Pre-Budget Submission - Review of the Pharmacy Sector - Irish Pharmacy Union
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IRELAND’S OFFICIAL PHARMACY PUBLICATION SEPTEMBER 2019 HPV vaccination Review of the Pharmacy Sector Pre-Budget Submission IPU calls for action on FEMPI, new pharmacy contract and expansion of pharmacy services CPD: ROSACEA | CHILDHOOD IMMUNISATION | JIM POWER
SEPTEMBER 2019 22 07 A Note from the Editor IPU News The latest news and events from Butterfield House 8 Dates for your Diary 8 Pharmacy in the Media 10 IPU Business Briefings The IPU Review is published monthly and circulated to Irish 10 Pharmacists call for better access pharmacists. The views expressed to contraception by contributors are not those 12 Budget 2020 – IPU calls for funding to of the IPU nor is responsibility accepted for claims in articles increase pharmacy services or advertisements. 12 IPU Flu Vaccination Ad Campaign – 23 September Subscription: 14 Vaccination Awareness Campaign €100 (Ireland North & South) and 14 Launch of IPU Academy Autumn Programme €150 (including postage overseas). – 16 September 2019 Publisher: 16 Irish Pharmacy Union 15 Letter to the Editor (IPU Services Ltd), Butterfield House, Butterfield Avenue, Rathfarnham, Dublin 14, D14 E126 Tel: (01) 493 6401 Fax: (01) 493 6626 Email: ipureview@ipu.ie Website: www.ipu.ie Editor: Jack Shanahan MPSI Editorial Associates: Siobhán Kane, Ciara Browne and Jim Curran Advertising: Siobhán Kane Email: ipureview@ipu.ie Tel: (01) 493 6401 Features 16 IPU Pre-Budget ©2019 Copyright: All Rights Reserved, Irish Pharmacy Union. Printed by Ryson Colour Printers Ltd. IPU Review is a Registered Trademark Submission 2020 of the Irish Pharmacy Union. 20 HPV Vaccination – Get the Facts 22 Review of the Community Pharmacy Sector 2018 26 20 26 Childhood Immunisation IPUREVIEW SEPTEMBER 2019 3
The complete range of pain relief Paralief Range Pain Relief - Full prescribing information is available on request. For retail sale through pharmacies only. THE STATED DOSE SHOULD NOT BE EXCEEDED. Please refer to the individual product Summary of Product Characteristics. PA Holder: Clonmel Healthcare Ltd., Clonmel, County Tipperary: Paralief 500 mg Tablets - Contains paracetamol PA 126/20/1 (24 pack size) Paralief Cold+Flu Hard Capsules - Contains paracetamol, phenylephrine HCl and caffeine PA 126/272/1 Paralief Hot Lemon 600 mg Powder for Oral Solution in Sachet - Contains paracetamol PA 126/20/6 Paralief 500 mg Effervescent Tablets - Contains paracetamol PA 126/20/4 PA Holder: Chanelle Medical, Loughrea, County Galway: Paralief Night Film-coated Tablets - Contains paracetamol and diphenhydramine HCl PA 688/38/1 Paralief Extra Film-coated Tablets - Contains paracetamol and caffeine PA 688/50/1 For more information go to www.clonmel-health.ie. Date prepared: January 2019 2018/ADV/PAR/131H
53 40 31 CPD: Rosacea News 55 Updated Code of Conduct 34 Jim Power: international for pharmacists to be launched clouds gathering in September 55 World Pharmacists Day 38 Learnings from Fitness to Practise: – 25 September Part 2 56 Report on Living With and Beyond Cancer in Ireland launched 40 IPU Professional Department 57 Registration now open for – how can we help you? 9th All Ireland Pharmacy Conference 44 Pharmacy Posters and 57 Bridge weekend Promotional Materials 58 Irish Chemists’ Golfing 44 Society News 48 Clinical Tips: Asthma Update – Part 2 59 Classifieds 50 High Tech Medicines 51 Studies 52 Product Information 53 Pharmacy in the Community 54 International News 31 IPUREVIEW SEPTEMBER 2019 5
Challenging Times Ahead? Let Accord take care of you Richard Doherty Gregg Farrell Nicola Flynn David Lane John MacHale Damien McCormack Padraic O’Brien Liam Ryan Further information is available on request from Accord Healthcare Ireland Ltd Euro House I Euro Business Park I Little Island I Cork I T45 K857 I Ireland 021-461 9040 Date of Preparation: August 2019. Na-371-01-a
A NOTE FROM THE EDITOR Jack Shanahan MPSI The dysfunctional nature of PCRS communication The ink had barely dried on my last column when the PCRS hit a new chapter in bizarre behaviour. A rant about ‘owings’ and non-dispensing fees winged its way to all our letterboxes. To my mind, it exemplified all that can go wrong with a relationship. T he tone was day delivery of a professional limited income it can mean simple multi-item prescription aggressive, service. The fact that we the difference between could have hundreds or accusatory and owe a very small number a meal or a medicine. A even thousands of euro of the content was of medicines to patients at common conversation at medicines. If the pharmacy completely lopsided. any given time is completely the dispensary counter will holds the prescription, they The question arose as to why? normal. It is equally normal involve a patient deciding to could be hit by a substantial Why on earth did the PCRS that the patient collects these take part of their prescription. ingredient price drop in the send out such a missive when owed medicines. This is not They will then return on following month. The PCRS/ they knew that the issue it an attempt to defraud or payday to collect the balance. HSE has form in retrospective addressed was self-limited? otherwise game the system. Another common problem price cuts. Particularly galling was The most common reason derives from a ‘labour saving’ Fundamentally, any that the PCRS had agreed a for an owing is that the practice in surgeries. This commercial relationship is strategy, as well as a technical pharmacy simply does not arises where a patient gets based on trust. We see it with solution, with the IPU to have enough stock to cover an a prescription for an acute the Revenue Commissioners, resolve the owing concerns individual prescription item. item and the doctor decides to with self-assessment being that the PCRS expressed. In the era of drug shortages, add their regular prescription the norm. While verification Loans are complicated. Part this is a common problem. onto the form. While this may is a normal part of trust, of the reason is that they arise It can get complicated not be an issue, if we had threats and accusations are from multiple factors. They when the brand that the dispensed the regular items not. The dysfunctional nature are also a fact of life in every pharmacy dispensed becomes recently, it becomes one. Where of PCRS communication with community pharmacy in the unavailable. This could mean, the prescriber is reluctant to community pharmacy is a country. The root cause of our by way of example, that you reissue a prescription form, the barrier to good relations. problem stems from the PCRS dispense 14 tablets of brand x only realistic option is to put It is beyond time that the insistence that they will only valsartan 160mg. After a few the regular items as owed, and attitude changed. pay one dispensing fee for days of no valsartan 160mg of dispense them when they