a 2 year arrangement covering both and to allow contractors and Health Boards to plan ahead

Transcription

1 Finance, ehealth & Pharmaceuticals Directorate Pharmacy and Medicines Division Dear Colleague PHARMACEUTICAL SERVICES AMENDMENTS TO DRUG TARIFF IN RESPECT OF REMUNERATION RATES FOLLOWING THE FINALISED -14 & 2014/15 FUNDING SETTLEMENT Summary 1. This Circular advises of changes in the Drug Tariff to remuneration arrangements and future intentions effective for July and October dispensings plus advance advice of other planned changes where detail is to follow- all following the finalisation of a community pharmacy funding settlement for -14 and Background 2. NHS Circulars PCA (P) ()11, 15 & 18 advised of amendments to the Drug Tariff in respect of payment changes prior to finalisation of the community pharmacy funding settlement for A settlement has now been reached with Community Pharmacy Scotland (CPS) on a 2 year community pharmacy funding settlement to cover both -14 and which has the following key elements: 29 July Addresses For action Chief Executives, NHS Boards For information Chief Executive, NHS NSS Enquiries to: Shelagh Scott 1 st Floor East Rear St Andrew s House EDINBURGH EH1 3DG Tel: Fax: shelagh.scott@scotland.gsi.gov.uk a 2 year arrangement covering both -14 and to allow contractors and Health Boards to plan ahead Pt 7 Tariff prices to continue to be managed in such a way that St Andrew s House, Regent Road, Edinburgh EH1 3DGwww.scotland.gov.uk

2 - the aggregate level of reimbursement across all items is fair for both contractors and Health Boards, - Tariff stability remains a key objective consistent with the need to react to market circumstances, - Health Boards continue to benefit quickly from attractive market pricing as new generic copies become available, - The basis for the sharing of overall margin achieved by contractors on Pt 7 Drug purchases is updated to ensure it continues to be fair for both contractors and Health Boards. - Pt 7 Tariff claw back arrangements in respect of margin to be returned to Health Boards in respect of prior years is managed as far as is practical to smooth cash flow for contractors. - To achieve the last two points a new Margin Sharing Arrangements (MSA) on the purchase of drugs is being introduced for -14 and derived from the EPPP arrangements which applied in respect of A recurring uplift in the annualised remuneration Global Sum of 3.254m to take effect from 1 October with a further recurring uplift of 2.968m to take effect from 1 October The recurring element represents a 1.74% increase but with a six month deferral in the start date. These increases are based on an agreed formula to address salary and cost pressures consistent with the requirements of the Public Pay Policy for Scotland and to be affordable are funded from within the Pt 7 Tariff management arrangements and new MSA referred to above. The Global Sums applicable for the following years therefore become: m (year on year increase 1%) m (year on year increase 1.7%) m (annualised rate to ) (year on year increase 0.85%) Increased target payments for the CMS and updated conditionality for receipt of these payments to apply for dispensing months July-. The payment CMS to be replaced by a new Operations and Development payment with effect from the dispensing month of October to support contractor achievement of operational benchmarks and sign up for development initiatives which may from time to time be introduced with the first development initiative planned to be a new Additional Pharmaceutical Service relating to dispensing of Gluten Free food prescriptions scoped for introduction from 1 October.

3 A one off non-recurring Regulatory Support of 200 out with the Global Sum increase to be to all contractors on the Pharmaceutical List at 1 July. As a consequence of this settlement discount claw back arrangements in respect of both Drug Tariff Pt 7 (i.e. generic drugs) and those to which Pt 11 (i.e. proprietary drugs) applies, will remain unchanged from those currently in force unless or until evidence from the continuing quarterly pricing checks which SG and CPS will continue to conduct jointly requires that they be reset. Updating with effect from October dispensings of conditionality related to payment of the Quality and Efficiency payment. Commencement in October subject to satisfactory scoping of a final 2 stage migration out of remaining existing transitional remuneration arrangements (including also shadow fees for newer contractors) to a new simpler structure based around 4 new payments to be completed in April 2014: - an establishment payment - a dispensing pool payment - a complex dispensing payment and - a Pharmaceutical needs payment 4. The detail of Drug Tariff changes now effected are included in Annexes A and B to this Circular and advance advice related to other prospective changes, where detail is still to be finalised, are introduced in Annex C. Consultation 5. Community Pharmacy Scotland has been consulted on the Drug Tariff amendments and the contents of this Circular. Action 6. Health Boards are advised to send a copy of this Circular to all community pharmacy contractors and Community Health Partnerships in their areas. 7. Community Pharmacy contractors are advised in particular to note the actions recommended at Annex C (1 st stage migration process) to prepare for introduction of the Complex Dispensing and to note the planned introduction from October of an Additional Pharmaceutical Service relating to Gluten Free Food prescriptions. Yours sincerely Bill Scott Chief Pharmaceutical Officer and Deputy Director, Pharmacy & Medicines Division

