS’ RIGHTS: Individuals will be given strongerrights under the GDPR, including the right to rectification, theright to erasure, the right to object to processing, the right torestrict processing and the right to data portability. This finalright makes it easier for patients to move their informationfrom one data controller to another, and they will have theright to receive certain personal data in a structured,commonly used and machine-readable format. These rightsare complex and not absolute. Practices should ensure thatthey understand when they apply and have a process in placeto deal with them, should patients wish to exercise them.

Key actions that practices should have taken or need toaddress now

•Be aware that the law is changing and familiarise yourselfwith ICO guidance. Regularly check the ICO website athttps://ico.org.uk/ to review updates as they are published.Discuss who will lead this process within the practice.

•Start documenting exactly what data you hold, how it iscollected, how it is stored, who has access to it and whoinformation is shared with. It will then be easier to comparethe current data set-up with GDPR requirements and identifyany gaps in the processes.

•Identify the legal basis for processing the personal data thatyou hold. If you are relying on consent, review how you seek,record and manage consent and consider if you need to makeany changes.

•Review your current privacy notices and consider makingchanges now to ensure they are GDPR-ready. They should betranslated into other languages as necessary to meet the needsof your patient population, and adapted for children and othervulnerable patients so that they can be easily understood.

•Update your subject access request procedures and plan howyou will handle requests within new timescales and providerecords in the required formats.

•Develop a policy for reporting data breaches to the ICO,identifying who will assist and make decisions about whatinformation to provide and when.

•Consider providing staff training on the changes over thecoming months, so that they are all aware of theirresponsibilities in advance.

Hopefully the above will provide you with a starting point toget up to speed, and aid transition to the new regulations.

References

1 https://ico.org.uk/media/for-organisations/documents/1624219/preparing-for-the-gdpr-12-steps.pdf

2 https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/

3 https://ico.org.uk/for-organisations/guide-to-data-protection/privacy-notices-transparency-and-control/

Data Protection is Changingby Dr Rachel Birch

PRACTICE MANAGERS

24 /MAY

Data Protection is Changing - UPDATEby Dr Rachel Birch

PRACTICE MANAGERS

As a follow up to the article on Pages 22 and 23, Dr RachelBirch, Editor-in-Chief of Practice Matters, provides furtherdetail in two important areas that will be subject to changeunder the GDPR.

READ THIS ARTICLE TO:

•Get the latest updates on data protection•Ensure your own practice is ready before the new regulations

With only a matter of weeks until the 25 May 2018 deadline,it is important for practices to prepare themselves for theimplementation of the EU General Data Protection Regulation(GDPR) (1). With significant coverage in the media about theGDPR, patients may well be familiar with some of thechanges to existing law. Two areas in particular may be ofinterest and importance to patients: the patient’s right ofaccess and confirming fair processing of their data.

Subject access requests

Picture the scene. It is 25 May 2018 and the practice receivesa subject access request, in writing, from Mr S, a frequentattender who, in addition to extensive medical records on thepractice computer system, also has two thick volumes ofLloyd George GP records. Mr S informs you he knows hisrights and has waited until today to make his request, so thathis request will be processed under the new rules.

Would you be ready for this scenario?

What information can the patient request?

The GDPR states that individuals will have a right to obtain:

•confirmation that their data is being processed•access to their personal data•other supplementary information, largely corresponding toinformation that should be provided in a privacy notice.

The GDPR clarifies that allowing individuals to access theirdata is so that they are aware of, and can verify, the lawfulnessof the processing.

However, in terms of requests for copies of medical records,there may be varying reasons why patients may makerequests, including keeping a record for personal reference, tojog their memory of distant events, or to investigate apotential complaint or claim.

Irrespective of reasons, patients are entitled to make subjectaccess requests and they do not need to provide a reason fordoing so.

In this scenario, it transpires that the patient is asking forcopies of all of his medical records. He has put his request tothe practice in an email and has requested an electronic copy.You do not have a note of his email address on your computersystem.

On looking at Mr S’s request further, it appears he made a

subject access request three months ago and obtained a fullcopy set of his medical records.

How should you verify the patient’s identity?

Before proceeding, can you be sure that the person emailingyou is the patient to whom the record relates? If you are inany doubt, it is reasonable to ask the patient to provide moreinformation, such as a date of birth, a passport or a birthcertificate.

Do you have to provide an electronic copy of the patient’smedical records?

The Information Commissioner’s Office (ICO) has publisheda helpful guide to the GDPR (2), and there is specificreference to an individual’s right of access to information. TheGDPR states that if a subject access request is madeelectronically, you should provide the information in acommonly used electronic format.

