Pharmacy concerns overblown
THE OPINION piece headlined ‘Pharmacy sector in need of medicine’ (Sunday Gleaner, July 15, 2018) contains a number of inaccuracies relating to Government’s programmes to ensure access to healthcare for those least able to afford it.
The Ministry of Health – of which the National Health Fund (NHF) is one agency – is, therefore, keen on setting the record straight, with the goal to maintain transparency and accountability to the public.
The recent shortage of drugs is triggered by a variety of factors, none of them to do with the Government’s programmes to provide users of the public health system with prescription drugs.
Rather, these factors include business decisions by overseas manufacturers to voluntarily discontinue supplies, and global shortages affecting active pharmaceutical ingredients, without which finished pharmaceutical products cannot be supplied.
Other factors that may impact shortages include the growing demand for medicines as a result of people living longer and outbreak of new diseases; manufacturers choosing to satisfy their in-country demands first, in the face of global shortages; and a lack of an early warning system within the marketplace to notify of impending drug shortages, thereby providing adequate opportunities to prepare for such shortages.
The Ministry of Health, including the NHF, and the Jamaica Association of Private Pharmacy Owners are, in fact, now in talks to see how best we can collaboratively plan for similar future scenarios.
FAIR COMPETITION ACT
The Fair Competition Act (FCA) generally applies to the Government/ Ministry of Health. Section 54 of the act provides that: “Subject to any provision to the contrary in or under this or any other act, this act binds the Crown.” Notwithstanding, we are of the view that, in this instance, the provisions of the act are not applicable to the Ministry of Health/NHF in the delivery of this aspect of public health services.
The ministry wishes to reiterate its commitment to universal access to health and universal coverage. Universal access to health and universal health coverage imply that all people and communities have access, without any kind of discrimination, to appropriate and timely, quality health services according to the needs, as well as access to safe, effective and affordable quality medicines, while ensuring that the use of such services does not expose users to financial difficulties, especially groups in conditions of vulnerability. The Government must, therefore, ensure access to essential medicines.
In 2013, the Government took the decision that the NHF would take over the management of pharmacy services in the public sector. Accordingly, the mandate of the NHF was expanded to include, as outlined in the NHF Act (amended in 2011), “make pharmaceutical medical supplies accessible and available to government-owned health facilities” and “carrying on the business of chemists, druggists, manufacturers, importers and distributors of and dealers in all kinds of:
pharmaceutical, medical, chemical, and other preparations, compounds and articles or things;
medical and surgical supplies, utensils and implements;
mechanical, electrical, electronic, sonic, radiographic, scopic and other equipment for use in governmentowned health facilities.”
In delivering on this mandate and in response to challenges being experienced in the delivery of pharmacy services, notably inadequate access points, overcrowding and long waiting times, the NHF in 2016 developed a programme of public-private partnership.
An initial pilot of the programme was executed between December 2016 and March 2017, which saw the participation of five pharmacies in May Pen and seven in Kingston. An additional five pharmacies were engaged in Montego Bay, bringing the total to 17, and the programme extended to June 2017.
The pilot was successful in signalling its potential to contribute to improved access to medications for the general public, with two very important criteria satisfied:
Customers validating the need for this service and their satisfaction in how the service is delivered; and
Service providers expressing high levels of satisfaction with the programme and them having the necessary resources and tools to supply the service to the customers.
NO UNFAIR ADVANTAGE
The programme’s expansion is in an effort to provide improved services, including a reduction in waiting time to public-sector patients who will fill approximately 2.5 million prescriptions this year. Since 2016, the 17 pharmacies in the pilot have filled more than 73,000 prescriptions, demonstrating a clear contribution to the public good.
To be eligible to participate in the programme, public health patients must have prescriptions for medication that are on the government-approved Vital, Essential and Necessary (VEN) list of drugs. The patient is expected to pay a minimal fee of $200 per prescription, which is to offset administrative costs at the participating private pharmacies.
The engagement of participating pharmacies, meanwhile, is based on their ability to deliver service to those in need, in a timely and efficient manner – on the basis of a set of criteria in line with programme objectives.
The criteria include being strategically located in proximity to a major hospital/health centre or town centre; willingness to accommodate NHF inspection prior to engagement and auditing based on defined schedules during the contract period; possess adequate and comfortable waiting area to accommodate six to 10 customers; and possess adequate and proper storage facilities to accommodate approximately 190 VEN list items.
In addition to a variety of other criteria, participating pharmacies are required to be able to process approximately 30 scripts (indicative) per day with an average waiting time of 30 minutes per customer and ensure commitment to treating all patients, public and private, with equity.
DRUG SERV AND NHF CARD
Drug Serv windows, of which there are 105, serve predominantly public patients. Of the 105 Drug Serv locations, only 10 see private patients, and even then, these are patients who are many times unable to access their drugs from private pharmacies. Further, the provision of services at these 10 locations was inherited when the NHF took over the operations of Health Corporation Limited in 2011.
The NHF card provides subsidies to beneficiaries of all ages to treat 16 chronic illnesses, and currently has more than 380,000 active beneficiaries. Important to note is that private pharmacies that accept the card under the NHF Pharmacy Provider programme also benefit.
Increased enrolment for the card brings increased business to their doors. Since its inception in 2003, NHF has paid out more than $32 billion to NHF pharmacy providers, as the number of beneficiaries has increased. At the same time, the number of private pharmacies signing on as NHF pharmacy providers have grown from 376 in 2015 to 405 in 2018. There are currently some 430 private pharmacies in Jamaica.
INTERNATIONAL TENDER
The NHF, being the designated agency to procure drugs on behalf of the Government of Jamaica for the islandwide network of public health facilities, does so by competitive international tender. This results in cheaper costs for drugs. In accordance with the Government’s policy, which prescribes no user fee for services at public health facilities, including the provision of drugs, through the NHF-managed public-sector pharmacies, patients of public health facilities receive VEN list drugs at no cost.
Meanwhile, there are some private patients, particularly those battling cancer, kidney disease and HIV, who have difficulty sourcing certain medications. From time to time, the NHF provides support to the private sector to serve these patients. There are also some critical, hard-to-source pharmaceutical and medical supplies not stocked in the private sector and which are only available from the NHF public-sector pharmacies.
The Ministry of Health welcomes feedback from the public, asking only that this be done in a constructive manner and in the interest of ensuring the best possible health outcomes for our people.