4 ANNEX A NOTIFICATION OF AMENDMENTS TO DRUG TARIFF WITH EFFECT FOR DISPENSINGS FROM 1 JULY payment (CMS) With effect from July the following changes will apply with respect to the (CMS): Recalculation of the nominal total monthly payment for each contractor - the aggregate amount available for these payments at 30 June is an annualised rate of 4.457m i.e. a monthly aggregate amount of 0.371m. - effective 1 July the monthly aggregate amount will rise to 0.536m - the target monthly payment for each eligible contractor will be recalculated as the % share of the total Pt 7 non ZD reimbursement for that contractor between 1 April 2012 and 31 March. ISD will advise each contractor of his/her revised nominal total monthly payment recalculated as above. Updated eligibility criterion - eligibility to receive this payment in respect of July dispensings onwards will be that a contractor has to be on the Pharmaceutical List at 1 July - where a contractor acquires an established pharmacy the new contractor will inherit the previously calculated CMS payment. Conditions to be met for the payment of the - CMS for the dispensing months of July, August and The criteria, checks and calculations which will determine payments in respect of the dispensing months of July paid, August paid October and paid November will be as follows. These broadly roll forward for 3 further months the arrangements in place at 30 June but with the benchmark date for registrations moved forward to 30 April : Criterion 1 s B1, B2, B3 - Boards will check contractors' performance with respect to all patients registered at 30 th April at end July, August and respectively with report timing in accordance with the table below Criterion 2 s C1, C2, C3 - Boards will check if contractors have met the requirement of having carried out and completed at least 4 High Risk interventions by end July,

5 August and respectively with report timing in accordance with the table below Criterion 3 s D1, D2, D3 - Boards will check if contractors have met the requirement of having carried out and completed at least 4 New Medicines interventions by end July, August and respectively with report timing in accordance with the table below Each check will be carried out once only. The level of payment for each month will depend on the performance of the contractor against the particular checks as detailed in the table below. Dispensing Month July August Report issued by PSD to Board 16th August 16th Notification by Board to PSD 31 st August 30 th Due End of End of October applied B1 C1 D1 B2 C2 Criterion scrutinised by NHS Board 95% of patients registered up to 30 April have been assessed Minimum of 4 high risk medicine interventions carried out and completed * Minimum of 4 new medicine interventions carried out and completed * 95% of patients registered up to 30 April have been assessed Minimum of 4 high risk medicine interventions carried out and Criterion Met? Yes No CMS for July CMS for July CMS for July CMS for August

6 16 th October 31 st October End of November D2 B3 C3 D3 * unless extenuating circumstances are agreed by Health Board completed * Minimum of 4 new medicine interventions carried out and completed * 95% of patients registered up to 30 April have been assessed Minimum of 4 high risk medicine interventions carried out and completed * Minimum of 4 new medicine interventions carried out and completed * CMS for August CMS for August CMS for CMS for CMS for The effect of the reductions following application of s B, C and D is individual but potentially cumulative. Contractors who fail to meet all 3 checks in a particular month will therefore see their target payment reduced by 75% for that particular month. Contractors who fail to meet 2 out of 3 checks in a particular month will see their target payment reduced by 50% for that particular month and contractors failing one check will lose 25%. Regulatory pressures payment A one off Regulatory Pressures of 200 per contractor will be to all contractors on the list at 1 July along with July dispensings payments paid. Arrangements for contractors added to the list 1 July onwards The arrangements in respect of contractors added to the list 1 July onwards will continue to be those promulgated previously in respect of those added to the list 1 April June