are a single line item. While we any variation, brand y arrives due. could argue the toss on the into stock. You then proceed There is, of course, an merits of this approach, the to dispense the 14 balance. inevitability that some owed real issue is that this generates Our systems should be able items are never collected. problems. The upshot is that, to record correctly what had This may be because the on a technical level, neither happened in this situation. medicine has changed, the our nor the PCRS’ IT systems The problem is, if we do that, patient’s circumstances deal with ‘owings’ very well. it will result in an extra claim. change or a host of other There is an implication in the While we can put a note reasons. As things stand, there letter that the very fact that a into a patient’s file, there is is no simple mechanism for pharmacy owes a medicine to no adequate mechanism for returning this to the PCRS. a patient is somehow suspect. correctly recording multiple The solution proposed This mindset is toxic, borne brand supply on a single by the PCRS, to hold owing of an adversarial approach PCRS claim. prescriptions until fully and a deliberate decision Another common reason for dispensed, is unworkable. to poison the atmosphere. an owing is the prescription Because of the deficiencies The typical pharmacist is levy, which is seen as a tax. in the claim process, it could struggling with the endless While €2 may not seem mean substantial losses to challenges posed by the day to much, for a person on a a pharmacy. For instance, a If you have any comments, queries or issues to raise, send your “Letters to the Editor” by email to ipureview@ipu.ie. IPUREVIEW SEPTEMBER 2019 7
Pharmacy in the Media We issued a press release in response to the recent public consultation on increasing access to contraception. In our release, we highlighted the IPU proposal for a scheme to allow women to access contraception directly from their community pharmacist without prescription and without charge. We received extensive media coverage with IPU Executive Committee member Caitriona O’Riordan being interviewed on Newstalk and across multiple regional radio stations. There was coverage in the Irish Examiner, The Times, the Irish Daily Mirror, the Irish Sun, the Irish Daily Star and regional newspapers, as well as in online media on BreakingNews.ie and Dates fioarry IrishHealth.com. Marie McConn was also interviewed on Limerick FM. We were mentioned on SHEmazing.net and your D TheJournal.ie in relation to VAT being removed from condoms. We issued a press release to call for funding to be made available in Budget 2020 to allow pharmacies ER 2019 SEPTEMB to expand the services they offer to patients. IPU ide member Kathy Maher was interviewed on Newstalk, orld Suic mber W Day, 10 Septe Pre v e n ti o n Today FM, FM104 and across a significant number of sp .i n fo/wspd regional radio stations. There was also coverage in the www.ia ngs, Irish Independent. ess Briefi IPU Busin We were also quoted in an article on TheJournal.ie 11 – 2 6 .ie er www.ipu in relation to the HSE. Septemb cademy S e p te m ber IPU A Programm e 16 Autumn launches, ie academy. www.ipu ay, eimer’s D b e r W orld Alzh ie m eimer. 21 Septe www.alzh n TV accinatio te m b e r IPU Flu V a m p a ign, 23 Sep dC & Radio A .ie www.ipu y, acists Da b e r W orld Pharm rld m o 25 Septe www.fip.o day rg/w a rm a c is ts ph ay, d Heart D S e p te m ber Worl h e a rt .ie 29 www.iri sh 2019 O C TO B E R s Month, a n c e r Awarenes Breast C cer.ie www.can ntal Healt h b e r World Me n ta l 10 O c to .m e Day, www land.ie healthire nal AGMs, IPU Regio 14 – 2 4 .ie www.ipu October 8 IPUREVIEW SEPTEMBER 2019
Contains nicotine “I quit smoking for her” Fergus O’Shea Help smokers quit with an unbeatable combination* from Patch + Mini IRE/NIQ/2019-001 FOR 24 HOUR CONTROL ON THE GO CRAVING RELIEF *Provides significant improvements in quit rates vs patch alone. Stead LF et al. 2012 Nicotine replacement therapy for smoking cessation, Cochrane Library. NiQuitin CLEAR 24 hrs transdermal patches are indicated for the relief of nicotine withdrawal symptoms including cravings as an aid to smoking cessation. Indicated in adults and adolescents aged 12 years and over. NiQuitin patches should be applied once a day, at the same time each day and preferably soon after waking and worn continuously for 24 hours. Apply a patch to non-hairy clean dry skin surface, a new skin site should be used every day. Therapy should usually begin with NiQuitin 21 mg/24 hrs and reduced according to the following dosing schedule: Step 1 NiQuitin Clear 21 mg/24 hrs transdermal patches first 6 weeks. Step 2 NiQuitin Clear 14 mg/24 hrs transdermal patches next 2 weeks. Step 3 NiQuitin Clear 7 mg/24 hrs transdermal patches last 2 weeks. Light smokers (e.g. those who smoke less than 10 cigarettes per day) are recommended to start at Step 2 (14 mg) for 6 weeks and decrease the dose to NiQuitin 7 mg/24 hrs for the final 2 weeks. Contraindications: Non-smokers, hypersensitivity, children under 12 years and occasional smokers. Precaution: Supervise use if hospitalised for MI, severe dysrhythmia or CVA, if haemodynamically unstable. Use with caution in patients with active oesophagitis, oral and pharyngeal inflammation, gastritis, peptic ulcers, GI disturbances, susceptible to angioedema, urticaria, renal/hepatic impairment, hyperthyroidism, diabeties, phaeochromocytoma, seizures & epilepsy. Discontinue if severe persistent skin rash. Pregnancy and lactation: Oral formats preferable to patches unless nauseous. Remove patches at bedtime. Side effects: Transient rash, itching, burning, tingling, numbness, swelling, localised pain urticaria, hypersensitivity reactions. headache, dizziness, tremor, sleep disorders, nervousness, palpitations, tachycardia, dyspnoea, pharyngitis, cough, nausea, vomiting dyspepsia, upper abdominal pain, diarrhoea, constipation, dry mouth, sweating, dermatitis, photosensitivity, arthralgia, myalgia, asthenia, malaise, influenza-type illness, fatigue, seizures and anaphylaxis. Legal classification: GSL: PA 1186/18/4, PA 1186/18/5 & PA 1186/18/6. MAH: Chefaro Ireland DAC, The Sharp Building, Hogan Place, Dublin 2, Ireland. http://www.medicines. ie/medicine/12136/SPC/NiQuitin+CLEAR+7+mg+24+hours++transdermal+patch/ http://www.medicines.ie/medicine/12137/SPC/NiQuitin+CLEAR+14+mg+24+hours+transdermal+patch/ http://www. medicines.ie/medicine/12138/SPC/NiQuitin+CLEAR+21+mg+24+hours+transdermal+patch/ NiQuitin Mini 1.5mg/4mg Mint Lozenges are used for the treatment of tobacco dependence by relief of nicotine withdrawal symptoms and cravings. Indicated in adults and adolescents aged 12 years and over. NiQuitin Mini 1.5 mg are suitable for those who smoke who smoke 20 cigarettes or less a day. NiQuitin Mini 4 mg are suitable for smokers who smoke more than 20 cigarettes a day. Place a lozenge in the mouth whenever there is an urge to smoke, allow