APSM corrects Daily Mail article market stats
An article published today (8 December 2015) in the Daily Mail ‘High
Street Chemists who charge the NHS £300 for skin creams that should cost £12’, contains
a number of significant inaccuracies about the Specials market and APSM
activities.
Here follows
the APSM response to the facts presented within the article.
DAILY MAIL QUOTE: The
practice has been exposed by the BAD which says up to £400m a year of
taxpayers’ money is being wasted on paying too much for these treatments. Even 2% salicylic acid cream which can be
effective for these conditions costs the NHS £75m per year.
APSM
Response: Dermatology Specials are a
small proportion of Specials spend in primary care – approximately £1m per year.
The
total spend on Specials in England in 2014 was £89.5million in primary care. A very small percentage of this is for
dermatology specials through community pharmacy.
Only
a small number of Dermatology products are in the top 500 specials*. In
the last 3 months to September 2015, 1404 items were prescribed for
topical use (which would include dermatology products) at a cost of
£259,360. Over a year this is approximately £1m. (Just over 1% of all spend).
Of
the 3 products mentioned specifically, Coal Tar 5% was 220 prescriptions in last
3 months less than£200,000 per year (average cost £180 - £190). Coal Tar 10% ointment 100g was 23 in the last
3 months – less than £30,000 a year. 2% salicylic acid in aqueous cream
100g was 63 prescriptions in 3 months - approximately £50,000 over a year.
These figures are based on data for England. The estimated value for Dermatology Specials in the community including Scotland and Wales is £1.2m (an additional 20%).
These figures are based on data for England. The estimated value for Dermatology Specials in the community including Scotland and Wales is £1.2m (an additional 20%).
*The
NHS BSA lists the top 500 most reimbursed specials (in Primary Care) by cost
(NIC) and number of items. This includes
items on the Drug Tariff as well as those not included in the Tariff and covers
approximately 80% of the total spend on Specials each year.
DAILY MAIL QUOTE: In Scotland they are still supplied by NHS
prices but in England the pricing is governed by market forces
APSM Response:
The Scottish Tariff covers a smaller number of products (50) and uses a
different mechanism for setting prices, although commercial and NHS prices are also
taken into account. Overall, the price
of the majority products on the Specials Tariff in Scotland is similar to the
England Tariff with some fluctuations (some are cheaper in England than
Scotland and visa versa).
Certain dermatology products may have
been negotiated separately and we cannot comment on the process used.
The
Specials Tariff is designed by the
Department of Health to provide sustainability of supply and
a mechanism to ensure that safe and effective specials are available to the NHS
via a resilient supply chain that provides a fair return, ensuring the long
term sustainability of the specials market.
The DH has a mechanism for deciding which products will go on Tariff and
it is regularly reviewed.
DAILY MAIL QUOTE: “The creams are made by 14
member companies”
APSM RESPONSE: Of our 13 members only a
minority produce any of these creams and in very small volumes. APSM members report that they produce a
relatively small number of specials for dermatology supply to community
pharmacy. If they are asked to produce
them they are generally bespoke ‘one off’ preparations, i.e. the ingredients
are sourced and they are manufactured, quality checked and sent out the same
day.
DAILY MAIL QUOTE: “in prescriptions outside hospitals, £246 -
£346 for every pot used”
APSM RESPONSE: The Tariff prices listed for
these products as listed in the latest Tariff dated November 2015 they are:
-
100g
Coal tar 5% in oint base - £280.96
-
2%
sulphur/2% salicylic acid in aqu cream - £198.64
- 10% coal tar oint 100g - £216.36.
Prices
in English November Part VIIIB
DAILY MAIL QUOTE: These traditional ointments contain coal tar,
sulphur or sometimes dissolved aspirin, in aqueous cream, a base of paraffin
oils used for generations for dry skin.
APSM
Response: The product
examples used are not simple, effective or high street products.
Coal Tar is a
particularly difficult product to manufacture.
Although it has been used for hundreds of years in skin preparations,
there are concerns about its toxicity and known carcinogenic properties both
for patients and those involved in manufacturer, so it can only be manufactured
under special conditions. Pharmaceutical
standard coal tar as an ingredient is now very difficult to source – due to
recent changes in safety and quality regulations there are now only a very
limited number of raw ingredient suppliers worldwide and the cost has become
prohibitive – in fact many licenced manufacturers have had to cease manufacture. For these reasons, it is rarely used in
manufacture for licenced pharmaceuticals or Specials.
In
March 2013,
the MHRA (Medicines and Health Regulatory Authority) issued a warning about the
use of Aqueous Cream, particularly
for children with eczema as it may be an irritant. This is thought to be because of the, sodium lauryl sulfate (SLS), contained in
emulsifying wax which is one of the ingredients of aqueous cream. The National Eczema Society and NICE advise
caution in its use.
DAILY
MAIL QUOTE: Private manufacturers have
come in as part of the drive to open up the NHS to market forces, but as a
result patients and taxpayers are being penalised.
APSM Response: Commercial manufacturers were set up in
response to MHRA increased controls on specials quality and patient safety
following the ‘peppermint water case’ in 2000, in which an infant died after an
incorrectly formulated pharmacy preparation. Specials are now rarely made up in a community
pharmacy. There are a small number of
hospital manufacturing units which also have MHRA licences, but the commercial
sector exists to meet the majority of demand.
DAILY MAIL QUOTE: “The
NHS is charged more than £300 a pot for products that could cost just £12
APSM Response: If an NHS
manufacturing unit charges £12 then this reflects the price they charge, not
necessarily the cost of the product – this would not be sustainable in a normal
commercial environment. The full costs
of manufacture may have been allocated elsewhere within the NHS budget
(staffing, capital investment, etc).
Also, for some medicines they may have been able to manufacture a batch
in advance or at a later date and can achieve cost efficiencies this way, i.e.
they are not always operating a same-day service.
In England
and Scotland a number of Hospital Pharmacy units are supplying Specials
alongside commercial manufacturers and together we are providing essential
services to patients. However, most
in-house hospital units are not geared up to large volume production across
such a wide range of possible products so could not meet the demand for
Specials – particularly in England. Therefore the majority of capacity and
volume in the market comes from the commercial pharmaceutical manufacturing
sector and so the cost structure of the market has to be based on a commercial
rather than NHS funded model.
The Price Difference reflects the
commercial model
The main
purpose of Specials manufacture is to patient safety and to meet patient
clinical need. Commercial manufacturers
are required (by the MHRA) to carry sufficient capacity to meet demands on a
daily basis
with more than 20,000 potential preparations on systems, it is not possible to
predict demand so most orders are manufactured same day. For the average manufacturer this can be 2-500
different orders per day. There are
inherent costs involved with maintaining a high level of production capacity to
fulfil orders, as well as express delivery costs. This same-day manufacture also includes a
very stringent quality process (to pharmaceutical standards) – see attached –
to ensure patient safety. The costs associated with this
intensity of commercial manufacture are reflected in the price.
DAILY
MAIL QUOTE: “We have tried to discuss it with the APSM but says it doesn’t have
to talk to us”.
APSM
RESPONSE: “We made a direct approach to
BAD over a year ago to introduce ourselves.
We attended a meeting, shared information and agreed to attend future
meetings of their Specials Working Group.”
DAILY MAIL QUOTE: “Because
of a commitment to open the NHS to market forces and competition, the
Government has now prevented NHS pharmacies that manufacture these creams for
hospital use from also offering them through community pharmacies”
APSM
RESPONSE: “Our understanding is that any hospital pharmacy with an MHRA
specials licence can – and do - supply to community pharmacy.”
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