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Pharmaceutical Services Negotiating Committee

Returns

In some cases, copies of prescriptions processed via CIP are being returned to contractors for clarification which would have previously been processed without being returned via the manual legacy pricing systems.

NHS Presription Services is addressing this problem through staff training and a review of GP system supplier’s legacy drug dictionaries. Some positive progress has been made to reduce the number of inappropriate returns but PSNC believes that much more must be done to fully resolve the problem.

The table below shows the percentage of prescription items returned to contractors in recent months:

Average No. of Referred Back Prescriptions

                                        Legacy*        CIP

January 2008

0.81%

0.55%

February 2008

0.89%

0.49%

March 2008

0.88%

0.47%

April 2008

0.82%

0.43%

May 2008

0.85%

0.40%

 June 2008† 0.88% 0.39%
 July 2008 0.83% 0.37%
 August 2008 0.71% 0.38%
 September 2008  - 0.40%
 October 2008  - 0.40%
 November 2008 0.39% 
 December 2008 0.35%
 January 2009 0.34%
 February 2009  - 0.35%
 March 2009  - 0.32%
 April 2009 0.32% 
 May 2009 0.33% 
 June 2009 0.33% 
 July 2009 0.42% 
 August 2009  - 0.39%
 September 2009 0.40%
 October 2009 0.38% 
 November 2009 0.38%
 December 2009 0.34% 
 January 2010 0.33%
 February 2010 0.32%
 March 2010 - 0.31%
 April 2010 0.32% 
 May 2010 - 0.32%
 June 2010 - 0.32%

* Under the legacy processes, the prescription form itself was sent back to contractors for clarification with payment delayed for all items on the form. PSNC agreed a change to the processes for CIP, to allow a copy of the form to be returned and for payment only to be delayed for the particular item on the form where clarification was being sought.
† In June 2008, the NHS Prescription Services amended the way that these statistics were generated but this did not make a significant difference in the statistical results

PSNC is continuing to closely monitor problems with copies of prescriptions being returned for clarification unnecessarily. To report suspected unnecessary returns to the PSNC Information Team, click on the link below to access the special online feedback form:

Suspected Errors with 'Returns' Feedback Form

PSNC will ensure that this information is fed back to NHS Prescription Services so that solutions, for example further training of staff can be adopted where possible. Alternatively, contractors can also contact the NHS Prescription Services Help Desk directly to report and discuss returns (0845 610 1171).

Known Issues include:

Different Terminology on Prescription vs Pricing System

At present, GP systems use different drug databases in their systems. In practice, this means that different systems can use slightly different descriptions for the same product. The NHS Dictionary of Medicines and Devices (dm+d) has been developed as the future standard for medicines and device identification and in EPS Release 2, all GP system suppliers will issue electronic prescriptions using the same standard dm+d descriptions.

NHS Prescription Services' pricing system and staff use the product descriptions held in dm+d and the staff refer to the dictionary for product information. In some cases, copies of prescriptions are being returned to contractors for clarification which would have previously been processed in the manual legacy systems. A key reason for this is the use of non-standard or synonymous formulation descriptions on prescriptions, for example there have been recent cases of prescriptions for ‘enteric coated’ tablets being returned because dm+d uses the description ‘gastro-resistant’ tablets. Frequently reported examples are:

 

 Prescription dm+d Description 
Diclofenac Dual Release Capsules 75mg Diclofenac Sodium 75mg Modified Release Capsules 
Morphine Sulphate Oral Solution 10mg/5ml  5ml Unit Dose Vials Morphine Sulphate Oral Solution 10mg/5ml  5ml Unit Dose Vials Sugar Free
Paroxetine SF Susp 20mg/10ml Paroxetine 10mg/5ml Oral Suspension Sugar Free
Vitamin B Compound Forte Vitamin B Compound Strong
Flucloxacillin Elixir 125mg/5ml Flucloxacillin 125mg/5ml Oral Solution
Penicillin V 125mg/5ml Phenoxymethylpenicillin 125mg/5ml Oral Solution
Paracetamol Elixir Sugar Free Paracetamol Oral Solution Paediatric Sugar Free
Bumetanide 1mg/Amiloride 5mg Amiloride 5mg/ Bumetanide 1mg Tablets 

 

NHS Prescription Services are addressing this problem through staff training and a review of GP system supplier’s legacy drug dictionaries. PSNC has also written directly to GP System Suppliers to alert them about this problem and to request changes to the descriptions used for certain products.

