August 14

The PSI seems to have a thing about consultations. Last month it was mail order pharmacy and this month it’s the fees charged by the PSI. Coming up later in July is the draft policy on Data Protection. Since it’s inception in 2008 the PSI has announced twelve consultations on various draft policies. There have been four this year already. The Council seems to be unable to make a decision about anything without a consultation. Like the Mail Order consultation I also sent in a submission on the issue of fees as well. Not as comprehensive as I still have a pharmacy to run. What follows is a brief synopsis.

When the new PSI was inaugurated initially it was stated that one of the reasons for high registration fees was that they needed to build up a reserve in case it was challenged in the courts.

This reserve fund now stands at over €11 million. There is now no justification in continuing to charge excessive fees to pharmacists and community pharmacies to grow this fund further. Last year the PSI generated a surplus of over €1 million.  This equates to approximately €550 per pharmacy. That is to say, the PSI could reduce registration fees to community pharmacies by €550 per annum and still generate a surplus each year.  Also in relation to a reserve fund, what happened to the funds of the old PSI upon it's dissolution and the proceeds of the sale of Shrewsbury Road. These funds could greatly reduce the burden on Irish pharmacists to continue funding the PSI.
When compared to the UK and Northern Ireland the costs of registration of community pharmacies is excessive to say the least. The GPhC in the UK regulates 47,000 pharmacists and 14,000 pharmacies and has a budget of only €26 million.  That is nine times as many pharmacists, twenty six times as many pharmacies but only three and a half times the budget.  In the North the PSNI regulates 2,100 pharmacists and 550 pharmacies and has a budget of €1.25 million. That is 30% of the number of pharmacists and 40% of the number of pharmacies yet it does all this with only 17% of the budget of the PSI.2,250 to register a pharmacy in Ireland, €195 in Northern Ireland and €277 in the UK.  Ten times the cost for one tenth of the work.
The question must be asked where and on what is the PSI spending money on that the GPhC and the PSNI are not?  Is the PSI needlessly duplicating the work of other government and semi-state agencies?  HIQA for instance inspects hospitals.  Is it really necessary for the PSI also to inspect hospital pharmacies? The same can be said for various tasks carried out by the HSE and HSA which the PSI seems hell bent on duplicating.  Are the tasks being carried out being expanded to fill the available budget rather than what is necessary or required?
Has there ever been an independent value for money audit of all of the PSI's activities? How much benefit if any is there to the public or patients compared to the costs of each activity?  This could be evaluated in a manner similar to QALYs when considering a medical treatment.
In relation to staffing, the PSI currently has a staff of 35. One member of staff for approximately every 50 community pharmacies or one for every 143 pharmacists.  The Medical Council has a staff of 51. They regulate 18,000 doctors, one member of staff for every 350 doctors.  The Dental Council has a staff of 5 (yes single figures) and they regulate 2,600 dentists. One for every 500 or so.  The Veterinary Council also has a staff of 5 and regulates 2,350 vets and 697 veterinary practices. One for every 490 vets or one for every 140 practices.  Their registration fees are €535, €200 and €450 respectfully. While there cannot be a direct comparison between these bodies their work is not that dissimilar.
The GPhC in the UK has a staff of 194. The break down is as follows.  Over all 194 staff of which 28 are inspectors. 46,748 pharmacists & 14,337 pharmacies. One member of staff per 240 pharmacists and per 74 pharmacies. One inspector for every 512 pharmacies.
The PSI has 35 staff and 7 inspectors, 5,100 pharmacists and 1,820 pharmacies. One staff member for every 146 pharmacists and one for every 52 pharmacies.  One inspector for each 260 pharmacies.  Comparisons with these other organisations would seem to indicate that the PSI is grossly over staffed.  Again it must be asked, are staff of the PSI undertaking tasks that could be performed by other agencies and are not strictly part of the PSI's remit?
The PSI has 7 authorised officers. As I said, one for every 257 pharmacies. Allowing for holidays etc this means that each inspector can spend a full day inspecting a pharmacy and still every pharmacy would be inspected one per year. This sounds to me as a massive under utilization of resources. While on this point I noted that announced inspections can be much more efficiently carried out. While there will always be a place for unannounced inspections it would seem that it would be a much better use of inspectors time if the majority of regular inspections were announced.

[edit: you can drop this next paragraph if it is running too long]
I asked if efficiencies and salary reductions have taken place as a result of the Croke Park and Haddington Road agreements and have these reductions been reflected in PSI expenses?  Every other area of the public service has taken a hit.  Albeit none as severe as the hit that community pharmacy has taken.  
The scale of the fees to community pharmacies in particular is at odds with the stated government policy of helping small businesses.  To put it in context. I have recently re-located my pharmacy. My biggest expense in this was the shop fitter. My second biggest expense was fees paid to the PSI!
[edit: you can drop this next sentence if it is running too long]
  This was more than the cost of re-wiring a shell of a premises from scratch, more than the cost of replacing the entire shop front and more than the cost of installing a full security and CCTV system.
Also in relation to small businesses the high level of the pharmacy registration fee is a disproportionate burden on the smaller pharmacies. After salaries and wages the PSI registration fee is amongst one of my biggest annual expenses. I feel that there should be a scale of fees based on square footage or something similar. Also I am disappointed that there is no facility to pay in instalments which might ease the burden somewhat.  
I would love to be privy to the discussions in committee on this issue.  But it will all be shrouded in secrecy.  The executive of the PSI will justify all their outlandish expenses and then all we will get is a note in the minutes of the Council of the recommendations of the committee.  If we are lucky we might get another 5% reduction that was so rightly jeered at this year's IPU conference.  All this just brings into focus the need to have community pharmacists with real world experience on the Council.  That's if any left who will take on the role.

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