to dissolve completely. Do not chew or swallow whole. Abrupt cessation: Use a lozenge whenever there is an urge to smoke, maximum of 15 lozenges a day. Continue for up to 6 weeks, then gradually reduce lozenge use. Gradual cessation: Use lozenges whenever there is an urge to smoke in order to reduce the number of cigarettes smoked for up to 6 weeks, followed by abrupt cessation. Adolescents (12-17 years): Only with advice from a healthcare professional. Contraindications: Hypersensitivity to nicotine or any of the excipients, children under the age of 12 years and non-smokers. Precaution: Supervised use in dependent smokers with a recent myocardial infarction, unstable or worsening angina pectoris including Prinzmetal’s angina, severe cardiac arrhythmias, uncontrolled hypertensions or recent cerebrovascular accident. Use with caution in those with; stable cardiovascular diseases, diabetes mellitus, susceptiblity to angioedema & urticaria renal/hepatic impairment, phaeochromocytoma & uncontrolled hyperthyroidism, GI disease & seizures. Side effects: Nausea, mouth/throat and tongue irritation, irritability, anxiety, sleep disorders, dizziness, headaches, cough, sore throat, dyspnoea, vomiting, diarrhoea, GI discomfort, flatulence, hiccups, heartburn, dyspepsia, nervousness, depression, palpitation, rash, angioedema, pruritus, erythema, hyperhidrosis, fatigue, malaise chest pain, anaphylactic reactions, hypersensitivity, tremor, dysgeusia, paresthesia mouth, seizures & epilepsy, dysphagia, eructation, salivary hypersecretion, pharyngitis. http://www.medicines.ie/medicine/14493/SPC/NiQuitin+Mini+1.5mg+mint+lozenges/#PRODUCTINFO http://www.medicines.ie/medicine/14492/SPC/NiQuitin+Mini+4mg+mint+lozenges/ Legal classification: GSL: PA 1186/18/11 & PA 1186/18/12. MAH: Chefaro Ireland DAC, The Sharp Building, Hogan Place, Dublin 2, Ireland.
IPU NEWS IPU Business Pharmacists call for better Briefings access to The IPU Business Department is holding a series of briefing sessions around the country, where expert speakers will provide you with an overview on how to use your pharmacy dispensary contraception data to save thousands of euro in income for your pharmacy, together with a presentation based on extensive research that identifies the key facets that drive and deter the appeal of In response to the recent public consultation working in community pharmacy at present and the issues that on increasing access to contraception, the pharmacy contractors need to be aware of when hiring and IPU has proposed a scheme by which women retaining pharmacists. could access contraception directly from their The briefing sessions have been designed to ensure that community pharmacist without prescription participants are provided with pertinent, practical information and without charge. Access to free contraception that is delivered in a no-nonsense, straight forward manner. was a recommendation made by the Oireachtas There will be time for Q&A and speakers will also be available to Committee on the Eighth Amendment. address any specific issues of concern. Irish pharmacists have been safely and appropriately providing emergency contraception without prescription since 2011, a service which has Speakers and Agenda been funded for medical card holders since 2017. By improving access to regular birth control, more (1) Maximise pharmacy revenue by using your dispensary women will use it, which should result in reduced data. How to save thousands of euro rates of unintended pregnancy. This session will provide a demonstration of how hmR’s Community pharmacist and IPU Executive Pharmacy Platform identifies opportunities within the Committee member Caitriona O’Riordan said: “We data and helps pharmacy owners unlock hidden profit know from HSE research that almost half of women potential including generic opportunities. would prefer to access contraception through their pharmacy. The oral contraceptive pill is one of Speakers: Michael Tierney, IPU PCC Committee Member, the safest and well-studied medicines available. and Alan McCormick, Senior Manager, Pharmacy Pharmacists would undergo appropriate training on Business Intelligence, hmR Ireland the selection and supply of the most appropriate contraception and therefore there is simply no (2) Perspectives on Community Pharmacy. Attracting clinical cause for concern.” and Retaining Pharmacists There is no clinical reason why oral contraceptives This session will evaluate the factors that are deterring should still require a prescription. Both the pharmacists from working in community pharmacy and American Academy of Family Physicians and the look at what can be done to address this issue. American College of Obstetricians and Gynecologists support access to contraception without Speaker: Larry Ryan, Director, Behaviour & Attitudes. prescription, which is becoming increasingly available from community pharmacists across the Date Location Time USA and Canada, and has been shown to improve 11 September Midlands Park Hotel, 7.30pm – 9.30pm access and reduce unintended pregnancies. Portlaoise Ms O’Riordan continued: “Providing convenient and affordable access to birth control should be 19 September Radisson Blu Hotel, 7.30pm – 9.30pm a public health priority. Even the World Health Letterkenny Organisation in its recent guidelines said that oral contraceptive pills should be made available 24 September Oriel House Hotel, 7.30pm – 9.30pm without a prescription. Providing women with this Ballincollig, Cork choice will make it easier and more convenient to 26 September Kingswood Hotel, 7.30pm – 9.30pm get contraception safely, meaning more women Citywest, Dublin will use it, which should result in reduced rates of unintended pregnancy.” Contact Darren.kelly@ipu.ie or jim.curran@ipu.ie to register your interest in attending. 10 IPUREVIEW SEPTEMBER 2019
We’re making it even easier to find unlicensed medicines. They’re now just a click away. shop.medisource.ie Medisource is delighted to introduce our new online ordering system for exempt medicinal products. Pharmacists can register for online access at shop.medisource.ie ■ Real-time stock information ■ Easy search filter ■ Tracking of online order history ■ Fast re-order option ■ Relevant product details e.g. HSE code, Fridge item, Foreign pack ■ No fax requirement The first dedicated and No. 1 supplier of unlicensed or difficult to get medicines in Ireland. Medisource is Irish-owned and has a team of pharmacist-led experts to deal with your enquiries. www.medisource.ie | Call 1890 2866366 | Fax 01 2866288 | Email info@medisource.ie
