Consultation Responses

Published on: 25th July 2022 | Updated on: 20th February 2024

CPW will respond to consultations, such as Welsh Government or General Pharmaceutical Council consultations, where the outcome of the consultation could have an impact, of any kind, on the delivery of the community pharmacy contractual framework or the viability of the community pharmacy network.  CPW will also respond to any consultations where there is an opportunity to make a case for a greater contribution from community pharmacy. Responses to consultations are listed below:

16 February: Welsh Government

CPW responded to the WG consultation on Healthcare procurement Reforms asking for clarity, as there is in England, that pharmaceutical services provided by community pharmacies are out of scope.  CPW also expressed concern that greater flexibility could undermine national contractual agreements. A copy of  the CPW response can be accessed here.

Consultation on Pharmacy Supervision

CPW responded to this important consultation from DH&SC supporting the proposed changes to supervision as a facilitator of increased headroom for service delivery. A copy of the CPW response can be accessed here.

14 November: AWMSG Strategy 2024-29

With the support of AWTTC the All-Wales Medicines Strategy Group (AWMSG) committee have been developing their next five-year strategy for 2024–2029. CPW’s response identified key issues and lobbied for a more strategic relationship with CPW. A copy of the CPW response can be accessed here.

Healthcare Degree Apprenticeships

CPW responded to a HEIW consultation exploring the potential role of apprenticeship degrees being undertaken in the healthcare sector.  A copy of the CPW response can be accessed here.

Committee of the Welsh Parliament Draft Budget Proposals 2024/25

CPW responded to the consultation identifying the desire to budget for an increase in funding for the network, access to the NHS pension scheme, Access to the NHS premises fund and Welsh Risk Pool insurance for PIPs. A copy of the CPW response can be accessed here.

AWTTC policy on MARRS chart

Used by carers in health and social care.  CPW’s response emphasised the concerns of the board in relation to the risks to patient safety and building in inefficiency by not operating an all-Wales MAR chart.  A copy of the CPW response can be accessed here.

AWTTC consultation on antipsychotic prescribing

CPW responded to this consultation focussing on the opportunity to monitor prescribing in care homes and in the community and community pharmacies as a source of medicines advice. A copy of the CPW response can be accessed here.

Decarbonisation: Prescribing and disposal of inhalers

As part of their decarbonisation work, AWTTC have consulted on the prescribing, supply and disposal of inhalers that have a higher global warming footprint.  A copy of the CPW response can be accessed here.

Consultation on the reform of primary care ophthalmic services

Welsh Government consulted on changes to ophthalmic services similar to the reforms of pharmacy and GP services. CPW response focussed on the opportunity to manage many eye care conditions in collaboration with opticians given appropriate digital connectivity.  A copy of the CPW response can be accessed here.

The NHS (General Medical Services) consultation

The Welsh Government has consulted on the proposed 2023 GMS Regulations to replace the 2004 Regulations.  The changes take into account the experience of the past few years and the desire to have a more uniform delivery of GMS services across Wales.  A copy of the CPW response can be accessed here.

Developing a Strategic Pharmacy Workforce Plan

CPW responded to a consultation from HEIW looking at the development of a strategic pharmacy workforce plan.  A copy of the CPW response can be accessed here.

Citizens Voice Body Consultation

The Welsh Government have consulted on further elements of their plans to replace Community Health Councils with a Citizens Voice Body for Health and Social Care.  The elements consulted on were, access to premises, representation and service change.  A copy of the CPW response can be accessed here.

Welsh Government Consultation on recycling

Welsh Government have consulted on a code of practice for separate collection of waste materials for recycling from non-domestic premises.  A copy of the CPW response can be accessed here.

AWTTC CAS Formulary Update

AWTTC has consulted on the latest update to the Common Ailments Service Formulary.  A copy of the CPW response can be accessed here.

GPhC: Supporting good decision making at hearings

The GPhC are proposing to strengthen their decision-making guidance for fitness to practise panels. The proposed update to the guidance makes clear what they mean by discrimination, bullying and harassment, and how seriously concerns of this nature will be taken. The revised guidance will also make sure that panel members consider cultural sensitivities and differences.  A copy of the CPW response can be accessed here.

The  Duty of Quality

The Duty of Quality in the 2020 Act aims to achieve a system-wide approach to quality in the health service to secure improvement in all areas. The duty will ensure the Welsh Ministers and NHS bodies exercise all their functions with a view to securing improvement in the quality of health services. CPW has responded to the proposed Duty of Quality Statutory Guidance 2023 to accompany these new requirements.  A copy of the CPW response can be accessed here.

Substance Misuse Treatment Framework – Young People

Welsh Government have consulted on additions to their substance misuse framework to improve the support given to children and young people.  CPW has responded to the consultation.  A copy of the CPW response can be accessed here.

Welsh Government consultation on Non-Domestic Rates

The Welsh Government have consulted on a wide range of improvements to non-domestic rates. The proposals include the following: more frequent revaluation cycles, Improving the flow of information between government and ratepayers, providing the Welsh Government with more flexibility to amend reliefs and exemptions and a future review of reliefs and exemptions.  A copy of the CPW response to the consultation can be accessed here.

