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Greg Lawton

@thisislawton

Nov 17, 2023

My submission to the Health and Social Care Committee’s Pharmacy Inquiry (as amended from my original submission in July; the committee invited me to submit a version with a reduced word count).

Thread 🧵committees.parliament.uk/writtenevidenc…

Some excerpts (with minor amendments) from my original submission:

The term “pharmacy” is often used, incorrectly, interchangeably with “pharmacists”. To illustrate, a parliamentarian recently referred to community pharmacy closures, and in that context asked whether the government had got the contract with “pharmacists” right.

Pharmacies are the businesses, or premises; pharmacists are the healthcare professionals.
In England, the government contracts nationally (pursuant to s.165(1)(a) of the National Health Service Act 2006) in consultation with community pharmacy businesses, not pharmacists, and pharmacists as a profession have no say in that national commissioning process for community pharmacy. It is by no means uncommon for people to confuse or switch between the words “pharmacy” and “pharmacists”, including for political purposes.

Privatisation in pharmacy, as a field of practice in healthcare, is highly advanced, at least arguably moreso than in any other area of healthcare. There are parallels in the field of optometry, but some of the largest pharmacy businesses have connected businesses involved in the wholesaling and manufacturing of medicines, so their political influence, influence on the NHS, and profile, is far greater than that of their optical counterparts.

The Health and Social Care Committee (“the Committee”) may receive submissions to the inquiry from the organisations described below in the “Pharmacy Organisations and Bodies” section of this submission. If it is claimed, or it appears, that they represent (for example) “pharmacy” or “community pharmacy”, it is crucial to understand whose interests they represent in fact.

Many who interact with “pharmacy representatives” will, though they may not realise it, not have interacted with the profession or its representatives. The profession of pharmacists often struggles to have its voice heard - and it is, instead, drowned out by the voices of pharmacy businesses.

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The interests of pharmacists and pharmacy business owners may conflict in certain respects. By way of example, the Company Chemists’ Association and Community Pharmacy England, which represent pharmacy business owners, have each called on the NHS to stop recruiting pharmacists into the Additional Roles Reimbursement Scheme (“ARRS”). This could potentially be contrary to the interests of pharmacists, and, at least arguably, the interests of the public. The apparent basis of the request (the alleged insufficiency of the availability of pharmacists) was not supported by the citation of evidence, if any such evidence exists, and the pharmacy media seemingly did not insist on any such evidence being provided, or comment on the lack of it. It should be borne in mind that it is in the interests of pharmacy owners to have more pharmacists available, so that there is increased competition for jobs, remuneration therefor can be reduced, costs are lowered, and profits are increased.

A pharmacy business owner will want to run his business at the greatest possible profit, which means making his costs as low and revenues as high as possible, whilst seeking to avoid reputational harm. A pharmacist will want to be paid the best possible salary, to practice within regulatory parameters so that his career is not put in jeopardy, and to work in conditions conducive to that end and to his own wellbeing. It is also to be hoped - through professional training and by virtue of his career choice - that he will want his profession to develop, and to use his skills to deliver safe and effective care to patients. If he fails to meet regulatory requirements, he may face regulatory sanctions - but the same cannot presently be said of pharmacy businesses/premises. This issue is explored in more detail below under the heading “Regulation”.

Investment which is in the interests of pharmacists and patients costs money. It costs money to implement the staffing and other resources required to keep staff and patients safe, and to provide clinical care. It costs money to train a profession and expand its scope of practice. Spending money is not in the interests of the business owner qua a business owner), save to the extent that it coincides with his aforementioned objectives, and subject to his appetite for risk. There will be a natural inclination among pharmacy business owners, in general terms, to seek to achieve their objectives more cheaply. If they can achieve their objectives without the cost of a pharmacist, they will do so.

Much of the disharmony in pharmacy, and jostling about its future, has its roots in the conflicting interests of pharmacists and pharmacy business owners. Some pharmacists are also pharmacy business owners, and have conflicting interests themselves; this manifests in different ways, depending on the individual.

If the future of pharmacy were carved out in the interests of the profession, it would be one thing. If it were carved out in the interests of pharmacy businesses, it would be another. This distinction between representatives of pharmacy businesses and representatives of pharmacists is therefore of paramount importance to the present inquiry. Ultimately, from the Committee’s perspective, the only thing that should matter is the public interest, and how that is best served.

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Often, a person may be exposed only, or more so, to a particular viewpoint, which may shape his understanding and perspective. A person's employment history can also be relevant, because it may mean, for example, that the person has signed a contract with his former employer not to say anything disparaging about the employer - thereby affecting his performance in the roles he undertakes thereafter. If he is in an influential position in an organisation or body, the constraints upon him, or his viewpoints, can affect the performance of that organisation or body. These things are true of members of the Committee, just as they are true of the individuals from whom the Committee receives submissions. The Committee is respectfully asked to bear these things in mind during the inquiry.