IPU NEWS Budget 2020 – IPU calls for funding to increase pharmacy services The IPU is calling for funding to be made available in Budget 2020 to allow pharmacies expand the services they offer to IPU Flu patients, including the introduction of: n A Minor Ailment Scheme; Vaccination Ad n A New Medicine Service, which will help drive prescription adherence; n A Chronic Disease Management Service; and n Improving Access to Contraception for women. Research has indicated that 18% of a GP’s workload is spent Campaign – 23 September on minor ailments and that the timely delivery of the Minor Ailment Scheme could save nearly one million GP consultations every year. A successful pilot of a Minor Ailment scheme was conducted in 2016, but the HSE has yet to make any decisions on a wider implementation programme. Kathy Maher, IPU spokesperson and community pharmacist, We are launching a Flu Vaccination campaign at the end of said: “Community pharmacy is the most accessed part of the month to urge members of the public to take the best Ireland’s health system, with nearly 78 million visits to a course of action to prevent getting the flu – by getting the pharmacy every year. The spirit of the Sláintecare plan is flu vaccination. The ads centre on the image of the local for care to be provided at the lowest level of complexity. pharmacy being an important part of the community, Pharmacies open long hours and over weekends and can be and that patients should feel very comfortable going to attended without appointment – that is why, for a range of their pharmacy for their vaccination. services, community pharmacies are the logical providers of The campaign will take place over two weeks from care. Pharmacists can bring added value to both the patient and 23 September – 6 October, with a TV ad airing across all the HSE. As demand for healthcare continues to increase, the Irish national TV channels, Channel 4 and Sky channels, State cannot rely on traditional models of care and it must be and a Radio ad airing on Today FM and regional stations. recognised that pharmacists are part of the solution.” We want you to get involved in this campaign to The Programme for Government gave a clear commitment further push our message of Need a Flu Vaccination – to expand pharmacy services within two years. Ms Maher said Think Pharmacy using your social media channels. A that while that hasn’t happened, “we are still optimistic that the media kit will be available to members on www.ipu.ie > Government will see the opportunities that exist and implement Communications > Ad Campaign > Flu Vaccination prior changes. However, our members now need to see flesh on the to the campaign, where you will find tweets and posts, as bones of these commitments, and Budget 2020 provides an well as images from the campaign and links to the ads. opportunity to ring-fence funding to deliver on Government objectives.” Ms Maher concluded: “It is incumbent on decision-makers to deliver a health system fit for purpose. As matters stand, we are currently lagging behind international best practice in circumstances where the UK, Canada and New Zealand lead the charge in the provision of expanded patient services. Budget 2020 provides an opportunity to change this and if this happens it could very well be the foundation stone for health service improvements.” 12 IPUREVIEW SEPTEMBER 2019
Olmesartan Medoxomil ® Olmesartan Medoxomil/HCTZ PLUS 20/12.5 mg, 20/25 mg & 40/12.5 mg, 40/25 mg ® Powerful Blood Pressure Reduction 1-3 Omesar’s proven efficacy and flexible dosing as affordable as ever 3,4 Omesar 10, 20, 40 mg film-coated tablets (olmesartan medoxomil). Prescribing information Please consult levels is recommended in patients with mild to moderate renal impairment. Combined use of ACE-inhibitors, function closely. Do not use in patients with moderate and severe hepatic impairment, cholestasis or biliary the Summary of Product Characteristics (SPC) for full prescribing information. Presentation: Film-coated tablets angiotensin II receptor blockers or aliskiren is not recommended. If considered absolutely necessary, use under obstruction. No data available on use in children and adolescents below 18 years. Contra-indications: containing 10 mg, 20 mg, 40 mg olmesartan medoxomil. Contains lactose monohydrate. Uses: Treatment of specialist supervision with frequent close monitoring of renal function, electrolytes and blood pressure. Do not use Hypersensitivity to the active substance or any of the excipients. Renal impairment. Refractory hypokalaemia, essential hypertension in adults. Treatment of hypertension in children and adolescents from 6 to less than 18 years concomitantly in patients with diabetic nephropathy. Care in mild to moderate hepatic impairment. Aortic or mitral hypercalcaemia, hyponatraemia and symptomatic hyperuricaemia. Moderate and severe hepatic impairment, of age. Dosage: Oral administration. Adults (18-65 years): Recommended starting dose 10 mg daily. If required valve stenosis, or obstructive hypertrophic cardiomyopathy. Not recommended in patients with primary cholestasis and biliary obstructive disorders. Second or third trimester of pregnancy. Concomitant use with aliskiren- the dose may be increased to 20 mg daily. Maximum daily dose is 40 mg. Elderly (65 years or over): No dose aldosteronism. Metabolic and endocrine effects (eg in diabetic patients). Fluid or electrolyte imbalance. Monitoring containing products in patients with diabetes mellitus or renal impairment. Warnings and precautions: adjustment generally required. If up-titration to maximum dosage required, monitor blood pressure closely. Patients of serum potassium in patients at risk of hyperkalaemia is recommended. Not recommended with lithium. Sprue- Symptomatic hypotension in patients who are volume and/or sodium depleted. Correct intravascular volume with renal and moderate hepatic impairment: Maximum daily dose is 20 mg. Not recommended in patients with like enteropathy reported in very rare cases, in absence of other etiologies immediately discontinue treatment. depletion before administering. Other conditions associated with stimulation of renin-angiotensin-aldosterone severe hepatic impairment. Children and adolescents aged 6 to less than 18 years: As for adults. Daily dose should Hydrochlorothiazide may cause acute myopia and secondary angle-closure glaucoma, if occurs discontinue system. Renovascular hypertension. Not recommended in all stages of renal impairment. No experience in patients not exceed 20 mg in children < 35 kg. Safety and efficacy not established in children aged 1 to 5 years. Not hydrochlorothiazide treatment as rapidly as possible. The blood pressure lowering effect of olmesartan medoxomil with a recent kidney transplant. Combined use of ACE-inhibitors, angiotensin II receptor blockers or aliskiren is not recommended for children under 1 year of age. Contra-indications: Hypersensitivity to any component. Second or is somewhat less in black patients than non-black patients. May cause a positive result in an anti-doping test. As recommended. If considered absolutely necessary, use under specialist supervision with frequent close monitoring third trimesters of pregnancy. Patients with biliary obstruction. Concomitant use with aliskiren-containing products