Registration of Social Workers and Social Service Workers in Care Services (Scotland) Amendment Regulations 2014 [Draft]
Item 2 is subordinate legislation. We have one affirmative instrument to consider: the draft Registration of Social Workers and Social Service Workers in Care Services (Scotland) Amendment Regulations 2014.
As usual with affirmative instruments, we will have an evidence-taking session with the minister and her officials. Once we have had all our questions answered, we will have the formal debate on the motion, if necessary.
I welcome the Minister for Children and Young People, Aileen Campbell, and her officials from the Scottish Government: Diane White, senior policy officer in the office of the chief social work adviser; and Katy Richards, solicitor in the food, health and community care division.
I give the minister an opportunity to make a brief opening statement.
Thank you for the opportunity to introduce the regulations, which were made under sections 78(2), 78(3) and 104(1) of the Public Services Reform (Scotland) Act 2010. The regulations amend the schedule to the Registration of Social Workers and Social Service Workers in Care Services (Scotland) Regulations 2013.
The 2013 regulations require social services workers within the scope of registration to register with the Scottish Social Services Council—specifically, all new workers who are commencing employment in any of the groups that are within the scope of registration must achieve registration within six months of commencing employment—and set final dates by when existing workers must achieve registration.
The draft regulations relate to the latest group of workers for whom registration with the SSSC will commence in June 2014—namely, supervisors who work in care-at-home and housing support services. The provision amends the schedule to the regulations to set the date when existing workers who work in those services must achieve registration with the SSSC.
In summary, the regulations maintain and fulfil the policy intention that registration with the SSSC is a prerequisite of employment and continuing employment, and provide the final dates of registration for the latest group of workers.
I am happy to answer any questions that the committee may have.
Thank you, minister. Do members have any questions?
I wonder whether there is a qualification attached to the registration. Is there a minimum qualification that those people need to attain? If so, how long does it take for someone with no previous qualification to get to that level?
The level of qualification that is required is Scottish vocational qualification level 3.
Diane, would you like to comment on timing?
The timing can vary between 12 and 18 months. It depends on how much experience the worker has, because their experience goes towards the accreditation in obtaining the qualification.
The regulations provide for a lead-in time up to 2017, so there is a period in which workers can register. The closing date is 2017, so there is time for this group of workers to gear up to be able to register.
Do you think that three years is adequate to allow people to qualify, given that they may not get the certification first time?
The original bill was consulted on and we put out the draft regulations for consultation to all employers, employees and unions and representative groups such as Unison, but no comments came back. I think that the timescale is achievable for this group of employees and that there will be enough time for them to get the right qualifications. The act was passed in 2010 so, as well as having the time from now until 2017, the workforce has understood since 2010 that there will be a requirement for registration.
Good morning, minister. Is there a cost for registration? If so, will it be uprated yearly or at other points?
The cost will depend on the level of the person’s role—for example, the cost for senior managers is £30 and the cost for the group that we are talking about today is £20. There are different strands and tiers of cost, depending on the person who registers.
Is it a yearly cost?
Yes.
There are no other questions from members, so we now move to item 3, which is the formal debate on the affirmative Scottish statutory instrument on which we have just taken evidence. I remind the committee and others here that the members should not put questions to the minister during this formal debate session and that officials cannot speak in the debate.
Motion moved,
That the Health and Sport Committee recommends that the Registration of Social Workers and Social Service Workers in Care Services (Scotland) Amendment Regulations 2014 [draft] be approved.—[Aileen McLeod.]
Motion agreed to.
I thank the minister and her officials for their attendance this morning.
Thank you.
09:52 Meeting suspended.National Health Service (Pharmaceutical Services) (Scotland) (Miscellaneous Amendments) Regulations 2014 (SSI 2014/148)
Under item 4, we will take evidence on the National Health Service (Pharmaceutical Services) (Scotland) (Miscellaneous Amendments) Regulations 2014 (SSI 2014/148). It should be said that it is slightly unusual to take evidence on a negative instrument but because, as everyone would agree, there has been a fair bit of interest in this issue, I thought that it would be useful to invite Scottish Government officials along to answer any questions that members might have.
We have with us this morning a panel of witnesses from the Scottish Government: Professor Bill Scott, chief pharmaceutical officer and deputy director, finance, e-health and pharmaceuticals directorate; David Thomson, deputy director, primary care division; and Katy Richards—still with us from earlier—who is a solicitor in the food, health and community care division.