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The number of registered pharmacists is likely to increase for many years to come. Until the early 2000s, the number of universities offering pharmacy courses (to train to become a pharmacist) in England was stable, at around 12. The number then increased markedly, and the number of university places increased - with 26 universities in England and 31 in the UK now offering the MPharm course. If the number of pharmacists on the register had stabilised in the early 2000s, and pharmacists have a career on the register spanning (say)
30-40 years, it could be expected that the number of pharmacists on the register would continue to increase over a 30-40 year period until equilibrium had been reached again.

However, the number of university places also appears to be increasing. In 2021, there was a 14% increase in university admissions relative to the previous year, which in turn was 8% higher than the year before that. lt seems likely that the number of registered pharmacists is set to increase for the foreseeable future, without any further intervention being required.

It is in the interests of pharmacy businesses to claim that there is a “shortage” of pharmacists. Such claims have been made without evidence, or contrary to the evidence available at the time; if they are believed, and the number of pharmacists is increased as a result, competition increases, remuneration is reduced, and profit goes up.

Read 9 tweets

Greg Lawton

@thisislawton

Sep 2, 2023

The "Supervision in Community Pharmacy" report, produced without any input from the profession itself, and seemingly without legal advice, is another discreditable chapter in the history of pharmacy supervision.

Thread 🧵/rpharms.com/Portals/0/RPS%…

Where was the draft report, for comment? Where was the communication, transparency, or collaboration and discussion with the profession, whilst the group’s activities were going on? What did group members do to seek the views of, and represent, their own membership cohorts? Where is the analysis of the patient safety risk, the effect on costs and public confidence in pharmacy, and the impact on pharmacists’ pay and the availability of jobs?

2/

The word “clear” appears 12 times in the report. Its derivatives, such as “clarity”, a further 6 times. But a model of clarity the report is not.

Despite purporting to review statute, it fails to specify which specific statutory provisions it would alter.

The group leaves it to the Department of Health and Social Care, and regulators, to decipher its intentions. The DHSC and regulators attended group meetings as observers, but if the discussions which took place were as unclear as the report, it’s anybody’s guess how they would interpret them.

That is not to suggest, however, that the group’s discussions will have any impact on the final consultation document.

3/

Read 71 tweets

Greg Lawton

@thisislawton

Mar 11, 2023

Some of the issues with "foregone clinical checks" – where a clinical check is done on a prescription supply then no check is completed for any number of subsequent supplies occurring within a defined period - have not yet been highlighted by #pharmacy bodies.

Thread 🧵/

Pharmacists considering raising concerns to the superintendent (“SI”) about foregone clinical checks should remember that the SI has already signed off on the procedure.

2/

In the companies using FGCs, a paper will have been put to the SI and directors explaining that reducing clinical checking frequency would make the company more profit, through associated staffing cuts, and/or pharmacists spending more time on other profitable activities.

3/

Read 27 tweets

Greg Lawton

@thisislawton

Feb 4, 2023

@rpharms

My experience of submitting a subject access request (“SAR”) to the Royal Pharmaceutical Society @rpharms.

Thread 🧵

The RPS’s initial response was to provide a spreadsheet listing over 2,000 internal emails/documents it held mentioning me, from which I selected 397 for disclosure. Some emails had interesting subject lines - see for example the image below.

2/

There were subject lines indicating my personal data was mentioned in various Executive, Board and Assembly Papers, and discussions about a Boots documentary and pharmacy safety initiatives.

3/

Read 11 tweets

Greg Lawton

@thisislawton

Jan 21, 2023

https://twitter.com/thisislawton/status/1614320986320703489

Part 2.

Pharmacists might sometimes feel isolated and alone, and wonder whether their concerns are shared by others. Often though, people will contact the PDA about the same issues, independently.

21/

https://twitter.com/thisislawton/status/1614320986320703489

How many “unmanageable workplaces” are there at Boots?
Again, is there a company list?

How many company proposals to address workload would only be suitable for a “novice”?

How often is there an “incomplete understanding” of the issues people are facing, from management?

22/

Another mention of a patient death. How many of these are there, potentially resulting from a clinical governance issue? Is the GPhC aware? What difference would it make if it was?

23/

Read 15 tweets

Greg Lawton

@thisislawton

Jan 14, 2023

Comments on the Wayt & McPherson v Boots employment tribunal case. It reveals some of the internal culture at Boots.

Two Area Managers ("AMs") successfully claimed unfair dismissal, after a restructure made their workload unmanageable.

assets.publishing.service.gov.uk/media/62f673e7…

Thread/

The AMs made no complaint about routinely working overtime: 60 hours per week over 6-7 days, whilst contracted for 37.5 hours over 5 days.

How many AMs propagate that culture? How many expect routine overtime from pharmacy staff? What happens if the pharmacy staff complain?

2/

Boots still uses codenames for projects it considers sensitive.

3/

Read 20 tweets

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