PHARMACY REFURBISHMENT SPARKS CALLS FOR REGULATORY REFORM
A pharmacy on the southside of Edinburgh and a local MP have called for the GPhC to review its regulatory approval process for the use of a temporary pharmacy premises while an existing pharmacy undergoes essential improvement work.
Colinton Mains Pharmacy decided to refurbish its pharmacy premises to improve disabled access, create larger accessible, fully confidential, consulting rooms for their customers and an improved working area for staff. The level of building work required meant it was not possible to operate from the pharmacy site for a couple of months. So to maintain service delivery, the pharmacy hired a ready built and kitted out pharmacy in a container from PortaPharma, to place on the street directly outside the existing premises.
The Goodburn family, who own the pharmacy, contacted the GPhC several months before work was due to start and were surprised to discover they would have to apply for a new temporary premises registration. They were also told they would need to pay the pharmacy’s GPhC annual registration fee again for the entire year, despite the fee being paid for the existing pharmacy for 12 months, with no option of a rebate for the period while the pharmacy undergoing renovation was closed.
The pharmacy superintendent had to complete a lengthy registration application form for the temporary pharmacy, designed for new, temporary pharmacies setting up for the first time at events like festivals or trade shows, not an established pharmacy setting up temporary premises outside their own front door.
Local MP Involvement
Jo Goodburn, pharmacy owner, made contact with her local MP, Dr Scott Arthur, who contacted the GPhC on the pharmacy’s behalf to raise concerns. They have called for the GPhC to carry out a review and provide a more appropriate process more relevant for these specific circumstances.
“The person we dealt with at the GPhC was helpful and acknowledged the form was not really appropriate for what we were doing. It was exactly the same team of people serving the same customers, in the same way, using the same SOPs but in a fully equipped pharmacy container. It was frustrating and time consuming,” explained Jo.
“Then for a small family business to have to pay the annual premises registration fee twice, when you're in a cabin 10 steps outside your pharmacy, seems unfair. Especially when you are told you can’t get a rebate on the licence for your existing pharmacy for the time that it wasn’t in use. The GPhC could have just transferred that portion of our existing licence to cover the period we were in the container and inspected the temporary premises, as they did, to ensure everything was in order”
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scotpharm.com Regulations Disproportionate
Jo believes the regulations for these specific circumstances are disproportionate. She feels there needs to be a balance between ensuring requirements for appropriate safety and regulation are in place and a practical system which will not discourage small independent pharmacies from undertaking major renovation.
“The GPhC needs to know where the temporary pharmacy will be and if anything will be done differently compared to what we normally do. They need a shorter version of the form for these types of temporary pharmacy premises, like the two page Scottish NHS contracts team required. We will write to GPhC now the whole process is finished and ask them to review and, if possible, simplify the system.”
Dr Arthur MP, said in his letter to the GPhC that the Goodburn family had put a lot of effort into planning the refurbishment and had hired a fully fitted pharmacy container to be placed directly outside the pharmacy.
“They have been asked to explain in some detail how they will apply the five Principles of Community Pharmacy which they are already doing and have been regularly inspected and are doing this well. It seems to me that this form may not be appropriate for the temporary measures the pharmacy is putting in place,” he wrote.
“I understand that they have been told there is a regulation in place which means the GPhC cannot do anything to reduce these requirements. I am writing to ask that this regulation should be reviewed, that it should be recognised that the regulation is likely not applicable in these specific circumstances. I would like to suggest that consideration could be given to creating some form of lighter registration process, or the temporary transfer of the existing pharmacy premises registration number, creating a more appropriate method to ensure this type of temporary premises for refurbishment is properly registered and controlled without creating a high cost and time burden which discourages a small community pharmacy from improving their premises,” he concluded.
A Legal Requirement
He received a response from the GPhC explaining regulations require the sale or supply of pharmacy and prescription only medicines take place at or from premises which are a registered pharmacy. It said even where the temporary facility is in very close proximity to an owner- existing registered pharmacy, the new premises must register as a separate pharmacy premises.
It said the organisation did not have discretion to waive the registration requirements, reduce the level of information requested, or transfer an existing premises registration number, based on the temporary nature of the arrangement or the registration of a permanent premises nearby.
The letter did however say it was important to remain focused on public protection while ensuring requirements and processes are pragmatic and proportionate. It added they were keen to review a range of policy and operational matters as part of an improvement programme, including how they deliver on core regulatory functions, including registration and inspection.
Work Now Complete
With work on the premises now almost complete, the pharmacy team are back in the refurbished pharmacy having spent two months in the PortaPharma container, supplied by PortaPharma UK.
“The temporary container was a small space and we also had a big increase in prescriptions at that time so the first two weeks were really hard. With little storage space for prescriptions, we had to contact patients as soon as a prescription was ready for collection so that we had space for the next lot of prescriptions. We found we needed two pharmacists at all times to keep on top of the prescriptions in that space,” explained Jo.
“The PortaPharma itself was fantastic. It is a ready-built pharmacy in a shipping container all set up inside with a consultation room, a small front shop and counter and a dispensary with a controlled drug cabinet and pharmacy fridge and IT connections for the PMR. A lockable, heavy security shutter on the front ensured it remained secure when we were closed.
“Now the staff are back in the newly refurbished pharmacy, they all have very broad grins on their faces. The customers have also been amazed that it is actually the same building when they walk in because it looks so much bigger and brighter!”
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