We will go straight to members’ questions.
I hope that our witnesses are aware of the questions that I asked in last week’s meeting of the Public Petitions Committee, which were designed to give notice of the areas in which I have a particular interest. I should begin by declaring my membership of the Royal College of General Practitioners and the British Medical Association, and I remind members that I have an interest—although not a personal one any more, I am glad to say—in the area that we are discussing.
10:00This is our second bite at this. We changed the pharmaceutical services regulations in the previous session of Parliament and thought that we had got them right then, but we clearly had not. I hope that we have got them right this time. I very much welcome the new regulations, but there are some outstanding issues.
Can the witnesses give us an indication of the potential definition of the new concept of controlled localities, which will be designated to protect remote and rural practices? That would help those who still have concerns about how geographically large or small a protected locality is likely to be. Can the witnesses give us further information on that?
I ask David Thomson to address that.
Thanks for the opportunity to explore the regulations with the committee. Through the regulations, we hope to address four objectives. We want to enhance the objectivity of the process; to give due weight to the effect on a dispensing practice that is affected by the application; to ensure that all those who are affected have the right to consultation; and to improve access to pharmacies for patients of dispensing practices. Those are the aims of the regulations.
The amendments introduce the concept of controlled localities, as Dr Simpson said. The aim of the controlled locality is to provide some extra process in the consultation for areas within a health board that are remote or rural in character and that are served by a GP dispensing practice. That is the policy aim behind it. Katy Richards will be able to talk you through the elements of the regulations that provide that definition.
I am the drafting solicitor and can help to explain the effect of the 2014 regulations.
The process is quite specific and we believe that it should be readily understood. A newly inserted paragraph 1A of schedule 3 to the National Health Service (Pharmaceutical Services) (Scotland) Regulations 2009 sets out two requirements that an area must satisfy to be classed as a controlled locality. First, the area must be remote or rural in character and, secondly, there must be a dispensing doctor in the area. The term “remote or rural” is further explained in the “Scottish Government Urban/Rural Classification 2011-2012”, and the existence of a dispensing doctor will be a matter of fact. In that regard, the requirements for a controlled locality are known in precise conditions, and dispensing GPs can look at the “Scottish Government Urban/Rural Classification 2011-2012” to assess the likelihood of their area being classified as remote or rural. In addition, paragraph 1A states that, once a particular area has been identified as being a controlled locality, the boundary of that controlled locality will be the same as the dispensing doctor’s practice boundary.
Thank you for that. I hope that that information will be fed out in more detail, perhaps even in a map or in a list of the practices that would fall within the scope of the regulations, so that every doctor will not have to look it up but will be aware of it. That would be helpful in reducing the significant tension that exists among dispensing practices.
Can I ask a supplementary question, convener?
Yes.
At the moment, the proposal is that the designation will last for three years, except in exceptional circumstances such as the building of a new housing estate or some other substantial development that might alter the character of the locality. We should remind ourselves that GPs are running businesses and, in my view, three years is not long enough for people to be able to plan the future of their businesses. A limit of three years could create uncertainty except in very remote and rural areas, where change as a result of the regulations will be much less likely.
It is that borderline that has been pushed out. We want more pharmacy services but we have affected those practices badly, as the Wilson and Barber report indicates. In paragraphs 49 to 51 of that report, the authors state that they are very concerned about destabilisation. I am still concerned about that boundary and wonder why the Government has settled on the limit of three years rather than five years or even, for some areas, a longer designation that would allow certainty in business planning and in investment in the dispensing part of a practice.
I can understand that sentiment, Dr Simpson. When we put the consultation out, the response that we got back was from one year and upwards. I have to be honest; we chose three years just to get a balance. That was linked to the pharmaceutical care planning that the boards have to do. In that planning tool, they review their plans every three years.
Thank you. That is a helpful explanation, but it does not give comfort to the ones on the boundary and their business planning. I still think that that is wrong.
As you know, convener, I did not move to annul the regulations because it is important to get this done quickly. This is a useful advance, but the situation will need to be watched carefully to see whether there will be considerable tensions on that boundary in the future.
We will take into account the points that are made here as we look at the guidance that we will put out.
Thank you.
