The
text that is red in colour represents, a continuation of the carefully
worded statement released by the New Zealand Department of Health,
apparently without any consultation with community pharmacists.
The government has claimed a "mandate" to introduce
these massive changes, but it is unsupported in reality. Australian
pharmacists should read and understand the rationale, prepare
appropriate strategies, and at least be positioned so as not to
be caught unawares like our New Zealand "cousins".
"How
will the changes help to solve these problems?
The
changes will help to solve the problems by:
Innovation
- These changes will help the development of innovative practices
and assist the development of cheaper services in line with the
needs of medicine users.
Capitalisation - More capital is expected to flow into
the pharmaceutical services to help to improve the range of services
and products provided.
Job satisfaction - The change should allow pharmacists
to choose more diverse career opportunities, make more use of
their skills and negotiate more flexible conditions of employment.
These changes should suit those pharmacists who also have childcare
or other responsibilities.
More and better quality advice - Pharmacists' time will
be freed up to concentrate on using their clinical skills in primary
health care. This will help to reduce medication errors and problems
with drug interactions. Nearly 50 percent of New Zealanders visit
a pharmacist for advice or medication each year.
More accurate health interventions - These changes will
better allow pharmacists to integrate with primary health organisations.
This should make it easier for discussions on the best medicines
for patients and the integration of medical records to take place.
In
addition it is envisaged that pharmacists will become more accessible.
In future they will be next to or inside other primary health
care services -- such as medical centres -- and other large businesses,
such as supermarkets. The distribution of medicine is expected
to improve, particularly in rural New Zealand."
Some
of the above may come to pass, but there is more than one way
to solve a problem.
Surely by giving the existing pharmacy owners political and financial
support, the government would generate better quality services,
because of self interest and professional pride.
Professional services, while needing to be properly remunerated,
are driven by one's own personal standards. Governments typically
take advantage of professionals in this way, in settings such
as public hospitals.
I would debate the latter part of the above comment that the distribution
of medicines will improve in rural New Zealand. This is probably
code for "after giving the prime business to supermarkets,
pharmacy ownership will be limited to rural areas, because it
is not profitable enough for supermarkets to establish in these
areas".
"Are the changes safe?
The
Government has taken a number of steps to make the proposed regime
safer than the existing one. No changes are proposed to the current
requirement that each pharmacy must be under the control of a
pharmacist. The proposed changes include:
A
licensing regime enabling Medsafe to reject unsuitable applications,
for example from people who have been convicted under the Medicines
Act 1981 or the Misuse of Drugs Act 1975.
If the licensee owns more than one pharmacy they will be required
to appoint one of their pharmacists to the position of a "superintendent
pharmacist". This pharmacist is legally and ethically responsible
for the professional standards of the entity that owns the pharmacies.
Pharmacists will be required to maintain their professional competence
under the proposed Health Practitioners' Competence Assurance
legislation.
Medsafe will be able to assess the share structure of companies
applying for licences and restrict errant owners. Medsafe will
also be able to remove licences from unsuitable licensees and
prosecute offenders.
The disciplinary mechanisms and penalties will be strengthened
in the Health Professionals Competency Assurance legislation.
Pharmacies will be required to have security around the dispensing
area so unauthorised people cannot access restricted medicines
when the pharmacist is absent."
Previous
comment has been published in this series illustrating that what
is proposed for the New Zealand model is not really safe. Licences
will be issued to "suitable persons" based on the fact
that they are not illegal drug users. This by no means covers
the range of activities that a "suitable person" could
enter into, once given control of a pharmacy. This aspect is supposed
to be alleviated by using "superintendent pharmacists",
a model which has already been proven to be flawed in UK and US
settings.
"Have
we had non-pharmacist owners of pharmacies in New Zealand before
these proposed changes?
Yes,
we currently have 15 existing 'grand-parented' non-pharmacist
owned pharmacies providing services in New Zealand. There is no
evidence non-pharmacist ownership has jeopardised the quality
or safety of these United Friendly Society (UFS) pharmacies.
A "grand-parenting" provision in the Act allows UFS
pharmacies, operating when the Act was passed, to continue to
operate without meeting the ownership restrictions. These pharmacies
were registered under the Friendly Societies and Credit Unions
Act 1982.
The
one major difference between Friendly Societies and supermarkets
is that the former is a "not for profit" organisation
and is set up for the genuine welfare of its members.
Compare this to supermarkets that are unashamedly set up to chase
profit.
