NHSE’s response to DCE on guidelines for OTC medicines

The Dermatology Council of England (DCE) wrote to NHS England (NHSE) to raise its concern over the implementation of NHSE guidance on restricting the prescriptions of over-the-counter (OTC) medicines. The DCE informed NHSE that it had collected evidence showing that a number of patients with chronic and/or severe inflammatory skin conditions have been incorrectly refused prescriptions of emollients because of the guidance. The DCE asked NHSE to consider clarifying and emphasizing the section on general exceptions so that there is not the unwarranted variation in the implementation of the guidance

See below the response to DCE from Dr Bruce Warner:
 
Dear Mr Holmes,
 
Thank you for your letter raising concerns over the implementation of NHS England & NHS Clinical Commissioners guidance for Clinical Commissioning Groups (CCGs) on Conditions for which over the counter items should not be routinely prescribed in primary care. Professor Stephen Powis has asked that I reply on his behalf as a joint chair of the clinical working group, responsible for the development of the CCG guidance.
 
I am sorry to hear that the Dermatology Council for England feels that the guidance is being misinterpreted by some CCGs and the impact this is appearing to have on people living with chronic and severe skin conditions. The clinical working group did not intend for this guidance to be used as a mechanism to initiate a blanket ban on emollients. If CCGs have implemented the guidance as intended, patients with chronic and severe skin conditions should still be able to receive their emollients on prescription as it is a chronic condition. The recommendation in this guidance only applies to those with mild dry skin.
 
As you may be aware, NHS England expects CCGs to take the guidance into account in formulating local polices, and for prescribers to reflect local policies in their prescribing practice. CCGs need to take decisions on implementation locally, ensuring they take into account their legal duties to advance equality and have regard to reducing health inequalities. The guidance does not remove the clinical discretion of the prescriber in accordance with their professional duties

NHS England is working closely with NHS Clinical Commissioners on implementation and is monitoring implementation of the guidance, including unintended consequences. As part of this ongoing review process the clinical working group will take account of your feedback and specific suggestion that we consider clarifying and emphasising the section on general exceptions.

Yours sincerely,

Dr. Bruce Warner                                                  
Deputy Chief Pharmaceutical Officer                             
NHS England & NHS Improvement