The remainder of this module will look at a number of practical issues that have been identified following the introduction of the Specials tariffs.
Special Obtains
A Special Obtain is any product that is not normally stocked by a wholesaler and therefore is sourced specially by the wholesaler. This is not the same as an unlicensed Special and the two should not be confused. Special Obtains may include dressings and appliances listed in Part IXA of the drug tariff as well as vitamin and mineral supplements. Because these products are not specially manufactured for an individual patient they do not fall under the unlicensed Specials rules and regulations. In most cases there will be no Marketing Authorisation for the product – this does not mean they are unlicensed, rather that they do not need a licence because they are not medicines.
Specials as "stock" items – broken bulk
Under the new arrangements pharmacists can no longer claim broken bulk when dispensing unlicensed Specials or imports that have been procured from a third party. This led to concerns that contractors may not be fully reimbursed if the prescribed quantity is less than the minimum quantity that can be supplied by the manufacturer. This can be a particular problem with solid dosage forms where there may be a minimum pack size available.
Where the Special is not listed in the relevant tariff the pack size used must be endorsed to enable the correct calculation of payment. In addition, pharmacists should make every effort to order as close to the precise quantity as possible in order to fulfil a prescription.
However, when this is not possible, the MHRA and PSNC have both confirmed that procured specials can be used by the pharmacy to fulfil prescriptions for more than one patient, in other words they can be held as stock items. For example, a particular unlicensed special can only be ordered in a pack size of 50 capsules but the prescription asks for 20 capsules to be dispensed. Although broken bulk cannot be claimed, the remaining 30 capsules can be used at a later date for another prescription. Care must be taken that the remaining stock will be in date for the duration of the prescription.
When endorsing specials as stock items it is advised that the total cost of the stock bottle is stated and endorse the quantity supplied. For example - "price for 50 caps £76.20, 20/50 supplied". This will ensure accurate reimbursement with no risk of an overpayment.
Record keeping for "stock" specials
Where a stock container is used to treat several patients the pharmacy must have a robust record keeping process and ensure that a full audit trail is kept. Where multiple prescriptions are dispensed from a single pack, pharmacists will need to retain the original Certificate of Conformity or Analysis (CoC/CoA) with that pack and make a copy for each prescription dispensed. The copy (of the fully endorsed CoC or CoA) is sent to the local health authority of the prescribing doctor, which may be different to your own.