I have a couple of questions. The first is about when a GP and a pharmacist want to co-locate but other pharmacists in the area block that. What is the role of the community if it supports the co-location? How much credence is given to its wishes to have co-location?
The regulations do not prevent co-location. However, the regulations look at all applications that come in, so we have to be aware of the possible unintended consequences of that, such as the inadvertent introduction of commercialisation in the primary care services, effects on the financial interests of GPs and others, and whether large companies that have money to go in with industry to build health centres then apply for the contract. That means that other pharmacies in the high street could be affected, which could have the unintended consequence of reducing the number of pharmacies, because they still depend on prescriptions.
If a health centre that has a pharmacy closes at the weekend, patients cannot get pharmaceutical services. We have found that in a number of pharmacies within health centres. It is therefore not just the one aspect of coterminosity that applies in the regulations. This issue goes much wider.
What notice is taken of the community’s position? For example, a community might be keen to have co-location because it makes it easier for people who are, for example, travelling a distance and who might not want to have to go somewhere else to access the pharmacy. What credence is given to the community’s position if it is keen to have co-location but pharmacies from outwith the area are keen to stop such development going ahead, because patients normally have to go to their GP and then travel to the pharmacy, which might be some distance away? Sometimes the other pharmacists, who are obviously trying to protect their businesses, are given more credence in the discussion than the community that will benefit.
We have asked the pharmaceutical services care plan to look at the services that are provided and where they are provided, and to match those with the demographics of the surrounding area. That is one vehicle that the community can use to make its representation.
So the community representation will be taken seriously.
Yes. Those plans will not be constructed by the boards without taking into account the communities that they serve. The communities will have input into the plans.
I have another question, which turns the thing slightly on its head. I welcome the regulations before us, as there are lots of issues that need to be dealt with. However, my view is that they do not deal with allowing patients in remote rural areas to access pharmacy services. People obviously want their GP services to be protected; they do not want a pharmacist if it is going to cost them the GP services that they know and enjoy. The regulations do not deal with the issue that people will benefit if they get access to pharmacy services. How can we get people in those rural areas to have access to pharmacy services that do not undermine their GP services?
As you know, we are going to have clinical pharmacists to support the general practitioners with their patients, for reasons of helping with complex medicines and complex patients. The issues that you are addressing may relate to the minor ailments service. How do people get medicines without having to go to the general practitioner all the time? We would want to consider how we do that in future in a way that does not undermine the general practitioner, yet, at the same time, does not require the community pharmacy to put in an expense on which it is not getting a return.
So that is work in progress.
It is work in progress.
There is also the issue of people with complex conditions who would benefit from sitting down and speaking to a pharmacist, rather than having the GP getting advice and the patient then getting that advice from the GP—who might themselves benefit from sitting down with a pharmacist, going through the patient’s medication and perhaps tweaking the regime to suit the patient’s lifestyle. That is particularly important with long-term conditions and palliative care.
I agree. We received a project proposal from the Western Isles just yesterday. We are considering it, as it will help us to shape the model that will serve patients in rural communities.
I do not have a declarable interest in this subject although, some years back, my sister-in-law ran a dispensing practice in the north of Scotland.
I am aware that GPs invest a significant amount in equipment, in readapting premises and in employing staff. If a community pharmacy were to take over in an area, is there any plan to compensate GPs in any way for the outlay that they might have made? What about the staff whom they are employing specifically to do pharmacy work? Would they be transferred to the incoming pharmacy? Has any arrangement been made about that?
I will ask David Thomson to answer that.
GPs, who are independent contractors, continually make decisions about their own investments. In contrast with pharmacy contractors, who are responsible for the provision of all infrastructure and staff who are required to deliver pharmaceutical services, dispensing doctor contractors, in addition to the dispensing remuneration that they receive, also have the costs of the premises that they require to provide dispensing services covered by the health board. They are already getting a potential advantage there.
On the question whether any redundancy costs would fall to the original employing practice, should staff be made redundant, the contractor would normally seek to redeploy those staff if possible. We are aware that, in practice, some staff have, as you have said, transferred to the new pharmacy, where the costs would obviously be borne by the new pharmacist.
When a dispensing practice loses its dispensing rights, health boards normally allow a period of grace for that practice to continue to dispense, giving it access to income to help with winding-down costs, including stock recycling and some staff redundancy costs.
In our view, it is important that the board and the practice are in discussion at an early opportunity to discuss the impact on the individual GP contractor’s business and to consider jointly how to continue the delivery of GP services in the area.