Same Brand Marketed by Multiple Suppliers

There are a number of cases where products with the same marketing authorisation number and brand name are marketed by a number of different suppliers, for example Dianette Tablets are manufactured by Bayer Plc and is supplied to Mylan under third party livery. A prescriber may issue a branded prescription for Dianette Tablets and a pharmacist will have the flexibility to dispense either supplier's product. As the reimbursement price of a branded drug is based on the manufacturer's list price, reimbursement prices for these brands may differ depending on the manufacturer supplied.

Under the legacy processing procedures, if a prescription was not endorsed to indicate supplier, NHS Prescription Services would default to the reimbursement price for the originator supplier's product. The CIP system no longer defaults to a particular supplier's product so the name of the supplier must be endorsed to ensure that copies of prescriptions aren't returned for clarification. Products know to be affected include:

  • Besavar XL 10mg tablets (marketed by Actavis and Teva)
  • Beta-Prograne 160mg modified-release capsules (marketed by Teva and Tillomed)
  • Dianette (marketed by Bayer Plc and Mylan)
  • Dicloflex Retard 100 tablets (marketed by Dexcel- Pharma, Almus and Kent )
  • Dicloflex 25mg gastro-resistant tablets (marketed by Dexcel-Pharma and Almus )
  • Dicloflex 50mg gastro-resistant tablets (marketed by Dexcel-Pharma and Almus)
  • Dicloflex SR 75 tablets (marketed by Dexcel-Pharma, Almus and Kent )
  • Dolenio 1500mg tablets ( marketed by Actavis and Alissa)
  • Half Beta-Prograne 80mg modified-release capsules (marketed byTeva and Tillomed)
  • Levest 150/30 (marketed by Actavis and Morningside Healthcare)
  • Monosorb XL 60mg (marketed by Dexcel-Pharma and Kent )
  • Nazdol 30mg MR tablets (marketed by Consilient Health and Teva)
  • Nifedipress 10mg MR tablets (marketed by Dexcel-Pharma and Teva)
  • Nifedipress 20mg MR tablets (marketed by Dexcel-Pharma and Teva)
  • Verapress MR 240mg tablets (marketed by Dexcel-Pharma and Sandoz )
  • Vera-Til SR 120mg tablets (marketed by Actavis and Tillomed)
  • Vera-Til SR 240mg tablets (marketed by Actavis and Tillomed)

The Department of Health have confirmed that if after being returned to the contractor, the script is re-submitted without the required endorsement, reimbursement will be made based on Part II clause 7C of the Drug Tariff, where the Secretary of State for Health will determine the price paid. This will be the lowest price that can be paid for that particular brand.

Generic prescriptions for Inhalers which include a Trademarked Name 

Particular problems are being experienced with generic prescriptions for inhalers where the prescriber has included a trademarked name to describe the type of inhaler required, for example:

  • Accuhaler is a registered trademark owned by GSK 
  • Easi-breathe is a registered trademark owned by TEVA
  • Turbohaler is a registered trademark owned by AstraZeneca 
  • Twisthaler is a registered trademark of Schering-Plough

If a generic prescription for an inhaler is received which includes one of these trade-marked terms to describe the style of inhaler then legally and ethically, the pharmacy should dispense the proprietary product which meets this description.   For example if a prescription is received for, 'Fluticasone Proprionate 50mcg Accuhaler', GSK's 'Flixotide 50mcg/dose Accuhaler' should be dispensed. The prescription should be endorsed with the product's brand name, for example 'Flixotide 50mcg/dose Accuhaler'.

