So we now have a consultation paper from the DOH which, if enacted as written sometime after Jan 25th 2012, will sound the end of further 100 hour pharmacies being granted permission to open. It is not yet clear for how long 100 hour applications will continue to be processed by PCTs, but it would not be surprising for there to be a flurry of last minute activity before this loophole is closed. Applicants should be aware that PCTs have for some time already found any possible reason, or excuse, not to process such applications, or to delay their processing. So any such application submitted now more than ever needs to be very much “right first time” when the clock is ticking, and the likely reception will be hostile.
PSNC say in their November newsletter that there will be “no facility to allow such pharmacies to apply to reduce their hours” in the new legislation. So anyone who has already or plans to open such a pharmacy will in future have to continue to operate it for 100 hours or close. Until the new dispensing reimbursement structure comes fully into place, it is hard to know by precisely how much margins will be reduced. It is fair to project that 100 hour pharmacies profitability will be negatively affected and therefore the number of items that will need to be dispensed simply to break even will increase, possibly into the region of 11-12,000 items a month or more depending on the individual situation.
It is worth noting, that unless there are changes resulting from the consultation, the large shopping centre and one stop community centre exemptions are also set to cease, leaving purely the distance selling/Internet exemption from the 2005 regulations in place.
No doubt it will take some time for the new regulations, based around Pharmacy Needs assessments, to bed in, and for experience to be gained of how PCTs will interpret them. Anyone considering applying to open a new pharmacy, or even relocate an existing one in 2012 should take good advice from advisers who are taking the time to study the hundreds of pages of new regulations, annexes etc.
As even the minor relocation regulations will be changing, and could easily prove to enforce tighter control, my advice to anyone planning to make a minor relocation apply to do so now, whilst the regulations definitely effectively support them.