with any antihypertensive agent, excessive blood pressure decrease in patients with ischaemic heart disease or of renal function, electrolytes and blood pressure. Do not use concomitantly in patients with diabetic nephropathy. in patients with diabetes mellitus or renal impairment. Warnings and Precautions: Correct intravascular volume ischaemic cerebrovascular disease could result in a myocardial infarction or stroke. Contains lactose. Not Contra-indicated in moderate and severe hepatic impairment, cholestasis and biliary obstruction. Care in mild depletion before administering olmesartan medoxomil. In patients with other conditions associated with stimulation recommended with medicinal products affecting potassium levels. Do not initiate during pregnancy and change to hepatic impairment. Special caution with aortic or mitral valve stenosis, or obstructive hypertrophic cardiomyopathy. of renin-angiotensin-aldosterone system, possible side effects include acute hypotension, azotaemia, oliguria or, alternative therapy, if appropriate, if pregnancy is planned or occurs during therapy. Pregnancy and lactation: Do Not recommended in patients with primary aldosteronism. May cause hyperglycaemia, raised triglyceride and rarely, acute renal failure. Increased risk of severe hypotension and renal insufficiency in patients with bilateral renal not use in the first trimester and discontinue as soon as possible if pregnancy occurs during therapy. Contraindicated cholesterol levels and hyperuricaemia. Periodic determination of serum electrolytes should be performed at regular artery stenosis or stenosis of the artery to a single functioning kidney. Periodic monitoring of serum and potassium in second and third trimester of pregnancy. Not recommended during lactation, change to alternative therapy, if intervals. Not recommended with lithium. Sprue-like enteropathy reported in very rare cases, in absence of other levels is recommended in patients with impaired renal function and kidney transplantation. Not recommended in appropriate. Interactions: Not recommended for concomitant use with ACE-inhibitors, angiotensin II receptor etiologies immediately discontinue treatment. Hydrochlorothiazide may cause acute myopia and secondary angle- patients with severe renal impairment or with severe hepatic impairment. Hyperkalaemia (which may be fatal), risk blockers, aliskiren, lithium, drugs affecting potassium levels. The blood pressure lowering effect of olmesartan closure glaucoma, if occurs discontinue hydrochlorothiazide treatment as rapidly as possible. The blood pressure factors include diabetes, renal impairment, age (> 70 years), combination with medicines which increase potassium medoxomil can be increased by concomitant use with other antihypertensive medications. Risk of acute renal failure lowering effect of olmesartan medoxomil is somewhat less in black patients than non-black patients. May cause a levels, potassium supplements, intercurrent events. Close monitoring of serum potassium in at risk patients is with concomitant use of NSAID’s and angiotensin receptor II antagonists. Monitoring of renal function and regular positive result in an anti-doping test. Do not initiate during pregnancy and change to alternative therapy, if recommended. Combined use of ACE-inhibitors, angiotensin II receptor blockers or aliskiren is not recommended. hydration of the patient is recommended. Use with NSAID’s can reduce the effect of olmesartan medoxomil. appropriate, if pregnancy is planned or occurs during therapy. As with any antihypertensive agent, excessive blood If considered absolutely necessary, use under specialist supervision with frequent close monitoring of renal Coadministration of warfarin and digoxin had no significant effect on the pharmacokinetics of olmesartan, warfarin pressure decrease in patients with ischaemic heart disease or ischaemic cerebrovascular disease could result in a function, electrolytes and blood pressure. Do not use concomitantly in patients with diabetic nephropathy. Not or digoxin. No clinically relevant interactions between olmesartan and drugs metabolised by cytochrome P450 myocardial infarction or stroke. Hypersensitivity reactions to hydrochlorothiazide. Exacerbation or activation of recommended for combination use with lithium. Special caution is recommended in patients suffering from aortic enzymes 1A1/2, 2A6, 2C8/9, 2C19, 2D6 and 3A4 are expected. Caution if used concomitantly with baclofen, calcium systemic lupus erythematosus. Contains lactose. Interactions: Not recommended for concomitant use with ACE- or mitral valve stenosis, or obstructive hypertrophic cardiomyopathy. Not recommended in patients with primary salts, cholestyramine and colestipol resins, digitalis glycosides, medicinal products affected by serum potassium inhibitors, angiotensin II receptor blockers, aliskiren, lithium, drugs affecting potassium levels. The blood pressure aldosteronism. Sprue-like enteropathy reported in very rare cases, in absence of other etiologies immediately disturbances non-depolarizing skeletal muscle relaxants (eg tubocurarine), anticholinergic agents (eg atropine, lowering effect of olmesartan medoxomil can be increased by concomitant use with other antihypertensive discontinue treatment. The blood pressure lowering effect of olmesartan medoxomil is somewhat less in black biperiden), antidiabetic medicinal products (oral agents and insulin), metformin, beta-blockers and diazoxid, pressor medications. Risk of acute renal failure with concomitant use of NSAID’s and angiotensin II receptor antagonists. patients than non-black patients. Do not initiate during pregnancy and change to alternative therapy, if appropriate, if amines (eg noradrenaline), medicinal products used in the treatment of gout (probenecid, sulfinpyrazone and Monitoring of renal function and regular hydration of the patient is recommended. Use with NSAID’s can reduce the pregnancy is planned or occurs during therapy. Excessive blood pressure decrease in patients with ischaemic heart allopurinol), amantadine, cytotoxic agents (eg cyclophosphamide, methotrexate), salicylates, methyldopa, effect of olmesartan medoxomil. Coadministration of warfarin and digoxin had no significant effect on the disease or ischaemic cerebrovascular disease could result in a myocardial infarction or stroke. Contains lactose. cyclosporine, tetracyclines. Concomitant use to be taken into account with amifostine, alcohol, barbiturates, pharmacokinetics of warfarin or digoxin. No clinically relevant interactions between olmesartan and drugs Interactions: Not recommended for concomitant use with ACE-inhibitors, angiotensin II receptor blockers, aliskiren, narcotics or antidepressants. Consider administration at least 4 hours before colesevelam dose to decrease metabolised by cytochrome P450 enzymes 1A1/2, 2A6, 2C8/9, 2C19, 2D6 and 3A4 are expected. Caution if used drugs affecting potassium