No Pharmaceutical Form Listed on the Prescription

Under the legacy processes, if the pharmaceutical form was not stated, NHS Prescription Services staff had a list of defaults to base payment on, rather than return the prescription for clarification. For example, in some cases, if the product was available as either capsules or tablets, reimbursement would be based on the price of tablets. These defaults are no longer in use where prescriptions are processed via CIP. This improves transparency, however the pharmaceutical form must be stated on the prescription, either as part of the prescribing or endorsing information, otherwise a copy of the prescription will be returned for clarification on what has been dispensed.

Where only one pharmaceutical form exists and the pharmaceutical form is not stated on the prescription,  payment will be automatically based on this pharmaceutical form.

Non-Part VIII Generic Endorsed with Supplier versus Brand Name

There has been an increase in the number of prescriptions for non-Part VIII generic products returned for clarification where the prescription has been endorsed with the supplier’s name rather than the supplier, for example, ‘Propranolol SR Caps 80mg’ endorsed with the supplier ‘Sandoz’ rather than the brand name ‘Bedranol SR 80mg Caps’.

This was occurring because NHS Prescription Services exception handlers did not have access to information that links the generic name to the supplier of the brand. From prescriptions dispensed in February 2008 the exception handlers will have access to this information. NHS Prescription Services are also working to address this problem through changes in the way that information is displayed on screen to staff.

Part II Clause 9 of the Drug Tariff allows contractors to endorse prescriptions for non-Part VIII generics using either the brand name or the supplier; there are no plans to change this therefore there is no requirement for contractors to change their endorsement practice.

PSNC is continuing to closely monitor problems with copies of prescriptions being returned for clarification unnecessarily. An online reporting form is available on the PSNC Website (www.psnc.org.uk/CIP)  to report suspected unnecessary returns to the PSNC Information Team. PSNC will ensure that this information is fed back to NHS Prescription Services so that solutions, for example further training of staff, can be adopted where possible.

Total Quantity Not Stated but clear from Dosage Instructions

PSNC has received a number of reports of prescriptions being returned where the quantity to be dispensed is clear from the dosage instructions, for example ‘Take 1 tablet TDS for one week’ but the prescription does not include a total quantity, either as part of the prescribing instructions or the dispensing endorsement information. PSNC has raised this issue with NHS Prescription Services and they are working to address this problem through staff training.

Although contractors are not required to endorse a total quantity where the prescriber's intentions are clear on the prescription, in this scenario, it is helpful to NHS Prescription Services processing staff for a total quantity to be included on the prescription.  

Endorsement of non Part-VIII Generic Products (including ‘specials’)

Part II Clause 9 of the Drug Tariff sets out the endorsement requirements. Where a product is not listed in Part VIII of the Drug Tariff and has been prescribed generically, for example requests for 'specials', the prescription should be endorsed with the pack size from which the order was supplied and either the brand name or the name of the manufacturer or wholesaler from whom the supply was purchased. For specials or if the product is less common, the purchase price before discount (ex VAT) should also be endorsed on the form.

Where a manufacturer supplies multiple brands that meet the same generic description, an endorsement of the supplier name is insufficient and it is necessary for the product brand name to be endorsed, for example:

A generic prescription for Insulin Glargine 3ml pre-filled pen needs to be endorsed with details of the brand supplied, for example:

  • Lantus OptiSet 3ml pre-filled pen (Sanofi-Aventis), or
  • Lantus SoloStar 3ml pre-filled pen (Sanofi-Aventis)

A generic prescription for Insulin Detemir 3ml pre-filled pen needs to be endorsed with details of the brand product supplied, for example:

  • Levemir Flexpen 3ml pre-filled pen (NovoNordisk), or
  • Levemir Innolet 3ml pre-filled pen (NovoNordisk)

Similarly, where Adizem is dispensed against a generic prescription for Diltiazem Hydrochloride M/R Capsules 120mg and 180mg, the endorsement will need to specify which product was dispensed as both Adizem-SR capsules and Adizem-XL capsules are modified release preparation.