The GDPR also makes a best practice recommendation that,where possible, organisations should be able to provideremote access to a secure self-service system, which wouldprovide the individual with direct access to his or herinformation. If this is not currently possible, you couldconsider whether it is feasible or desirable to develop suchsystems in the future.

How long do you have to comply with the subject accessrequest?

Information should be provided without delay, but you willnow have 30 calendar days to comply, rather than the previous40 days.

You may be able to extend this period by a further two monthswhere requests are complex or numerous. However, if youneed this further time, you must inform the patient within 30calendar days of the receipt of the request and explain why theextension is necessary.

It is important that you consider if your current system canmeet this demand, if you have enough administrative staff,and whether they have received training on the new rulesunder the GDPR. Now is a good opportunity to update yourpractice protocols and procedures.

Can you charge a fee?

In most cases you will no longer be able to charge a fee.However, the ICO states that you can charge a “reasonablefee” when a request is “manifestly unfounded or excessive”,particularly if it is repetitive.

You may also charge a reasonable fee to comply with requestsfor further copies of the same information. However, this doesnot mean that you can charge for all subsequent accessrequests.

MAY / 25

Data Protection is Changing - UPDATEby Dr Rachel Birch

PRACTICE MANAGERS

Can you refuse to comply with his request?

The GDPR states that you can refuse requests that are“manifestly unfounded or excessive”. However, if you refusea request, you must tell Mr S why, within one month, andinform him he has a right to make a complaint to the ICO.

It would be better to explore Mr S’s reasons for the repeatrequest – perhaps he has mislaid his previous copy or nowwants it in an electronic format. In any case, three months haspassed since his last request, so you may wish to clarify it isjust his recent information within his medical record that herequires.

What about third party information?

You should remove third party information before disclosingthe records to Mr S. Third party information is that whichdiscloses information relating to or provided by a third partywho has not consented to that disclosure; for example,information provided by relatives in confidence.

Usually the identity of treating clinicians is not consideredthird party information. However, personal details, such as thefact that Dr A saw the patient as Dr B was sick, should beredacted, as this is clearly confidential information relating toDr B’s health.

You should also consider redacting any information that, ifreleased, may cause serious harm to the physical or mentalhealth or condition of the patient, or any other person.However, such circumstances are rare.

If you have any concerns regarding whether to redact specificinformation, contact Medical Protection for further advice. Transparency and fair processing

As has always been the case under the existing DataProtection Act 1998, practices have an obligation to informtheir patients what they are doing with their data. However,the GDPR will bring in more detailed and specific rules onproviding privacy information to data subjects. The ICO haspublished specific guidance (3,4) about such privacy notices. When should information be provided?

Privacy notices should be used to inform patients at the timeof collecting their data. Therefore, for example, informationshould be made available to patients when they register withyour practice.

However, you should consider other situations when it wouldbe appropriate to provide privacy information. This can bedone by imagining yourself in the patient’s shoes – are thereany ways you use information in a way that patients wouldnot expect?

How should data be provided?

The GDPR places emphasis on the importance of privacynotices being easily accessible to patients. Information withinsuch notices should be concise, truthful and written in clearstraightforward language.

Consider the various groups of patients who are registered atthe practice and their differing needs. It may be better toprovide separate notices for each category of patient. Forexample, if your clinicians consult with teenage children, withcapacity to make their own health decisions, you must ensurethat privacy notices are available appropriate to their level ofunderstanding. The same principles would apply to vulnerableadults.

Privacy notices should also be translated into other languages,as necessary, for your non-English-speaking patients.

What data should be provided?

In order to decide what to include, you must first identifywhat personal information you hold and how it is used.

Once you have done so, you must provide the followingnotice within privacy notices:

•the data controller’s identity •the data protection officer’s contact details •the purpose of the processing •the legal basis for processing •the categories of personal data concerned•the potential recipients of personal data •how long the data will be retained •a list of the data subject’s rights •any safeguards that will be used if data is to be transferred toa country outside the EU.

In addition, patients must be informed that they can complainto the ICO if they believe there is a problem with how theirdata is being handled.

Where should you display the privacy notice?

You may choose to use various methods to display thisinformation, including posters in the waiting room, leaflets atreception, information sheets attached to registration formsand letters to patients.

You could publicise the privacy notice on your practicewebsite, with links to the relevant information.

It is important to keep notices under regular review andupdate them with any changes.