Would any transfer of staff be under the Transfer of Undertakings (Protection of Employment) Regulations 1981?
I am not a lawyer, so I would not want to answer that. I am not sure whether Katy Richards is qualified to answer that either. I think that, in some circumstances, TUPE would apply, but I could not say that definitively for each situation.
10:15
It would seem reasonable that they should have the same terms and conditions as they have been used to.
Do the witnesses have any further response?
As David Thomson said, it is not my area, but what I know about TUPE is that it tends to be fact specific, so it is not possible to make a general statement about whether something would or would not transfer without knowing specific information about cases.
My understanding is that there is no protection. Unlike any other business, GPs do not have the right—nor should they have the right—to sell the good will, so they are not able to receive recompense for their investment. I understand the point about premises, but the GPs are still left with premises that they may be renting or that they may have built or purchased, unless they can use them for other purposes or renegotiate a rental agreement or recompense from the board to compensate them for the bit of space that is now no longer required.
Frankly, there is a failure in the regulations to address the whole area of the retraction of a service from general practitioners. For example, the GP in Drymen had invested a not insignificant amount for a small practice—£3,500 or £4,000—in software to improve patient safety. That is now of no value to her whatsoever. She cannot sell it to anybody else; it has no value. When the pharmacists take over the dispensing, they are not paying anything to us as taxpayers or to the health service for the effective good will that they are acquiring.
We have a commercial situation in which, if the new pharmacy’s financial sustainability is borderline, that is now one of the items looked at in the new regulations, and I am glad to see that. However, if the pharmacy is in a town and is highly sustainable, it can be acquired without any purchase of good will from the health service. I feel that we have lost an opportunity to say that, in some cases, we will want there to be a pharmacy, because it will be in the practice’s interest and it will charge nothing, whereas in other areas, we would like to charge something.
That was a supplementary question.
I appreciate that, convener.
We need to allow the witnesses to respond, and other committee members have questions.
At the pharmacy in Millport, there were four members of staff working in the GP practice, two of whom were re-absorbed into the practice and two of whom were transferred over to the pharmacy. That may not be a TUPE agreement, but it was a way of trying to sort things out. Good will does not exist for NHS services. Good will is about commercial services. As we discussed some weeks ago when we considered prescription for excellence, the amount of business that is coming through the front door of community pharmacies is now decreasing because of other competitors. Pharmacies receive no help with their rental, electronic systems or staff, so we are not publicly giving them money for that, and there is no good will in general practice, as Dr Simpson said.
Can I just check something? It may have been a turn of phrase that Dr Simpson used. He has made a lot of good points, but he spoke about a failure in the regulations and I would like to clarify whether the regulations strengthen the position of dispensing GPs in remote or rural areas.
I can answer that. The Cabinet Secretary for Health and Wellbeing has listened with concern to what has been said in the Parliament and what has been coming through from communities and from people who have written in. He was most insistent that it should be a priority for us to address how we strengthen dispensing doctor practices. That is the purpose of the regulations.
That is helpful. I just wanted to be clear that there is not a failure in the regulations. Dr Simpson and others perhaps think that there may be an opportunity to go further, either now or later, if the regulations are reviewed at a later date. The fact that the regulations strengthen the position of dispensing GPs was getting a little bit lost there.
Professor Scott, you used the word balance. I agree. The word commercialism has been used quite a lot as well. GP practices are commercial concerns, as are community pharmacies. I agree that there should be additional protection in certain circumstances but you are also in effect providing a commercial monopoly to one business against another. Is that one of the reasons why you went for a review period of three years? It is quite a big thing to give, for all the right reasons, a commercial monopoly to one commercial interest and exclude other commercial interests. Was that a concern when you went for three years?
That is one of the concerns. You may get a new housing estate or some new use of land that could alter the balance; we have to keep looking at that.
As we have said before, we are very conscious that the national health service is a public service. Regardless of any commercial activity, our requirement is to provide an environment for co-operation within the NHS. One of the aspects that we considered was trying to strengthen co-operation between the clinical pharmacists and the GP surgery, just as we are doing in the wider pharmacy and GP community.
You mentioned clinical pharmacists. In theory, is there anything to stop community pharmacists from forming such a relationship with GP practices in remote and rural areas? Are they excluded from doing that?
