Associação Nacional das Farmácias
ANF
ANF's mission is making community Pharmacies the most valued primary health care network by the Citizens.
ID: 230671229116-26
Lobbying Activity
Response to Evaluation and revision of the general pharmaceutical legislation
27 Apr 2021
ANF, on behalf of the Portuguese Community Pharmacies, welcomes the opportunity to provide input in the context of the European Commission roadmap/inception impact assessment on the Evaluation and revision of the general pharmaceutical legislation.
Many of the issues raised by the European commission in the pharmaceutical strategy have a direct impact on community pharmacies and, consequently, on patients’ timely access to safe, effective and affordable medicines.
We recognize the need of implementing measures to improve access and availability of medicines. To achieve this, it is important to guarantee that factors affecting distribution and dispensing to patients are also covered, such as:
• Developing a fair framework for pharmaceuticals which puts guarantees for security and timeliness of medicines supply for patients at its core.
• Ensure equitable access to patients through a sustainable pharmaceutical chain (manufacturers, wholesalers and pharmacies), increasing transparency and predictability of medicines’ pricing systems by establishing fair and adequate criteria for prices and margins.
• Regulatory and financial incentives to promote access to generics and biosimilars.
• Expanding the role and resources of the European Medicines Agency (EMA) in the coordination of Member States activities on the prevention and management of shortages in close collaboration with the Heads of Medicines Agencies (HMA). At national level, national pharmacy organisations should be closely involved in strategies related to the monitoring, prevention and management of shortages. National systems already in place can provide valuable insights on the development of a European system, ensuring flexibility to adapt to national regulations and specificities of the national pharmaceutical chain, while allowing comparability of data at European level.
• Ensuring increased transparency and timely communication on shortages to affected stakeholders such as community pharmacists.
• Assuring effective compliance with EU and national laws related to the public service obligations of supply chain actors through further clarification of these obligations.
• Reducing pharmaceutical waste caused by leftover medicines by ensuring that systems are in place that encourage the correct use of medicines and therapeutic adherence by recognising and fairly remunerate community pharmacist’s intervention on these areas.
• Reduce the ecological footprint by allowing patients to have access to all their medicines, including specialty medicines, closer to their home by using the full potential of the community pharmacies network.
ANF is member of PGEU, the voice of community pharmacy in Europe. PGEU position in attachment.
Read full responseResponse to Pharmaceutical Strategy - Timely patient access to affordable medicines
7 Jul 2020
The National Association of Pharmacies (ANF), PGEU member, representing 95% of Portuguese Pharmacies, welcomes the roadmap on a Pharmaceutical Strategy for Europe aiming in building a holistic, patient-centred strategy covering the whole lifecycle of medicines.
Community pharmacies have an equitable distribution, promoting social and territorial cohesion, contributing to reduce inequalities on access, especially in more deprived or underserved areas. For these reasons, we believe that community pharmacy’s role in guaranteeing timely patient access to affordable medicines must be addressed in the Pharmaceutical Strategy for Europe.
1. Ensure greater access and availability of pharmaceuticals to patients
ANF’s recognises the need of implementing measures to improve access and availability of medicines. To achieve this, it is important to guarantee that factors affecting distribution and dispensing to patients are also covered, namely regulatory and financial incentives to the dispensing of generics and biosimilars.
We also support EC initiatives to address medicines shortages. Improving reporting, monitoring and communication on medicines shortages, recognising the added value of community pharmacy-based reporting tools already in place in some countries, such as Portugal, can better inform authorities, healthcare professionals and patients. The European Medicines Verification System is not an effective tool to monitor shortages since it does not give all the information that it is needed to assess if the supply meets the needs of the patients and the national markets. A more holistic and integrated systems are already in place in some countries.
2. Ensure affordability of medicines for patients and health systems financial and fiscal sustainability
ANF’s stresses the need to ensure equitable access to patients through a sustainable pharmaceutical chain (manufactures, wholesalers and pharmacies). Pharmacy’s margins should be aligned with medicines’ price regulations, establishing fair and adequate criteria to ensure equity of access and an adequate pharmaceutical coverage.
Additionally, pharmacies can play an important role on post-market evaluation of pharmaceuticals and pharmacovigilance. Pharmacies have the tools to collect and analyse real-world data and to collaborate in the production of real-world evidence in primary care, but also to monitor efficiency and budget impact of health technologies.
3. Enable innovation including for unmet medical needs in a way that harnesses the benefits of digital
Digitalisation can promote sustainability and efficiency of health systems, namely enhancing the communication and sharing of information between doctors and pharmacies to better follow-up patients’ treatments and using the installed capacity of pharmacies to provide remote consultations with GPs and other physicians, especially in remote or underserved areas. Pharmacy-based IT tools can better support patient care, increasing safety of dispensing, health literacy and reducing the pressure in other healthcare services.
Access and better patient care can be achieved implementing reconciliation and discharge services through integration of hospital and community pharmacy services, namely through the dispensing of certain hospital medicines through community pharmacies.
Correct use of medicines and adherence to treatment can be promoted through the implementation of patient medication reviews, new medicines services, dose dispensing services to individual patients and at care homes. Pharmacies can contribute to tackling AMR enhancing the adequacy of treatments through counselling, adherence and performing AMR rapid diagnostic tests
These initiatives can contribute to reduce the environmental footprint since it reduces patients’ traveling time and waste related to the use of medicines. Additionally, pharmacies are well placed to appropriately handle and dispose expired medicine.
Read full response