Control of Entry Consultation

Scottish Parliament

Scottish Government agrees with Royal Pharmaceutical Society on Control of Entry

Earlier this year the Scottish Government ran a consultation on the future of the Control of Entry arrangements for the provision of pharmaceutical care services.

The reason the review was carried out was the growing number of conflicts in rural and remote areas of Scotland between dispensing doctor practises and applicants seeking to open pharmacies in those areas. The dispensing doctor practises tended to mount very emotive campaigns that raised local fears that the opening of a community pharmacy would lead to the closure of local medical services.

The Royal Pharmaceutical Society was concerned at the level of fear and anger that these campaigns were causing in parts of rural Scotland.  The Society was also determined to confront these campaigns as they threatened the good standing of the profession, not just in the areas where dispensing doctors felt threatened, but also in the Scottish Parliament where news of these campaigns were causing some MSPs to think pharmacists were causing unnecessary trouble.

The decision to launch a consultation on modernising the Control of Entry arrangements was therefore something we welcomed as an opportunity to clarify the regulations where necessary but also to have an open debate about who should provide pharmaceutical care.  Overall however we started from the position that the regulations are fundamentally sound and did not require any radical change in the either the way applications are decided or the basic principal that pharmaceutical care should be provided by pharmacists wherever possible.

We responded positively to the consultation, agreeing with many of the suggestions to help make the process of allowing a new pharmacy to open more transparent.

The Scottish Government has now published its review based on the consultation responses.  The document strongly backs the value of pharmacy in rural Scotland.  To quote a key line, “the Scottish Government remains committed to the principle that all patients in Scotland should have access to the full range of pharmaceutical services from conveniently located pharmacy premises.”

There are some changes that the Scottish Government have proposed in the Review. Applications will go through a ‘pre-application’ stage where the local health board will decide if it is strong enough to warrant it being heard by the Pharmacy Practice Committee (PPC). The Review also proposes that the Health Board allows the Area Medical Officer to nominate a representative to sit on the PPC.  This will hopefully counter some dispensing doctor claims that PPCs lack transparency.

The application form will be changed in future as well in order to make applicants submit a more thorough case for a new pharmacy. There will also be a year-long period between applications that have been rejected from being re-submitted unless circumstances can be shown to have radically changed.

The Society welcomes these changes.  They do not alter the fundamental principle that the pharmacy profession is best placed to offer pharmaceutical care.  This Review sprang from a sustained campaign to make it impossible to open a pharmacy in rural Scotland, the result of the Review however is to reject those calls and instead to propose a series of modernisations that will preserve the best traditions of pharmaceutical care in rural and remote Scotland.

We will continue our dialogue with the Government, and with MSPs, to ensure that the worth of our profession continues to be understood and that the best arrangements are in place to deliver pharmaceutical care for all patients in Scotland.