Further advice•The ICO has published the Data Protection Self Assessment tool (5),incorporating helpful checklists to assess your compliance with dataprotection law and identify what steps you need to take at this stage to beGDPR compliant on 25 May 2018.

References(1) .https://www.eugdpr.org/(2).https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/(3).https://ico.org.uk/for-organisations/guide-to-data-protection/privacy-notices-transparency-and-control/privacy-notices-under-the-eu-general-data-protection-regulation/(4).https://ico.org.uk/for-organisations/guide-to-data-protection/privacy-notices-transparency-and-control/(5).https://ico.org.uk/for-organisations/resources-and-support/data-protection-self-assessment/

26 / MAY

Are you ready for NHS data security requirements? – GDPR,DSP, IG Toolkit

While much has been written and said about the EU’s GeneralData Protection Regulation (GDPR), the compliance deadlinefor which is 25 May this year, GP practice managers need tobe aware of another set of data security requirements – whichshould have been met by April.

The ‘2017/18 Data Security and Protection Requirements’mean that all health and care organisations will be expected totake steps to implement 10 data security standardsrecommended by the National Data Guardian. From April2018 the new Data Security and Protection Toolkit (DSPToolkit) replaced the Information Governance Toolkit (IGToolkit). It now forms part of a new framework for assuringthat organisations are implementing the 10 data securitystandards and meeting their statutory obligations on dataprotection and data security.

The reality of the regulations

Firstly, it’s worth pointing out that the regulations will becomepart of the CQC inspections. When considering data securityas part of the ‘well led’ element of their inspections, the CareQuality Commission will look at how organisations areassuring themselves that the steps set out are being taken.

General Practices, contracted to provide primary care essentialservices to a registered list under GMS, PMS or APMS, mustcomply with the requirements, as part of the data security andprotection requirements set out in that contract. That said,some requirements will be fulfilled by CCGs or NHS EnglandRegional on behalf of practices.

What do you need to do?

With the above in mind, what do the regulations actuallymean for practices and what should you now have in place?

First of all, you should have familiarised yourself with the 10standards. We’ve produced a handy, downloadable document,which can be accessed here:

http://practiceindex.co.uk/img/the-10-data-standards-for-healthcare-providers.pdf

Otherwise, key points of interest that practice managers need

to be aware of, broken down into the separate sections of thepolicy document are:

Senior level responsibility: Each practice must have a namedpartner, board member or equivalent senior employee to beresponsible for data and cyber security in the practice. TheCCG as commissioner will be responsible for providingspecialist support to this role but each practice remainsaccountable.

Completing the Information Governance Toolkit v14.1: Eachpractice remains accountable and responsible for completingthe current GP IG Toolkit with a recommendation thatpractices attain level two as a minimum. From 2018/19onwards, it will be replaced with a new approach to measureprogress against the 10 data security standards.

The commissioned GP IG services are available to supportpractices in this. The locally commissioned GP IT Deliverypartner will also be contractually required to complete thecurrent IG toolkit to at least level two for their organisationand the services delivered under the GP IT contract.

Complete the GDPR Checklist: NHS Digital will publish achecklist to support public authority organisations (includinggeneral practices) in implementing the requirements of GDPRwhich they will be required to comply with from May 2018.General Practices should complete this checklist to ensurethey will be able to meet their legal obligations from May2018.

Each general practice will be accountable and responsible forcompleting this, including the appointment of a DataProtection Officer (DPO). More information on GDPR can befound here:

https://practiceindex.co.uk/gp/blog/data-protection/data-security-gdpr-dont-next-headline-maker/

Training Staff: Each general practice is accountable forensuring all staff complete appropriate annual data securityand protection training. Online training is available. Thistraining replaces the previous Information Governancetraining while retaining key elements of it and adding a newsection on cyber security. More information can be found at

https://www.elfh.org.uk/programmes/data-security-awareness

Are You Ready for NHS Security Requirements?by Practice Index

PRACTICE MANAGERS

MAY / 27

Are You Ready for NHS Security Requirements?by Practice Index

PRACTICE MANAGERS

Continuity planning: Each General Practice is required tocontinue to maintain a business continuity plan, which willinclude the response to data and cyber security incidents.

Reporting incidents: Each general practice is accountablefor ensuring data security incidents and near misses arereported to CareCert in line with reporting guidelines.Practices will be supported by the commissioned GP ITand GP IG services in the reporting and managing of theincident.