We can use pharmacists who are employed in any capacity. The one thing that we must do, though, is to ensure that we are not providing a perverse incentive. We have to ensure that a pharmacist’s activity is about the patient and not any commercial approach that their employer would want.
It is about who is best placed to provide the service in that area.
Yes.
Financial sustainability is a key criterion. I am not talking about GPs per se. My colleague Gil Paterson has business experience that I do not have, but I suspect that if you ask a dispensing GP in a remote or rural area whether their dispensary is vital to their sustainability, every single one will say yes, because if they do not have a monopoly on that, they will lose money. However, losing money does not necessarily make a GP practice unsustainable; it just means that it has less money. How do you get the balance between commercial self-interest and what is sustainable? How is that teased out?
I will bring in David Thomson.
It is important to note that dispensing income for GPs is never intended to cross-subsidise the delivery of core services. That is in our statement of financial entitlement and those directions are the financial basis for the regulations. We do know that that is not what plays out on the ground. It is important that we recognise that, even if the rules state something slightly different.
You asked about balancing the commercial interests of both parties. That is why we have drawn the regulations in such a tight way, with a very specific set of criteria to define a controlled locality: it will be remote or rural, and it will have a dispensing GP practice. We recognise that there will be tensions. As has played out previously and will play out under the new regulations, there will always be an argument about whose commercial interests are best served.
I will clarify the effect of a controlled locality. Words such as “monopoly” have been used and I want to ensure that people’s understanding is correct. A controlled locality designation does not necessarily mean that a pharmacy application will not be granted. The existing test of necessity or desirability still applies but, in addition, the pharmacy practices committee of the NHS board looks at whether granting the application could prejudice the existing provision of primary medical and pharmaceutical services in the controlled locality. If the PPC decides that an application would create no prejudice, it can grant the application. The aim is to strike the balance.
That explanation is much more nuanced and has helped me to understand the position; I lacked understanding before.
It helped that Mr Thomson put it on the record that there is no cross-subsidy. The issue is more about how we retain in certain localities GPs who might for whatever reason otherwise decide to relocate; it is not about making the delivery of primary healthcare affordable, because there is no cross-subsidy from the dispensing part of the business—it was helpful to know that.
I am a city MSP, so I do not know the nuances and dynamics in remote or rural areas, but I think that a community pharmacy can involve not just a pharmacist but someone selling a loaf of bread and a pint of milk. Such an outlet could address other social concerns. A dispensing pharmacist in a community could have a regenerative dynamic, outwith a GP’s dispensing role. Is that considered as part of the overall package when a community pharmacist seeks to go on an area’s pharmaceutical list? Are such issues looked at in the round?
The main concern for the NHS is the national health services that would be provided.
I am just trying to understand the bigger picture. I have no further questions.
I welcome Professor Scott’s comments about safeguarding and strengthening the situation. Like others, I have received a couple of emails. One was sent to me by a doctor, whom I will not name. They suggested that the regulations say nothing about how commercial pharmacies will be sanctioned if they do not fulfil the promises that they make to a health board. How will they be sanctioned?
We have systems in the NHS whereby, if a contractor does not provide the required service, they can be taken to a disciplinary committee. Further to that, if a patient or the board is not satisfied, the pharmacist can be referred to the General Pharmaceutical Council—the regulator—which could have severe consequences.
The regulations do not need to specify that—other legislation or procedures can be invoked against pharmacies that do not fulfil their duties.
Yes.
TUPE has been mentioned and I have a couple of questions on it, which I will round up. I take it that someone who is employed by a dispensing GP is employed solely by the GP and that the health service does not participate in that. Is that right?
That is correct, unless a board employs a member of staff to work in a dispensing practice. That does not apply in this case.
So the health service has no input into the number of people who are employed in a location, who those people are and what they do. Is that right?
David Thomson can back me up on this, but I think that dispensing practices are commercial businesses, so it is for them, and not the NHS, to determine who they employ and how those staff are used.
10:30
In other words, they are actually working in the private sector, not the public sector, and they are therefore covered by employment law. Just like the business that I own, they need to adhere to employment law. That means that the employer—whether it is me or a doctor—is responsible for any redundancy if the business closes for whatever reason. That is presumably the case.
I am sorry, but I do not feel qualified to answer that question.
It would be extremely worth while to have an answer.