7 All other remuneration payments and conditions for making of payments In broad terms the framework established for the transitional payment regime and as detailed in NHS Circular PCA (P) (2012)8 and as subsequently amended by NHS Circulars PCA (P) ()11 & 15 and other Circulars in relation to other payments remain in place, except as detailed below with the conditions and eligibility for all payments remaining unchanged from those detailed in the Appendix to NHS Circular PCA (P) (2012)8. All contractors already on the Pharmaceutical List will now remain for the dispensing months July - March 2014, i.e. the anticipated final time period within which the transitional remuneration regime will be in place, in the contractor Category as defined by paragraphs 3-8 of the Appendix to NHS Circular (PCA(P)(2012)8, with no right to change Category, except where there is an outstanding option to opt for ESP status not disallowed by virtue of NHS Circular PCA(P)(2010)23. Any contractor newly added to the list 1 July onwards will automatically be classified as Category IVe or VII as appropriate.

8 ANNEX B NOTIFICATION OF AMENDMENTS TO DRUG TARIFF WITH EFFECT FOR DISPENSINGS FROM 1 OCTOBER Quality and Efficiency Contractors as a whole are continuing to make excellent progress in making electronic claims with the average rate of electronic claims as at April now having reached approximately 97% although the achievement levels of a minority of contractors are still falling well short of the target rate. To recognise the success being achieved all contractors on the Pharmaceutical List for the dispensing month concerned will continue to be eligible for the dispensing months October - March 2014 to receive a contractor specific Quality and Efficiency proportional to their achievement of the target of making 90% of all claims electronically with a maximum payment for making 90% or more claims electronically. The monthly target Quality and Efficiency for each individual contractor will remain at the level in force for dispensings for those on the Pharmaceutical List at 30 and will be 150 for all contractors added to the list 1 October onwards. With effect from October dispensings paid December (Q&E payment continues to be paid one month further in arrears i.e. January 2014) ) however the conditions for receipt of the payment will be revised as follows. Firstly to receive any payment for a particular month a contractor will have to achieve a rate of claims of at least 75%. At or above this claims threshold the contractor will continue to receive a payment pro rata to achievement against the 90% claims rate target, with the payment capped at the contractor s own target Q& E payment. Below this threshold the contractor will not be eligible for any payment. Electronic Claim Rate Used for calculation June July August Prescriptions Dispensed July August Paid For Activity October November Target rate for electronic claims Achieved rate of electronic claims in that month 90% <45% NIL 90% =/>45% & <75% 90% >75% & <90% due 50% of contractor s target Q&E payment Pro rata contractor s target Q&E payment

9 & subsequent 5 months October & subsequent 5 months December & subsequent 5 months which applies at 90% achievement 90% 90% plus Capped at contractor s target Q&E payment 90% <75% NIL 90% >/=75% & <90% Pro rata contractor s target Q&E payment which applies at 90% achievement 90% >90% Capped at contractor s target Q&E payment Confirmation/amendment of other remuneration arrangements Other rates of remuneration to apply from October are subject to confirmation/amendment in due course following consideration by Scottish Government and Community Pharmacy Scotland on outturn on Global Sum for and projections for -14.

10 ANNEX C ADVANCE NOTIFICATION OF OTHER PLANNED CHANGES TO REMUNERATION ARRANGEMENTS IN RESPECT OF WHICH AMENDMENTS TO THE DRUG TARIFF WILL FOLLOW IN DUE COURSE In this Annex notice is given to contractors of further planned changes to remuneration arrangements, details of which have still to be finalised between the Scottish Government and CPS to allow contractors potentially affected to plan ahead, and take initial action as indicated below. 1. Final stages in migration out of transitional remuneration payments The objectives for the payment regime which will replace transitional arrangements are: -fairness between all contractors -predictability of income -transparency -fair weightings to reflect dispensing activity and any special support being provided to patients living at home in the community -introduction to reflect relative pharmaceutical needs -efficiency in the payment process It is therefore intended that on completion of the migration out of existing transitional remuneration payments the existing community migration payments plus current shadow fees payments plus certain other existing payments which either wholly or in part are recurring at a flat rate will be consolidated into a new 4 part payment structure comprising the following elements: Establishment Subject to conditions relating to overall dispensing turnover activity this will be a single flat rate payment which will be to all contractors. Dispensing Pool A fixed pool will be established, which will be shared between contractors on the basis of historic dispensing volumes. The shares will be updated quarterly. Complex Dispensing A weighting will apply to Dispensing Pool payments to reflect the relative level of support which pharmacy contractors record in Patient Care Records as being provided. Pharmaceutical Needs A weighting will apply to Dispensing Pool payments to reflect the relative Pharmaceutical needs of patients served. It is planned that this migration process should be completed in two stages.