Unsupported technology: CCGs must ensure for allsupported general practices the following:

•Identify unsupported systems (including software,hardware and applications); and

•Have a plan in place by April 2018 to remove, replace oractively mitigate and actively manage the risks associatedwith, unsupported systems.

NHS Digital good practice guidance on the management ofunsupported systems can be found here:

https://www.digital.nhs.uk/cyber-security/policy-and-good-practice-in-health-care/legacy-hardware-software-unsupported-platforms/good-practice-guide

On-site technology assessments: CCGs must ensure thecommissioned GP IT delivery partner carries out thefollowing for all supported general practices and GP ITinfrastructure. General practices are required to fullysupport such assessments.

Checking IT supplier certification: All parties whocommission or procure IT Systems i.e. individual generalpractices, CCG, GP IT Delivery Partners and NHS Digital(GPSOC) will ensure that any supplier of IT Services,infrastructure or systems used in general practice have theappropriate certification. CCGs will ensure commissionedGP IT services include access to specialist technical advicefor IT procurement.

When preparing for the new regulations, you may considerthat you need to increase your organisation’s understandingof data and cyber security. The 10 Steps To Cyber Securitywhich you can find here:

https://www.ncsc.gov.uk/guidance/10-steps-cyber-securitymay prove helpful.

Data security and data sharing is a hot topic – and willcontinue to be so over the coming months – so keep an eyeon Practice Index and The Dispensary Gazette for moreinformation.

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English Pharmacy Regs Review...by Ailsa Colquhoun

DDA NEWS UPDATE

A review of the NHS (Pharmaceutical andLocal Pharmaceutical Services)Regulations 2013 has uncovereddisincentives for dispensing practices toengage in collaborative working/practiceamalgamations.

It has also agreed that legislationsurrounding dispensing rights is overly

complicated, resulting in confusion for contractors andpatients.

Following consultation with organisations including theDDA, the Department of Health and Social Care haspledged to review and consider whether the regulationsrelating to dispensing rights should be redrafted forsimplicity.

It has also pledged to monitor the situation regardingamalgamations involving dispensing practices, andmake a further assessment by the end of 2018-19financial year.

Other concerns raised by the review include the

revelation of “strong evidence of prescription directionto some distance selling pharmacies”.

A recommendation has been made to the DHSC toconsult on the introduction of a new requirement fordistance-selling pharmacies to declare any vested orsignificant interests.

Regulations relating to pharmacy applications in ruralareas will also be fine-tuned.

A further review of the regulations will be published by31 March 2023.

The review can be read in full here:

https://www.gov.uk/government/publications/nhs-pharmaceutical-and-local-pharmaceutical-services-regulations-2013-post-implementation-review

Article used with permission and taken from theDispensing Doctors’ Association:

https://www.dispensingdoctor.org/

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30 / MAY

GDPR The GDPR for GPsBy Charlotte Harpin and Emma Kewley of Browne Jacobson LLP

From 25 May 2018 the General Data Protection Regulation(‘the GDPR’) will govern the use of personal data in theUK. Organisations processing personal data must complywith the GDPR.

The GDPR turns best practice under the Data ProtectionAct 1998 into legal obligations and many of therequirements of the GDPR will be familiar. Some keychanges are:

•Increased penalties for any breach of the GDPR;

•Charges for providing copies of information in response tosubject access requests have been mostly removed and thetime for responding has been shortened;

•Public authorities, which includes GPs, must appoint aData Protection Officer (‘DPO’);

•High risk processing will require a Data Protection ImpactAssessment;

•The need for data protection by design and by default;

•Regulators, including the Information Commissioner’sOffice, must be informed of a data breach within 72 hoursof a data controller becoming aware of the breach;

•Enhanced requirements of transparency;

•A greater focus on consent and specific requirements forvalid consent. In particular, a positive “opt-in” is requiredand consent must be freely given. In the health context,there are other grounds for lawful processing that will bemore appropriate than consent. The ICO’s view is thatpublic authorities should avoid relying on consent unlessyou can confidently demonstrate it was freely given. Accountability and governance

There is a strengthened focus on transparency and theintroduction of a principle of ‘accountability’, requiring allorganisations to demonstrate compliance. Important stepsto take now are:

•If providing NHS services appoint a DPO and allocatesufficient resources to support them.

•Even if not providing NHS services, a DPO will still beneeded when carrying out large scale processing of specialcategory data (which includes health data).

•DPOs can be shared between organisations.

•Review information governancepolicies to ensure they are up-to-date and enable clear DPOmonitoring/reporting

arrangements.

