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Transcript
Personally administered drugs and appliances, and those used for diagnosis 17.4 A contractor who is providing services under a GMS contract may, whether or not the contractor is authorised or required to provide dispensing services to specific patients, be entitled to the payments listed in paragraph 17.3. This applies only in relation to the following products– (a) vaccines, anaesthetics and injections; (b) the following diagnostic reagents: Dick Test; Schick Test; Protein Sensitisation Test Solutions; and Tuberculin Tests (i.e. Koch Test, Mantoux Test, Patch Test and Diagnostic Jelly); (c) intrauterine contraceptive devices (including drug-releasing IUCDs, contraceptive caps and diaphragms); (d) pessaries which are appliances; and (e) sutures (including skin closure strips). 17.5 In respect of these products, subject to the provisions of this Section, the PCT must pay to all contractors under their GMS contracts the payments listed in paragraph 17.3, as calculated in accordance with this Section – if the products are provided in accordance with paragraph 52(1)(b) in Part 3 of Schedule 6 to the 2004 Regulations. Products not covered by this Section 17.6 Subject to the provisions of paragraph 17.6(b), no payments are payable under this Section in respect of the products listed in paragraph 17.6(a), which are centrally supplied as part of the Childhood Immunisation Programme(a) MMR (Measles, Mumps and Rubella); BCG (Bacillus Calmette-Guérin); Tuberculin Purified Protein Derivative; Meningococcal C conjugate vaccine (for children under 5 and persons entering the first year of higher education); DTaP/IPV/HiB (Diphtheria/Tetanus/Pertussis/Inactivated Polio/Haemophilus influenzae type B); dTaP/IPV (low dose Diphtheria/Tetanus/Pertussis/Inactivated Polio); DTaP/IPV (Diphtheria/Tetanus/ Pertussis/Inactivated Polio); Td/IPV (Diphtheria/Tetanus/Inactivated Polio); Hib/MenC (Haemophilus influenzae type B/meningitis C), PCV (pneumococcal) and HPV (human papillomavirus types 16 and 18); (b) payments are payable under this Section in respect of Td/IPV (Diphtheria,/Tetanus/Inactivated Polio) where that product is used for the treatment of adults or supplied to patients who require such products prior to travelling outside the United Kingdom and in either case where the Td/IPV product has been purchased by the contractor directly from the manufacturer. 17.6A No payments are payable under this Section in respect of the Pandemic Influenza Vaccine (H1N1) 2009, which is centrally supplied by the Department of Health as part of its programme of vaccination against a Pandemic Influenza Virus. 17.7 If a medical practitioner issues a prescription for a drug or appliance instead of supplying it himself, no payments are payable in respect of that drug or appliance under this Section. 17.3 The amounts payable in relation to the provision of drugs and appliances are– (a) the basic price of the drug or appliance, which is the price as calculated in accordance with Part II, Clause 8 (Basic Price), clause 10 (A, B and C) (Quantity to be Supplied), clause 11 (Broken Bulk), clause 13 (Drug Preparations Requiring Reconstitution from Granules or Powder) and Part VII (Lists of Drugs with a Commonly Used Pack Size) of the Drug Tariff, less a discount calculated in accordance with Part 1 of Annex G; (b) the appropriate dispensing fee, as set out in Part 2 of Annex G (in respect of contractors authorised or required to provide dispensing services in accordance with Part 3 of Schedule 6 to the 2004 Regulations) or Part 3 of Annex G (in respect of all other contractors); (c) an allowance to cover the VAT payable on the purchase of any products listed in paragraph 17.4 (a) to (e) and which are provided in accordance with paragraph 52(1)(b) in Part 3 of Schedule 6 to the 2004 Regulations. The allowance is to be calculated by applying the rate of VAT applying at the time of a claim to the basic price of the product after the discount calculated in accordance with Part 1 of Annex G has been deducted; and (d) exceptional expenses, as provided for in Part II, clause 12 (Out of Pocket Expenses), of the Drug Tariff. Presc (No of fees) Total number of fees for personally administered prescriptions. Please note that a personally administered prescription item can attract more than one fee. Total of Basic Prices Total Net ingredient cost of prescription items (net ingredient cost) personally administered plus '% Addition to Basic Price'. This excludes fees. Discount This deduction is made at different levels based on the total basic price of price of personally administered items prescribed for the relevant month. (Ref Statement of Financial Entitlement Paragraph 17.3.) This amount is deducted as it assumed that a discount is received from suppliers on the full cost of the personally administered items. A Doctor may be exempt from this deduction at the discretion of their Primary Care Trust. VAT This does NOT apply to Doctors registered for VAT. This is calculated on the 'Total of Basic Prices' plus '% Addition to Basic Price' minus 'Discount'. (Ref Statement of Financial Entitlement Paragraph 17.3) Dispensing Doctors The basic premise is that these payments are calculated in a similar fashion to those for Pharmacists, however, there are some notable differences (e.g. dispensing doctors are not paid a container allowance). All dispensing doctors have to be VAT registered. The amounts payable in relation to the provision of drugs and appliances are calculated using the following information: Basic Price (Drug Tariff Part II, Clause 8, 10, 11, 13 & Part VII) Discount Scale (3.17 - 