Pharmaceutical companies are offering schemes whereby Clinical Commissioning Groups (CCGs) can receive rebates on dispensed prescription products. These may be referred to as “Rebate Schemes”, “Local Pricing Agreements” or “Local Discount Schemes”.
Primary care rebates schemes are contractual arrangements offered by pharmaceutical companies or third party companies which offer financial rebates on GP prescribing expenditure for particular branded medicines or prescribable products.
Individual CCGs will need to reach a decision regarding whether it will enter into these rebates or local discount schemes. This policy summarises the main points for consideration and outlines a process for assessing and managing these schemes.
This policy applies to Portsmouth Clinical Commissioning group including all employees, members of the CCG, co-opted members, members of the governing body and committees.
In the interests of transparency it is the duty of all staff to ensure that all declarations of interest are made in accordance with the CCG policy.
Price reductions on branded products are not available when items are prescribed on FP10; the Prescription Pricing Division of the NHSBSA will reimburse dispensing contractors at the manufacturer’s list price. Hospital Trusts can often negotiate purchasing discounts particularly if a group of Trusts are buying collectively. In addition, lower prices agreed as a condition of a NICE TA recommendation (Patient Access Scheme or PAS discount) are generally only available to purchasing NHS Trusts. As the discounted price is a condition of the NICE recommendation for provision of the medicine within the NHS, if the NHS does not obtain the discounted price it is not complying with the NICE TA guidance.
The rebate schemes may cover medicinal and non-medicinal products, appliances and assistive technology. The potential value of the rebate scheme and indirect costs associated with administering the scheme should be considered.
Legal advice sought by the London Procurement Partnership (LPP) in 2012 concluded that primary care rebate schemes are not unlawful and are within the powers of CCGs to agree to, provided they meet certain requirements. This advice has been used to inform this policy.