•Ensure contracts are GDPR compliant, including any“data processing” arrangements e.g. records storage. Notethat the NHS Standard Contract is currently being amendedto reflect the GDPR.

•Evidence compliance by keeping records of riskassessments and advice given by the DPO.

•The ICO is preparing a draft privacy impact assessmenttemplate1 which GPs should use for high risk dataprocessing.

Subject access requests (SAR)

GPs should consider how they will deal with SAR in thenew shorter timeframe, as well as with the other datasubject rights under the GDPR (these include: rectification,restriction, objection, erasure, portability).

Summary Guidance is being published by the InformationGovernance Alliance to assist the NHS with the GDPR.This will cover data protection accountability andgovernance, implications of the GDPR for health andsocial care research, consent and personal data breachesand notification.

It is important to carry out an audit to establish whatpersonal data is currently being held and how it is beingprocessed. Policies and procedures should then bereviewed to ensure they reflect the fundamental principlesof the GDPR. Proactive and responsive engagement withthe issues presented by the GDPR is essential.

Charlotte Harpin is an associate lawyer and Emma Kewleyis a solicitor in the insurance and public risk team atBrowne Jacobson

Charlotte Harpin tel: 0330 045 2405Emma Kewley tel: 0330 045 2380Charlotte Harpin E: charlotte.harpin@brownejacobson.comEmma Kewley E: emma.kewley@brownejacobson.com

© Browne Jacobson LLP 2018

1 https://ico.org.uk/media/for-organisations/documents/1595/pia-code-of-practice.pdf

Every year a document is published on the internet titled PrescriptionCost Analysis. It isn’t the most exciting name for a document, but fordispensary managers it can give a rough and ready guide to themedicines which are most prescribed and dispensed across England.

Whilst there may be demographic reasons why practices who dispensein Scotland or Wales would have slightly different prescribing patterns,this document can be used to assess which of your medicines you shouldbe looking at with regards to profitability and cost.

As always, the clinical decision overrides all other considerations and itmust be that the best medicine for the patient is chosen to treat theircondition.

As part of your CPD why not take some time to look at the documentsavailable in more detail. They can be found at:

http://digital.nhs.uk/catalogue/PUB30246

The various documents explain such terms as NIC and “cost” and alsohow the data has been calculated.

Consider and Reflect on how these documents could be used to look atyour own prescribing and dispensing practices.

Is the volume of prescriptions written rising?

Is the cost to the NHS for dispensing medicine rising or falling?

What about the average cost of an item dispensed?

BNF CHEMICAL NAME

Atorvastatin

Levothyroxine Sodium

Omeprazole

Ramipril

Amlodipine

Simvastatin

Aspirin

Lansoprazole

Colecalciferol

Bisoprolol Fumarate

Salbutamol

Metformin Hydrochloride

Paracetamol

Co-Codamol (Codeine Phos/Paracetamol)

Citalopram Hydrobromide

Amitriptyline Hydrochloride

Sertraline Hydrochloride

Beclometasone Dipropionate

The Most Dispensed Generics - CPDby Gregory Bull

DISPENSARY STAFF

http://digital.nhs.uk/prescribing

Copyright @ 2018 Health & Social Care Information Centre. All rights reserved.

Prescription Cost Analysis, England - 2017

Summary Prescription Cost Analysis (PCA) provides details of the number of items and the Net Ingredient Cost (NIC) of all prescriptions dispensed in the community in England. The drugs dispensed are listed by British National Formulary (BNF) therapeutic class using the classification system prior to BNF edition 70.

Further analysis of the PCA data will be published later in the year in the Prescriptions Dispensed in the Community publication.

In 2017, £9.17 billion was the cost of prescriptions dispensed in the community. A decrease of 0.41% from £9.20 billion in 2016

In 2017, 1.11 billion prescription items were dispensed in the community. An increase of 0.15% from 1.10 billion in 2016

Key BNF Chapters

BNF CHAPTER BNF CHAPTER DESCRIPTION

01 Gastro-intestinal system

02 Cardiovascular system

03 Respiratory system

04 Central nervous system

05 Infections

06 Endocrine system

07 Obstetrics, gynaecology, & urinary-tract disorders

08 Malignant disease & immunosuppression

09 Nutrition & blood

10 Musculoskeletal & joint diseases

11 Eye

12 Ear, nose & oropharynx

13 Skin

14 Immunological products & vaccines

15 Anaesthesia

18 Preparations used in diagnosis

19 Other drugs and preparations

20 Dressings

21 Appliances

22 Incontinence appliances

23 Stoma appliances