11 1 st stage currently planned for October Half of existing transition and shadow fees payment plus certain other identified fixed rate payments will be pooled then redistributed as an Establishment and a Dispensing Pool Share. In parallel, contractors will add appropriate flags to Patient Care Records of those patients who have a Complex Dispensing Need excluding in respect of methadone dispensing which the contractor is addressing. Amendments have been to existing IT so that contractors may attach a record flag to indicate which of the following kinds of support is being provided: - monitored dosage system required by pharmacist - monitored dosage system requested by prescriber/social services/hospital - other adherence support required (eg MAR sheet) - instalment dispensing requested by prescriber - special monitoring and feedback required To enable aggregate data to be compiled and timeous decisions to be on appropriate metrics for the calculation of this payment weighting, contractors are invited to: - ensure that they have in place a PCR for all patients with a Complex Dispensing Need covered by the above classification - enter on each PCR the appropriate flag - complete this process at the latest by 13 2 nd stage, currently planned for April 2014 All remaining existing transition and shadow fees payments and material change of circumstance arrangements to be withdrawn at end of March 2014 and redistributed between the 4 headings detailed above. Confirmation of the timetable for this migration process and detail of the method to be used to calculate each payment and weighting is subject to scoping and assessment by SG and CPS. Further advice will follow in due course. 2. Replacement of CMS by the Operations and Development The CMS payment will be replaced with effect from October dispensings by the Operations and Development to enable payment to be re-targeted on a rolling basis to meet wider operational objectives and to provide scope for policy development initiatives to improve patient care.

12 The target monthly CMS for each eligible contractor in place at 30 will become the aggregate target Operations and Development, and will be split into two parts a fixed and a variable element, for example; A target monthly CMS payment of 1,000 at would become October onwards, An aggregate target Operations and Development of 1,000 up of: - fixed element variable element 875 This change is being to enable this payment in future to be targeted towards satisfactory performance by contractors in supporting agreed operations priorities across a wide front and separately to support patient care development projects from time to time being pursued. For the dispensing months October to December the variable element of the payment will be targeted to: Continue encouraging new medicines and high risk medicines interventions and assessments following CMS registration - all in line with pre-existing policy- but with targets better representing the numbers of patient interventions which it may reasonably be expected that individual contractors should achieve in the light of their local circumstances under the New Medicines and High Risk Medicines initiative, and the fixed element towards the introduction from October of Gluten Free prescriptions dispensing Additional Pharmaceutical Service on a 12 month trial basis, For the dispensing months January to March 2014 the variable element will also target implementation by contractors of Standard Operating Procedures (SOPs) for serial dispensing. arrangements with associated conditionality for will be developed in conjunction with Community Pharmacy Scotland and published in due course. The detailed conditionality for this payment for the October-December period to be included in the Drug Tariff is in the course of development and will be advised of by Circular in due course. In conjunction with this it is planned that the service specification for the Gluten Free foods prescriptions Additional Pharmaceutical Service will be published during August. 3. Advance payment arrangements During the negotiations on the -14 settlement the Scottish Government agreed with Community Pharmacy Scotland that the arrangements for making advance payments to contractors should be reviewed immediately and in advance of the formal settlement in the light of recent experience to ensure that they remain as

13 supportive as possible of delivering the policy target that contractors should receive each month an advance payment of 90% of their anticipated combined remuneration and reimbursement income for the following month, with reconciliation once prescriptions are received for payment processing. The projection arrangements used by Practitioner Services Division were accordingly updated in respect of February dispensing month payments onwards to increase the level of actual advance payments being. These updated arrangements are being kept under on-going review and further changes will be as necessary