levels, lithium. The blood pressure lowering effect of olmesartan medoxomil can be interaction effect. For further information see SmPC. Side effects: Fixed dose combination: Common: dizziness/ concomitantly with baclofen, calcium salts, cholestyramine and colestipol resins, digitalis glycosides, medicinal increased by concomitant use with other antihypertensive medications. Risk of acute renal failure with concomitant light-headedness, headache, fatigue, asthenia, peripheral oedema, chest pain. Uncommon: hyperuricaemia, products affected by serum potassium disturbances, non-depolarizing skeletal muscle relaxants (e.g. tubocurarine), use of NSAID’s and angiotensin II antagonists. Monitoring of renal function and regular hydration of the patient is hypertriglyceridaemia, hypercholesterolaemia, syncope, postural dizziness, somnolence, palpitations, vertigo, anticholinergic agents (e.g. atropine, biperiden), antidiabetic medicinal products (oral agents and insulin), metformin, recommended. Use with NSAID’s can reduce the effect of olmesartan medoxomil. Coadministration of warfarin hypotension, orthostatic hypotension, cough, diarrhoea, nausea, vomiting, dyspepsia, abdominal pain, rash, eczema, beta-blockers and diazoxide, pressor amines (e.g. noradrenaline), medicinal products used in the treatment of gout and digoxin had no significant effect on the pharmacokinetics of olmesartan, warfarin or digoxin. No clinically myalgia, muscle spasm, back pain, arthralgia, pain in extremity, haematuria, erectile dysfunction, weakness, blood (probenecid, sulfinpyrazone and allopurinol), amantadine, cytotoxic agents (e.g. cyclophosphamide, methotrexate), relevant interactions between olmesartan and drugs metabolised by cytochrome P450 enzymes 1A1/2, 2A6, 2C8/9, potassium decreased, blood potassium increased, blood calcium increased, blood urea increased, blood lipids salicylates, methyldopa, cyclosporine, tetracyclines. Concomitant use to be taken into account with amifostine, 2C19, 2D6 and 3A4 are expected. Consider administration at least 4 hours before colesevelam dose to decrease increased, blood creatinine increased, blood glucose increased, gamma glutamyl transferase increased, alanine alcohol, barbiturates, narcotics or antidepressants. Consider administration at least 4 hours before colesevelam dose interaction effect. Interaction studies only performed in adults. Not known if interactions in children are similar. aminotransferase increased, aspartate aminotransferase increased. For side effects which are rare or whose to decrease interaction effect. For further information see SmPC. Pregnancy and lactation: Do not use in the first Pregnancy and lactation: Do not use in the first trimester and discontinue as soon as possible if pregnancy occurs frequency is unknown see SmPC. Olmesartan: Common: hypertriglyceridaemia, hyperuricaemia, dizziness/light- trimester and discontinue as soon as possible if pregnancy occurs during therapy. Contraindicated in second and during therapy. Contraindicated in second and third trimester of pregnancy. Not recommended during lactation, headedness, headache, increased blood creatine phosphokinase, bronchitis, cough, pharyngitis, rhinitis, abdominal third trimester of pregnancy. Not recommended during lactation, change to alternative therapy, if appropriate. Side change to alternative therapy, if appropriate. Side Effects: Common (≥1/100 to
IPU NEWS Launch of IPU Academy Autumn Programme – 16 September 2019 The IPU Academy Autumn Programme 2019 is now online at www.ipuacademy.ie. This means that you can now view the IPU Academy Autumn Programme Vaccination 2019 and book your courses online. The five topics in the IPU Academy Autumn Programme were selected based on your feedback and will be delivered in venues countrywide. Awareness View the IPU Academy Autumn Programme and book your courses in 3 easy steps: 1. Log on to www.ipuacademy.ie 2. Enter your log-in details Campaign 3. Book your courses: • Epilepsy; • Hypertension; • Vaccines: adolescent and adult; • Women’s Health: Menopause and Overactive Bladder; and We are running a four-week Vaccination Awareness • Acne (Express Topic). Campaign across social media focusing on a different vaccination each week. Our campaign started on 27 The IPU Academy Autumn Programme will start August with a week of promoting HPV vaccination on Monday 16 September and run until Wednesday awareness. Our upcoming campaigns are: 13 November. As a member of the IPU, you are n 9 September: Children’s Vaccinations; automatically a member of IPU Academy. This membership benefit entitles you to attend, without n 23 September: Flu Vaccination; and charge, live learning events in the IPU Autumn n 7 October: Pneumococcal Vaccination. Academy Programme. The purpose of the campaign is to create public awareness that vaccinations are life-saving and if they have concerns or simply just want advice on these vaccinations, they can ask their pharmacist. We will have a media kit available on our website for each week of the campaign, which will include images and tweets/posts for your social media channels. The success of this Vaccination Awareness Campaign requires active support from IPU members; this will encourage more people to visit their local pharmacy and it will also reinforce our message that the pharmacy is the most accessible place for the public to visit to discuss their healthcare concerns. Keep an eye out for your weekly eNewsletter for more details on the campaign and the launch dates. 14 IPUREVIEW SEPTEMBER 2019
LETTER TO THE EDITOR Dear Editor, The ‘Cloth Cap’ has been a meltdown. A blurring of the pharmacists, as well as more editorials, there is no sense of long-time symbol of trade lines between pharmacist time explaining its nuances a Union exasperated. There union activism. Its image renumeration and drug costs, to patients. The memos is no sense of a profession embraces the progress of has become a millstone from the PCRS now appear that has endured promises worker’s rights, and the bond around our neck - a situation to have a weekly presence that never materialise. There between workers and their that suits the HSE narrative. in our post bag. These must is no sense of low morale, unions. While renumeration has be read to keep abreast of everything appears mildly The IPU never embraced diminished, services are the latest insights from the upbeat. There are plenty of the Cloth Cap image, as to still being delivered to the PCRS, otherwise? Then, more interesting articles, but as a be honest were too ‘posh’. same high standard. But heralded than the second barometer of where pharmacy In reality there was never our workload has also coming, there is FMD - more is, it is far too prosaic. the need for such a visceral expanded: vaccination, phased work but no renumeration. The Review has been cruelly approach. The 1990s were a dispensing and a deluge Pharmacy is working, it is an called a pharmaceutical time