Supermarkets are managed for the benefit of their shareholders,
and those shareholders are often major corporates, not capable
of possessing a social conscience.
How comfortable would you be with, say, a major Australian Bank
being selected as a "suitable person" to own and operate
a pharmacy?
Given their paltry service to small customers and their absolute
desertion from rural areas (often decimating local economies),
they show no concern or social conscience in any way.
They display their return on investor shareholdings as a badge
of honour.
"Profit is not a dirty word" they say, as old-aged pensioners
are left bewildered as to how they are going to receive their
next pension payments and local businesses ponder how they will
survive with no local bank.
How would a superintendent pharmacist stand up to the ruthless
top management of say, a global bank, if a professional dispute
evolved.
Not for long, I suspect.
There is already evidence that supermarket pharmacy owners in
the UK have set up a "black book" on what they would
describe as "recalcitrant superintendent pharmacists",
and the information is exchanged with competitors.
As ownership concentrates through takeovers and mergers of global
supermarket interests, where will the professional jobs be, given
that if you have been "blacklisted", then you may not
have a job at all.
The
Pharmacy Guild of Australia, I believe, could run a very effective
campaign (prior to an election) illustrating what may happen if
a bank became a "suitable person" in Australia. With
the universal unpopularity of banks, it would be far easier to
contrast a pharmacist-only ownership perspective, given that the
landscape is continually being littered with bank victims.
It's worth a thought.
"What do other countries do?
Open
ownership is relatively common internationally. The United Kingdom,
Eire, Poland, Switzerland, Italy, Holland, Norway, Belgium, Hungary,
the Czech Republic, Singapore, Malaysia, and Brazil do not restrict
the ownership of pharmacies to pharmacists. In Canada, with the
exception of Quebec, Nova Scotia and Ontario, the remaining eight
territories allow non-pharmacists to own pharmacies. In the United
States, with the exception of North Dakota, all states allow non-pharmacists
to own pharmacies.
Similar
licensing arrangements to the ones suggested for New Zealand exist
in Ireland, the United Kingdom, Norway, Belgium and Holland.
Ownership
is restricted to pharmacists in Australia, Austria, Denmark, France,
Germany, Luxembourg, Israel, South Africa and Iceland.
Hard
evidence on the impact of open ownership is hard to find. Recent
studies in Australia have tended to support the status quo (restricted
ownership) but they have been limited in scope (a government study
looking at competition in pharmacies which ignored other possible
regulatory means for ensuring the safe and efficient distribution
of medicines) or linked with vested interests (commissioned by
the Australian Pharmacy Guild)."
One
only has to research respected pharmacy journals in the UK and
the US to find the "hard evidence" of the impact of
open ownership.
The Australian system has long been recognised, with envy, by
other supposedly more mature economies (including the US).
We do have a rational system for introducing drugs into Australia,
distributed by a well organised and efficient group of community
pharmacists, and we have the cheapest drug costs in the world.
While there is always room for improvement, it must still be better
to support and refine a successful model based, on pharmacist
ownership.
Is not the Australian success hard enough evidence for the New
Zealand government to model?
"Won't the changes lead to increased bureaucracy and costs?
The
current system of registration and monitoring is in effect a licensing
regime. Current owners are required to adhere to legislative and
contractual obligations and run their businesses according to
good practice codes:
1.
Medicines Act 1981 and the Misuse of Drugs Act 1975
2. Ministry of Health's New Zealand Code of Good Manufacturing
Practice for Manufacture and Distribution of Therapeutic Goods
Part 3: Compounding and Dispensing
3. Pharmaceutical Society's Quality Standards for Pharmacy in
New Zealand
4. Contractual obligations of the Pharmacy Services Agreements
under the Ministry of Health dispensing contract.
The
provisions in the Medicines Act 1981 currently require wholesalers,
packers and manufacturers of medicines to be licensed. The proposed
changes will bring retailers under a similar licensing regime
and result in a small saving for government. The proposed costs
of obtaining a pharmacy license will be in line with the other
medicines licensing regimes."
Bureaucrats
love increasing areas of control.
Giving them a new licencing system on top of what they already
control would constitute a bureaucratic utopia.
A large part of the cost of running a community pharmacy is involved
in compliance with government regulations. Reducing regulation
and other bureaucratic procedures would allow a reduction in costs,
which would ultimately benefit the consumer, through competitive
market forces.
This is the area that the New Zealand government should have looked
at first.
To its credit, the Australian government did, but the implementation
of what is known as the Wilkinson Review, has been painfully slow.