Welsh Government; HIV Action Plan

The Welsh Government is consulting on a draft HIV Action Plan for Wales for 2023 to 2026.  The objectives of the plan are to seek to eliminate HIV, to improve the quality of life for those with living with HIV and to tackle the stigma associated with the virus.  A copy of the CPW response can be accessed here.

The Standards for Competency Assurance of Non-Medical Prescribers in Wales consultation

CPW responded to this pan-professional consultation from HEIW on the evidencing of competencies for non-medial prescribers in Wales.  A copy of the CPW response can be accessed here.

Hub and Spoke Dispensing

The Department of Health and Social Care on behalf of the four home nations has consulted on proposed changes to legislation to allow hub and spoke dispensing between different legal entities.  CPW’s response to the consultation can be found here.

Developing a strategic mental health workforce plan for health and social care

HEIW have consulted on the potential of developing a multi-professional workforce plan to support implementation of the Together for Mental Health Delivery Plan 2019-22   The plan sets out the requirement for Welsh Government to work with Health Education Improvement Wales (HEIW), Social Care Wales (SCW) and partners to produce a workforce plan for mental health services.  The CPW response to the proposals can be accessed here.

AWTTC The Care Home Medicines Optimisation Toolkit

The toolkit is currently in development. CPW responded to the draft toolkit and the Equality and Health impact Assessment (EqHIA). The aim of the document is to bring together a suite of guidance documents and useful resources, in one place, as an easy-access resource library that can be used by staff working in care homes.  A copy of the CPW response can be accessed here.

GPhC Consultation on remote hearings

The GPhC have successfully held some hearings remotely by video link during the COVID-19 pandemic. Those taking part were positive about their experience. The GPhC have consulted on whether this should remain an option for the future.  The CPW response to the consultation can be found here.

Impact of the waiting list backlog

The Health and Social Care Committee have held an inquiry into the impact of the waiting list backlog on people who are waiting for treatment.  CPW has responded to this consultation lobbying for a continued transfer of care into the pharmacy network.  A copy of the CPW consultation response can be found here.

RPS – Core Advanced Curriculum

The Royal Pharmaceutical Society (RPS) have recently consulted on their proposed core advanced curriculum. The curriculum describes the expectation of entry-level advanced pharmacists and bridges the gap between the post-registration foundation curriculum and the consultant pharmacist curriculum. The CPW response to the consultation can be found here.

Consultation on original pack dispensing and the supply of medicines containing sodium valproate

The Department of Health and Social Care, on behalf of the four home nations, has consulted on the provision of increased flexibility (+/- 10%) to support the supply of a greater number of medicines in original packs.  In addition the consultations looks at the mandatory supply of medicines containing sodium valproate in original packs.  A copy of CPW’s response to the consultation can be accessed here.

Health and Social Care Committee Inquiry into hospital discharge

Good patient flow improves the quality of care for patients, but a number of factors are likely to be causing delayed transfers of care, including capacity issues within the social care system, meaning that some patients who are ready for discharge remain in hospital. This has detrimental impacts on both the individual, and the flow of patients through the hospital, contributing to pressure on A&E departments and ambulance services. During the Sixth Senedd, the Health and Social Care Committee plans to explore how patient flow through hospitals can be improved.  The first part of this work is a short inquiry focusing on hospital discharge and its impact on patient flow through hospitals.  A copy of CPW’s response to the inquiry can be accessed here.

GPhC Consultation on changes to Independent Prescribing requirements

The GPhC have consulted on changes which will enable more pharmacists to begin their independent prescriber training.  The proposals are to:

  • remove the requirements for registered pharmacists to have two years of clinical practice, before they can enrol on an accredited independent prescribing course.
  • remove the requirement to have relevant experience in a specific clinical or therapeutic area, before they can enrol on an accredited independent prescribing course.
  • retain the requirement that course participants must identify an area of clinical or therapeutic practice to focus on during the course.

The CPW response to the consultation can be accessed here.

RPS Post-registration Pharmacist Foundation Curriculum

The RPS have consulted on a draft curriculum to support the Post-registration Pharmacist Foundation Programme.  CPW has responded to the consultation on behalf of contractors in Wales and a copy of the response can be accessed here.

GPhC Consultation: How we set fees

The General Pharmaceutical Council has conducted a consultation on how they should set fees for premises and registrants in the future.  CPW has responded to this consultation and a copy of the CPW response can be accessed here.

RPS Consultation: A Competency Framework for all prescribers

On behalf of NIHCE and Health Education England the RPS are pulling together a set of competencies for all prescribers.  As the competencies are likely to be adopted in Wales CPW has responded to the consultation on behalf of contractors in Wales.  The competency framework has been developed and updated to support prescribers to expand the knowledge, skills, motives and personal traits, to continually improve their performance, and to work more safely and effectively. A copy of the CPW response can be found here.