of progress in terms of of memos and paperwork. efficient and effective provider Hello magazine, a magazine pharmacy role in primary Vaccination many would say, within the primary care that is fearful of being edgy care: licencing, a new is a commercially unviable system. But with no rollback and confrontational, lest contract and new scheme. service, yet it significantly of the FEMPI cuts in sight, one someone gets upset. It is time Forward thinking civil contributes to the health of would expect a simmering to upset someone, it is time servants, prompted by the the population. The actual sense of discontent to prevail to get off our knees and stop IPU, saw a means to create a process of dispensing has also among our brethren. In truth, apologising for who we are more efficient and effective become more challenging, a fatalistic acceptance of our and what we do. delivery of services through as polypharmacy becomes situation seems to be the The Cloth Cap needs to be community pharmacy. more the norm, rather than mood music. donned. All this progress perished the exception. Needless to say, This sense of acceptance at the altar of ‘light the emergence of reference becomes tangible when Richie Collis MPSI touch regulation’ and pricing has created more you read the IPU Review. the subsequent financial administrative issues for Apart from Jack Shanahan’s See those lighting bills fall With a full lighting upgrade from Energia Lighting Solutions your business could reduce its lighting costs by up to 80%. It means savings for you and a brighter environment for all. To learn more see energia.ie/business Terms and conditions apply. IPUREVIEW SEPTEMBER 2019 15
BUSINESS Jim Curran, Director of Communications and Strategy, IPU IPU Pre-Budget Submission 2020 In this article, Jim Curran, IPU Director of Communications and Strategy, provides a summary of the key issues addressed in the IPU’s Pre-Budget 2020 submission, which was presented to the Minister for Finance, the Minister for Health and the Minster for Jobs, Enterprise and Innovation recently. Unwinding of FEMPI It is now 10 years since billion. This comprises €603 the average fee payments to Advisory has calculated that the Financial Emergency million in cuts to dispensing each pharmacy have fallen by this year’s implementation Measures in the Public fees and mark-ups (see Table nearly 18%. of the Falsified Medicines Interest (FEMPI) Act was 1), and €939 million (Table Despite these substantial Directive will, on its own, cost used to cut payment rates 2) in cuts to the wholesale cuts, community pharmacists the pharmacy sector €25.7 to pharmacists. Since then, margin/ingredient cost. have played their part in million. the State through FEMPI and HSE PCRS statistics for helping to build a health The cost of the restoration other measures has extracted 2009 to 2017 (2018 not yet service for the future, taking of public pay under the Public over €3.8 billion from the published) show that the cost on additional costs in areas Service Pay and Pension Act community pharmacy sector of medicines to the State has like changing IT systems and 2017 was €844 million up to through reduced medicine reduced by 37%. There has training staff in cooperating September 2018. The new reimbursements, and cuts to been a 17% decrease in the fee with State schemes, including three-year agreement, which pharmacy fees and margins. per item paid to pharmacies, the promotion of generic is currently set to run from The cuts through FEMPI and pharmacy output and medicines, among other January 2018 until December measures alone come to €1.54 efficiency have increased as initiatives. EY-DKM Economic 2020, will cost a further €887 16 IPUREVIEW SEPTEMBER 2019
Table 1: Reductions in fees and mark-ups paid to pharmacists by the State Year Pharmacy fees No. of items Mark-up & fees Reduction per item State & mark-ups dispensed under per item since 2009 savings State schemes 2018* (estimate) – 76,244,205 €5.25 €0.96 €73,194,436 2017 €397,910,000 75,763,097 €5.25 €0.96 €72,732,573 2016 €397,440,000 75,175,841 €5.29 €0.92 €69,136,626 2015 €389,740,000 73,542,223 €5.30 €0.91 €66,697,624 2014 €381,070,000 72,715,536 €5.24 €0.97 €70,236,816 2013 €393,930,000 74,378,504 €5.30 €0.91 €67,697,977 2012 €403,860,000 75,724,736 €5.33 €0.88 €66,123,326 2011 €386,630,000 72,023,261 €5.37 €0.84 €60,380,232 2010 €372,990,000 69,251,377 €5.39 €0.82 €56,816,616 2009 €420,960,000 67,825,991 €6.21 – – TOTAL – – – – €603,016,226 Source PCRS Annual Reports 2009 – 2017, PCRS Data and Fitzgerald Power Table 2: Reductions in medicine reimbursements paid to pharmacists by the State Year PCRS payments Items dispensed Cost Reduction FEMPI State for medicines under State per item per item reductions savings schemes since 2009 2018* (estimate) – 75,602,552 €12.08 €6.80 €82,250,000 €514,055,157 2017 €915,240,000 75,763,097 €12.08 €6.80 €81,753,464 €515,055,157 2016 €945,900,000 74,494,210 €12.70 €6.18 €84,492,157 €460,509,104 2015 €956,750,000 72,911,181 €13.12 €5.76 €85,461,329 €419,772,401 2014 €979,010,000 72,132,792 €13.57 €5.31 €87,449,695 €382,816,851 2013 €1,053,290,000 73,823,818 €14.27 €4.61 €94,084,728 €340,462,478 2012 €1,161,460,000 75,202,381 €15.44 €3.43 €103,746,972 €258,318,978 2011 €1,114,610,000 71,590,122 €15.57 €3.31 €99,562,113 €236,971,544 2010 €1,191,880,000 68,860539 €17.31 €1.57 €106,464,227 €108,168,541 2009 €1,273,770,000 67,468626 €18.88 – €113,779,020 – TOTAL – – – – 939,043,705 €3,236,577,248 Source: PCRS Data and Fitzgerald Power million. By 2020, more than The agreement (not yet is set at an uneconomic level set out below. Payment of fees 90% of public servants will be published), also reportedly for the service provided, given at this level, index-linked to completely out of the FEMPI restores funding cuts from the time taken by a qualified the present day and into the pay provisions. general practice during the professional to deliver the future, is now imperative for a In April of this year, the economic crisis. service, with the associated sustainable pharmacy service Irish Medical Organisation Pharmacies have delivered regulatory obligations and across the country. announced that the excellent value for money to reporting requirements. Government must now Government agreed to a €210 the State in the face of massive The report of the immediately commence million investment in general cuts to fees. An analysis Independent Body on the unwinding of FEMPI practice, along with a further by accountants Smith & Pharmacy Contract Pricing measures which were €80 million investment for Williamson in December 2017 (the Dorgan Report), previously applied to community chronic disease management. concluded that the current fee recommended a tiered fee, as pharmacy contractors, with IPUREVIEW SEPTEMBER 2019 17