Products where the brand name is very similar to the generic name (Glucosamine vs GlucOsamine)

As glucosamine and glucosamine sulphate are recommended International Non-proprietary Names (rINNs) and are not blacklisted by generic name, any brand of glucosamine including blacklisted items in Part XVIIIA of the Drug Tariff may be dispensed against a generic prescription for this product (Health Perception GlucOsamine Tablets are blacklisted). Contractors will be reimbursed based on the endorsed product.  

Glucosamine is manufactured by various manufacturers, one of whom is Health Perception who market a product called GlucOsamine. PSNC has received reports of a number of prescriptions for Glucosamine being returned for clarification where the brand name GlucOsamine was endorsed. We have alerted NHS Prescription Services to this so that this can be raised with processing staff as part of staff training.  However, as the generic and brand name of this product are so similar, to minimise the risk of prescriptions being returned,  it is recommended that where the 'GlucOsamine' brand is dispensed, the prescription is endorsed 'Health Perception GlucOsamine'.  


Resubmitting Returned Prescriptions

Photocopied prescriptions returned to contractors for further information contain a reference code. From this code, it is possible to determine the form type and whether the form was considered exempt from the prescription charge or charge paid. Where the patient is exempt there is also an indication of the reason why the patient was considered exempt. For example, from the reference code ‘FP10D E B’ on a returned photocopy, it is possible to tell:

  • the prescription form type, in this case an FP10D dental prescription
  • the exemption status, in this case, the ‘E’ indicates the prescription was considered exempt from the prescription charge. Prescriptions that are considered ‘Charge Paid’ will show the letter ‘C’
  • the patient’s exemption group, in this case, the ‘B’ indicates that the patient was exempt from the prescription charge because they were 16, 17 or 18 years of age and in full time education.

 Exemption Group Reference Codes:

 

A  is under 16 years of age
B  is 16, 17 or 18 and in full time education
C  is over 60 years of age
 has a valid maternity exemption certificate
 has a valid medical exemption certificate
F  has a valid prescription pre-payment certificate
G  has a valid War Pension exemption certificate
 is named on a current HC2 Charges Certificate
 was prescribed free-of-charge contraceptives
H  gets income support
K  gets income based Jobseeker's Allowance
 is entitled to, or named on, a valid NHS Tax Credit Exemption Certificate
S  has a partner who gets a Pension Credit Guarantee Credit
Z  exemption status not captured

 

 Resubmitted copies of forms should be sorted at the top of the 'exempt' or 'charge paid' group as appropriate and as directed on the FP34C Submission document. The number of returned forms and items being resubmitted should also be declared, in the relevant boxes on Part I of the FP34C Submission Document, for example the number of re-submitted copies that were exempt from the prescription charge should be added to the total number of forms in the 'Exempt from patient charge' field on the schedule. For ‘items’, only the number of items returned for clarification where payment has been delayed should be declared on the submission document as payment will already have been received for other items on the returned copies of the prescription forms.

This will ensure correct advance payment, however if contractors do not enter these items in the relevant group, it is a self correcting process and the contractor will be paid correctly via the final payment.


Copies of Prescriptions Returned Marked Disallowed

Where a copy of a prescription has been returned incorrectly marked as ‘disallowed’, it should be returned to NHS Prescription Services with the normal monthly prescription submission. The resubmitted item should be placed on the top of the bundle and clearly marked ‘Prescription Services Error – resubmitted for reimbursement’ (or equivalent).

Guidance on whether a particular product can be dispensed on an NHS prescription is available from the NHS Prescription Services' helpdesk (0845 610 1171) or from the PSNC Information Team (01296 432823).

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