11.18%) (SFE, Annex G, Part 1) VAT Allowance (SFE, Paragraph 17.3 (c)) Dispensing Fees (SFE, Annex G, Part 2) Out of pocket expenses (Drug Tariff Part II, Clause 12) The following document has been produced to act as guidance for dispensing practices on what endorsements are required for reimbursement: Dispensing Endorsement Guidance for Dispensing Practices Another difference for dispensing doctors is that payments are made by PCTs from their nondiscretionary funds. Therefore there is no need for any additional payments authorised locally to be submitted to NHS Prescription Services. Personal Administration GP Claims Claims for personal administration can be infrequent and not on a monthly basis similar to other prescriptions, therefore there are no advance payments. The prescriptions are processed during the month they are received and information is sent to the PCT payment site for payments to be made. The payment is calculated similarly to dispensing doctors. There are several vaccines that doctors "personally administer" in high volumes such as influenza vaccination. The GP practice claims payment for these specific High Volume Vaccines using the form FP34D Appendix for Dispensing Doctors and FP34PD Appendix for Prescribing only Doctors. What are PA items? PA items are mainly medicines directly administered by healthcare staff, including IUDs, sutures, vaccinations and other injections. There are anomalies: insulin is included but Implanon is not, The Prescription Pricing Division (PPD) keeps a list of personally administered drugs and they will reply to any specific queries by phone or email. How do you claim? PA items and dressings can be simply entered onto a FP10 as with any other medicine. What about prescription charges? Prescriptions for PA items like those for contraception are exempt from charges, whereas dressings are treated as normally dispensed items and the patient pays a fee where necessary. Practices can dispense dressings and collect the £7.10 fee or alternatively issue a prescription for the patient to use at a pharmacy. What are the rules regarding clawback? Clawback applies to all dispensing doctor NHS prescriptions, both for dressings and PA items. Are there any drawbacks to PA items and dressings? Yes, the biggest drawback is the effect of clawback. If the practice receives no discount, as is usually the case for injections since they are zero discount (ZD) items, they will lose money on any item costing more than £20 because the 11 per cent clawback on this £20 would be greater than a £2.20 dispensing fee. How can we avoid making this loss? The alternative is to issue a prescription for expensive items. Patients can take this to a pharmacy and bring back the item for administration in the practice. Unfortunately patients may then have to pay a prescription charge. Can I dispense PAs to my non-dispensing patients? Yes, PA items can be provided by the practice for direct use by clinical staff for all patients, as can dressings for use in the surgery. A prescription can be raised for these and submitted in the usual way. What about dressings for use by patients at home? Dispensing patients can be provided with dressings in a similar way to their usual medication. Dressings are not PA items, but I have never come across a failure to honour a prescription for one as long as the dressing is in the drugs tariff. Doctors are not able to dispense these items to non-dispensing patients. Can I provide dressings to non-dispensing patients at home? The practice could do this in a way that is convenient for patients and also boosts profitability by using a surgical supplies company such as NWOS or Wardles (see Contacts). These companies will dispense stoma care products and dressings on receipt of a prescription, send the items to the surgery for patient collection and pay an agency fee to the practice of 10-15 per cent of the item's price. This agency fee is payable to all practices including non-dispensing ones. Can I use dispensed but unused dressings? Assuming there is no contraindication due to infection risk, unused, unopened dressings that have already been dispensed may be used for other patients. This would save waste and may be of particular benefit to patients who would otherwise have to pay a prescription charge for their dressings. It would, however, be fraudulent to claim a second dispensing fee for any item already dispensed to another patient. Are there other medicines for which practices can claim? Yes, other medicines that are not PA items can be claimed. However, you should bear in mind that, if the patient should pay a prescription charge and a claim is made without collecting this, the practice would lose £7.10 per item. Most practices only claim if the patient is exempt from prescription charges, because this simplifies the administrative process. Reagents such as fluorescein and rose bengal may be claimed as can KY jelly, saline and other cleaning fluids. What about VAT? PA items are exempt from VAT, so that practices will be reimbursed by the PPD for the VAT they have already paid on purchasing these drugs. This is not the case for dressings and prescribing these may affect the de minimus status of smaller practices. How much is the practice reimbursed for PA items? The PPD will reimburse the tariff price of the medicine with a 17.5 per cent VAT allowance minus the clawback, plus the dispensing fee in addition. Dispensing fees can be maximised by prescribing smaller quantities, for example, individual flupenthixol injections rather than a box of 10. Dr Phipps is a dispensing GP in Lincolnshire Please contact Sarah Wild, [email protected] or call (020) 8267 4532