It may be. The issue has been raised, but we are now getting into employment law. There would need to be an arrangement. The message that we are getting is that the national health service would not be expected to incur any additional costs as a result of any change in delivery of the service. Of course, if TUPE applied, the national health service would need to take on the liability for the tens of years of employment and, as a consequence, it would become liable for any future redundancy. The issue is pretty complex. I suppose that TUPE could apply, if the move was presented as some sort of takeover. However, the message that we have had is that the national health service in Scotland will not incur any additional costs as a result of the arrangements on the ground, and nor should it. Is that the position?
The transfer of any staff from one private sector body to another would be for the private sector. We regard community pharmacy, in that respect, as a private employer.
Okay. We have one more question, which is from Richard Simpson.
It is on the new consultation process. Whereas previously the applicant was required to consult the community, the consultation process will now be agreed between the board and the applicant. Concerns have been expressed to me about the fact that there does not appear to be a role for the GP practice that will be affected, or for the community. One problem is that GPs have encouraged their communities to—need I go on? The witnesses will know exactly what I am talking about. That is fair enough, but I am concerned.
I am not saying, as Bob Doris suggested, that the regulations are a failure. I very much welcome the regulations, but they do not address the issue of how the community can be involved in ascertaining that the process that is proposed in the consultation is one that it subscribes to. I can foresee a situation in which the board and the applicant agree, the consultation goes out and the community—whether or not it is encouraged by anybody else—says, “I’m sorry, but we don’t think this process is reasonable, fair or correct.” How will you get communities involved in agreeing that? Should the board be required, through guidance, to consult the community council, which eventually will put up the named person? Will you explain that a little more?
I am sorry, convener, but that is not my last question.
As you know, health boards have a general duty to ensure that any consultations that they undertake are consistent with the Scottish health council guidelines. As we produce our guidelines, we shall look to address some of those concerns. I take the point that we have to ensure that we differentiate propaganda from fact.
My last question arises from Katy Richards’s comment that being a protected practice or designated locality—or whatever the term is; I have forgotten it—does not give any protection, because an application can be made for any area in Scotland.
That is a slight concern, because although there would be a three-year designated locality, an application could be made and there would then be an assessment as to what effect it might have on the practice. As far as I can see in the regulations—I might be wrong, because they are quite detailed—there is no requirement on the board to have any discussions with or investigations of the practice to determine what the potential effect might be before the process starts. In a designated locality, if an application comes in, is there a requirement on the board to go and talk to the practice and say, “We’ve received this application. You’re in a protected locality. What effect will it have on you if we proceed with the application?” Can Katy Richards explain that to me?
I ask that question, because my other concern is about a basic fallacy that is not being addressed, which David Thomson has alluded to. We know very well that there is cross-subsidy—he has said that on the record. Although the intention is that there should not be, the business of general practice has a wholeness to it—it takes a holistic view—which includes dispensing in its costs and any money that it gets in from it. I have a serious concern that we have not got this right. I hope that we have, Mr Doris, but I still have that concern. Could that issue be addressed? There has not been a review of the effectiveness of our previous regulations on practices, which I have asked for.
We have had a very good question-and-answer session here, Richard. I want the witnesses to respond to your question. Gil, do you want to ask something?
No, it is okay. I will forego my second question.
Could we have a response from Katy Richards and others to the question that Richard Simpson put?
As I said before, the idea of the controlled locality is to increase the protection that is given to a dispensing GP. It introduces a further layer of scrutiny for boards in relation to existing primary medical services, which did not apply under the old regulations, so that is a new thing.
You asked how a PPC might assess the effect on a practice. That is about the new joint consultation process. New regulation 5A, which introduces that new concept, sets out specific questions that the community is asked to provide views on, one of which is the potential for pharmaceutical services provided by the applicant to impact on existing NHS services. It would be for a dispensing GP and any members of the community who had relevant views to write in. After the consultation has finished, a consultation analysis report will be created, which will summarise the responses. The PPC has to look at that report when it determines an application.
We recognise that dispensing income might have become part of the business planning model for a number of practices. When a practice is having to withdraw or reduce a patient service as a result of the loss of dispensing income, and the continuation of that service is considered to be necessary for the community, we expect that the health board and the practice will be in discussion to put in a properly funded contractual arrangement for that. We recognise the situation.
I thank the witnesses for their attendance this morning at this longer-than-expected session, with extended questions and answers.
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