Date of prep: December 2020
Prescribing information and
adverse events reporting
For healthcare professionals only
The Cabinet Secretary for Health and Sport Jeane Freeman has responded robustly to the recently published report on the inquiry into the supply and demand of medicines in Scotland.
In a letter to the convenor, Ms Freeman outlined a range of criticisms about the report produced as a result of the inquiry.
“While the Committee’s report highlights a number of important issues for Government, the NHS and manufacturers of medicines, the executive summary fails to be truly representative of the positive evidence provided to the Committee that is captured within the body of the report. It is particularly disappointing that the Committee has used the report to unfairly and unjustifiably criticise the leadership of those who gave evidence.”
The letter comes a few weeks after the Directors of Pharmacy in Scotland also wrote a letter to the convenor complaining at the assertion that there has been a lack of leadership around various aspects of the supply of medicines in Scotland.
The inquiry into the supply and demand for medicines found an ‘incoherent system’ which fails to ‘put patients first’.
Published in late June this year, the inquiry made 129 recommendations highlighting failures of NHS Scotland to modernise systems, collect and share data, or provide any meaningful analysis of the impact of medicines on individual patients.
The Health and Sport Committee’s report describes a system ‘burdened by market forces, public sector administrative bureaucracy and under-resourcing, inconsistent leadership and a lack of comprehensive, strategic thinking and imagination, allied to an almost complete absence of useable data.’
In her letter to the convenor, Ms Freeman began by making the point that the report was published despite there being considerable changes made to cope with the COVID-19 pandemic and highlighted the fact that NHS Scotland did not at any time run out of medicines during this difficult period.
“It is worth noting that the Committee’s inquiry concluded taking evidence as we entered the current public health emergency. Throughout the COVID-19 pandemic, the NHS in Scotland has undertaken considerable change to minimise the loss of life, while maintaining access to critical NHS service, including access to medicines. It is the systems and leadership, which the committee has criticised within the report, which provided the remarkable resilience that has ensured that medicines have continued to be provided to patients, effectively and safely.
“Despite the challenges of increasing global demand for medicines as a result of the COVID-19 pandemic, the NHS in Scotland did not run out of medicines, instead of managing supply and demand in immensely challenging circumstances. It is, therefore, disappointing that the Committee’s report risks damaging the people of Scotland’s trust in the NHS and the care that it provides.”
She continued by questioning the quality of the report criticising both the scope and quality of the information presented. She goes as far as to say that the report is misleading.
“As I outlined in my letter to the Committee dated 28 July 2020, the report goes far beyond the published remit and as such contains misunderstandings, inaccuracies and inconsistencies. A number of areas highlighted, both during the evidentiary hearings and within the report, are not within the control of the Scottish Government and remain reserved to the UK Government.
“Whilst the Scottish Government will continue to represent the people of Scotland and ensure that decisions taken by the UK Government, such as exiting from the European Union Transition Period, have minimal impact on the NHS in Scotland and the people it cares for, issues represented in the report are misleading and do not capture the nuances of reserved and devolved responsibilities.”
Responding to issues raised in the report around the prescribing and dispensing of medicines Ms Freeman talked about the problems of wasted medicines and the clinical and financial burden of non-adherence to medicines. She sought to highlight the investment by the Scottish Government in the NHS Pharmacy First service and hinted that the pharmacotherapy service may well seek to utilise the skills of community pharmacists in future.
“A significant reduction in waste and costs can be generated by better medicines use. At a patient level, caring for patients with multi-morbidities and polypharmacy is an increasing global challenge. A number of prescribing strategies have been published which lead to structured reviews of appropriateness, efficacy and tolerability of treatment. Through consideration of more appropriate treatment or non-pharmaceutical management of a condition, there is the potential to reduce medication burden on patients.
“A substantial component of waste is where medication is not taken as prescribed (often referred to as non-adherence) and we are working to develop tools to identify patients with medication adherence issues to allow them to be prioritised for clinical review. Medicines management continues to develop as an expert field in NHS Scotland, consistently delivering improvements to patient safety, effective care and efficient spending.
“The Scottish Government has introduced the new NHS Pharmacy First Scotland service in July 2020. NHS Pharmacy First Scotland ensures that community pharmacies are the first port of call for minor illnesses and common clinical conditions. NHS Pharmacy First provides all users with a consultation, providing advice which includes self-care; referral to another healthcare professional such as an optometrist; and/or treatment from a nationally approved list of medicines, ensuring consistency for patients and cost-effectiveness for Boards
“The Medicines: Care and Review service, similar to NHS Pharmacy First, provide greater opportunities to support people with long-term conditions by identifying and prioritising risk from medicines with a view to minimising adverse drug reactions, address existing and preventing potential problems with medicines and providing structured follow-up and interventions where necessary.
“My officials are also considering options to enhance the Pharmacotherapy Service by using community pharmacists, alongside pharmacists and pharmacy technicians already working in GP practices. With recent access to the Emergency Care Summary, community pharmacists are able to provide more effective advice and support to patients, in particular during out-of-hours periods.”
The inquiry was particularly scathing around the information technology applied to the supply of medicines. Ms Freeman defended the Scottish Government progress in this area by highlighting the development of the Hospital Electronic Prescribing and Medicines Administration (HEPMA) system. She welcomed the focus on patient outcomes and referred to the Cancer Medicines Outcome Programme (CMOP) as an example of the successful use of patient-reported outcomes to improve care.
“As the committee’s report acknowledges, there is minimal provision to collect information about the purposes for which medicines are prescribed and the outcomes achieved by particular medicines or among particular groups. While this gap is a common feature of health systems in the UK and internationally, it is a significant constraint on the development of medicines policy and is a particular focus for the pharmaceutical industry, for whom data about outcomes achieved is of obvious scientific and commercial interest.
“These actions are being considered as part of a range of ongoing policy initiatives including our Digital Health and Care Strategy, the Chief Medical Officer’s Realistic Medicine approach and the ongoing development and implementation of a Hospital Electronic Prescribing and Medicines Administration (HEPMA) system.
“Returning to the subject of medicine outcomes, I warmly welcome the committee’s acknowledgement of the success of the Cancer Medicines Outcome Programme (CMOP). Cancer medicines account for the highest proportion of new medicines introduced within NHS Scotland each year. Currently, most of the information about the efficacy and side effects of cancer medicines is obtained through the results of clinical trials. However, the outcome of these medicines in the local populations may be different to those reported in trials.”
Pharmacy in Practice is a UK pharmacy publication with its roots in Scotland.