In part, this is because the underlying sentiment of Australian
bureaucrats is for open ownership.
Anything that would assist the enhancement of community pharmacy
would understandably, make that rationale a difficult one to support.
"Will opening up the ownership of pharmacies to non-pharmacists
drive up costs?
The
proposed changes may reduce the cost to the Government of providing
pharmacy services.
The
Commerce Commission can act against any person or company that
acquires, attempts to acquire or assists somebody acquire assets
of a business where that acquisition is likely to substantially
reduce competition in the market place."
As
always, the initial changes will demonstrate cost reductions.
As open ownership concentrates through mergers and takeovers,
market share for these operators will increase.
With increased market share comes increased prices and increased
profits.
Just look at the major Australian banks (and their fees) and Australian
supermarkets.
Australian supermarkets control about 85 percent of the retail
trade through two major entities and a group of operators who
inherited the third player (Franklins), which has had a recent
demise.
It is significant in that a survey of retail profits conducted
two years ago, it was found that the top 1000 businesses in Australia
accrued 87 percent of corporate profits and employed 49 percent
of workers.
The remaining SMEs accounted for 13 percent of corporate profits,
but employed 51 percent of workers.
When the only comparison of prices is between a small group of
major players, there is absolutely no incentive for these players
to actively compete against each other.
Trade Practice bodies, such as the ACCC in Australia, do not appear
to have been effective in preventing the major concentration of
supermarkets accruing to a handful of major corporations.
So how will New Zealand differ?
"Will
community pharmacies go out of business?
The
Government will introduce the changes over a three-year period
so that current owners can diversify their investments before
licensed open ownership starts."
What
a laugh!
With open government support, supermarkets will be given a legal
transfer of the goodwill of all that community pharmacists have
accrued to date.
Is this fair trade?
Obviously, the New Zealand government expects community pharmacists
to go out of business and has given them three years to think
about it.
I sincerely hope that New Zealand pharmacists fight back by amalgamating
their resources to tackle competition "head-on" in a
no-holds dust-up!
"Will
rural pharmaceutical services decline?
More
flexibility will mean new means of distribution are likely to
evolve. The Ministry of Health will be able to require rural pharmacy
services in its pharmacy service contracts.
Providers
of rural pharmacy services will continue to be subsidised."
Of
course these services will decline!
The clue is that they will need to be continually subsidised.
Perhaps competition will speed up as displaced urban community
pharmacists go bush to avoid the supermarket influences, and provide
"real pharmacy".
Perhaps Internet and mail order pharmacies will expand to fill
the void.
Whatever, it will still remain a depressing sight and there is
no way a major supermarket chain would venture into an area that
is not profitable.
What would the shareholders think?
Editor's
Note:
I
started a personal story in the last edition relating to my father,
a senior manager who was employed by one of Australia's largest
supermarket operators, attempting to lobby governments and pharmaceutical
manufacturers to support their bid for pharmacy ownership.
After the inevitable argument (and family split) I suddenly found
that my father began to pilot "pharmacy departments"
in their Katoomba branch store. It was no coincidence that I was
located in my own business, at that time, in Katoomba.
All the goods on offer were heavily discounted by my father in
an attempt to transfer market share.
I
fought back by blacklisting all the pharmaceutical manufacturers
involved in the pilot, and where possible, had any successful
over-the-counter formulas manufactured under my own brand.
An alternative brand offering comprising friendly manufacturers
was also prepared.
Pharmacists rallied from Lithgow to Penrith, with a few extra
dotted in Parramatta, to the common cause.
I
approached the local branch of the Australian Medical Association.
To my surprise, they agreed to blacklist any of those manufacturers
who were involved in marketing prescription only products, and
they extended their influence to four public hospitals, including
a major Sydney teaching hospital, that banned, among other items,
a major brand of paracetamol.
They did not like the concept of open selling discounted drugs.
For
the next three months I began to receive a succession of state
sales managers patting me on the head and advising that "I
should not rock the boat". For the subsequent three months,
the sales manager procession changed to national level.
After six months, I was asked if I would withdraw opposition if
they ceased supporting my father's pilot program.
I
agreed, and my father was forced to shut down his pilot.
That
was in the 1960's, and I believe I was instrumental in holding
back that supermarket's campaign for ownership of pharmacies.
They have never given up, simply altering their strategy by forcing
traditional pharmaceutical manufacturers to supply them with non-scheduled
products and lobbying politically to have the schedules downgraded,
creating more market share for them to acquire commercially.
My
father has since retired, and we are now reconciled.
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