This week the GPhC alerted everyone to a consultation it was running in relation to increasing its fees. As I read the consultation a few thoughts struck me:
1. The reasoning and justification is not clear and detailed. How will the additional revenue be utilised?
2. Blanket raises disproportionately affect some groups more than others. How is this impact assessed?
3. There is currently a climate of financial pressure not just in the healthcare sector but also on individuals. Has this been recognised in the consultation?
What do you think?
https://www.pharmacyregulation.org/get-involved/consultations/consultation-draft-changes-fees-2023
My full response below:
The reasoning for the proposed fees increase has not been properly explained or justified. The cost of living crisis (including increase in utilities and inflation) affects all individuals and businesses. The government has said that the cost of regulation must be borne upon those who are regulated. However this group has not received any dispensation or increase in remuneration and is expected to maintain appropriate buffers to absorb additional operational costs which have been assured are temporary.
Council minutes produced recently show that the GPhC holds a significant amount in reserve, so the need to justify a fee increase is not unwarranted. The pharmacy landscape has been changing rapidly for several years; it is still not clear what additional operational burden and cost will be required by the GPhC in its associated regulatory activities.
Pharmacy premises in particular have been under significant pressure to safely deliver services in a climate of significant financial pressure. £645m has recently been announced for new services, it is not clear how this money will be delivered. And the existing framework for dispensing medicines has meant that several pharmacies have been operating at a loss. The government expects the community pharmacy sector to prove its value via plans and outcomes it will deliver. I have yet to see a costed and detailed plan about how the GPhC plan to utilise the additional revenue it will garner. In the current climate of personal and organisational financial pressure, I would expect the GPhC to hold itself to its own standards by providing a person-centred approach with some empathy and more reasoned justification to those pharmacy owners and individual pharmacy professionals at the coalface.
Community pharmacies have recently been closing at a rate close to 11 a month, the tone of this consultation document does not convey an organisation that is engaged with the pharmacy landscape and its current challenges.