Table 3: Recommendations on fees by the Independent the Pharmaceutical Society of been created by expanding Body on Pharmacy Contract Pricing Ireland. the range of services available There are also no provisions from pharmacists. in relation to funding or Number of items dispensed per Fee per Fee indexed updating IT infrastructure to In Canada and the UK, annum item to End 2018 create efficiencies and cost for example, pharmacies savings within the system, provide additional services despite the need to do so. such as prescribing for minor Up to 20,000 items €7.00 €7.44 In 2011, the then Minister ailments, supporting better agreed with the IPU that it adherence to and use of 20,001 to 30,000 items €6.50 €6.91 was time for a new pharmacy medicines through the New Over 30,000 items €6.00 €6.38 contract to be negotiated Medicine Service, extended in parallel with a new GP vaccination services and contract. The Department chronic disease management, of Health has recently all of which are shown to the implementation of the of reimbursement for concluded negotiations with deliver significant benefits to recommendations of the medications dispensed under GP representative bodies on a both patients and the State State-commissioned Dorgan the GMS and Community new contract for GPs. A new and to take pressure off Report. Drugs Schemes is governed pharmacy contract is equally other parts of the healthcare by the 1996 contract. These necessary: one that is fit for system, including GPs and schemes have developed and purpose and which reflects the hospitals. The IPU therefore New pharmacy contract evolved over the years with needs of the patients and the calls for the following: changing administrative and The current Community practice of pharmacy in the n Immediately develop bureaucratic requirements. Pharmacy Contractors’ 21st century. and roll-out a national Pharmacists can also Agreement is now 23 years The Dorgan Report, Community Pharmacy- offer a wide range of new old, having been negotiated previously quoted, notes based Triage Programme, services to both public and and agreed in 1996. At the “our strong view that a new including a Minor private patients, relieving time, it was a modernising contract is required urgently Ailment Scheme, pressures in other areas of contract and positioned and that the parties should Emergency Medicines the health service which were pharmacy services well for move to achieve that”. That and Minor Injuries. not envisioned in the 1996 many years. However, the was 11 years ago in June 2008, This would provide contract. Developments in contract is now in urgent and still no negotiations have immediate enhancement information technology have need of review. It predates the taken place. of health service long since surpassed what Pharmacy Act 2007 by more capacity, allow for more was planned in 1996. The than a decade and does not efficient use of resources, existing contract does not accurately reflect the legal or accurately reflect the legal or Expanding the Scope of and improve ease of access for patients; regulatory framework within regulatory framework within Pharmacy Services which pharmacies operate which pharmacies operate n Allow community today. In other countries where today. Various clauses within pharmacists to improve The relationship between access to primary care is the contract are out of date, patient outcomes the HSE and the community limited due to a shortage of with many of the functions by undertaking pharmacy sector in respect GPs, additional capacity has outlined now carried out by “Government must now immediately commence the unwinding of FEMPI measures which were applied to community pharmacy contractors, with the implementation of the recommendations of the State- commissioned Dorgan Report.” 18 IPUREVIEW SEPTEMBER 2019
Table 4: Examples of community pharmacy services in other countries New Canada Australia Netherlands UK Ireland Zealand Health Monitoring and Awareness New Medicine Services Minor Aliment Scheme Chronic Disease Management INR Testing patient-facing clinical n Extend the scope of Conclusion community pharmacies need medication reviews pharmacy practice to to be adequately resourced to and improving the include Chronic Disease Given the very high level ensure that they can provide management of long- Management services. of interaction between the continuum of care which term conditions with Analysis commissioned the general public and is urgently required in our the introduction of by the IPU indicated that, pharmacists every day in communities, and which pharmacy-based in Ireland, approximately every city, town and village in patients are demanding. services, including 71,600 cardiovascular Ireland, local pharmacists are It is clear that the State Medicine Use Reviews events could be avoided in a unique position to expand urgently needs to invest in and a New Medicine through enabling their role as healthcare enhanced pharmacy-based Service, both of which community pharmacists providers for the benefit of services which, internationally are established NHS to practice to full scope, both patients and the State. and domestically, have pharmacy services in delivering an estimated With an ever-increasing demonstrated real benefits in the UK, which improve saving of €1.36 billion demand for healthcare as our terms of patient outcomes, adherence; over 30 years; growing population continues reduced total care costs to age, and with the ongoing and, crucially, the additional n Allow women to access n Introduce a community constraints on the resources capacity which can be contraception directly pharmacy-based available to deliver healthcare, released in more complex from their community smoking cessation we simply do not have the healthcare settings such pharmacist without service to allow public option of doing nothing. as General Practice and prescription and, subject patients to access There is an urgent need for a Emergency Departments. to Government policy, nicotine replacement fundamental shift in health The Irish Pharmacy without charge; therapy and smoking policy and the immediate Union and the pharmacy cessation counselling implementation of change. n Expand the range profession want to contribute from their community The time is right to optimise of vaccinations that to better health outcomes pharmacy; and the delivery of primary care pharmacists can provide, for Irish patients and their identifying those n Legislate for the by providing appropriate, communities. If allowed and within the National introduction of a convenient, accessible and properly resourced to do so, Immunisation Advisory comprehensive cost-effective healthcare pharmacists in Ireland are Committee (NIAC) Biosimilar Medicines through pharmacies in ready, willing and able to guidelines that are suited Policy, which communities throughout the help alleviate pressure on the to pharmacy provision, independent analysis country. health system and to deliver with State funding shows could lead to If enabled, pharmacists the sort of health service that for administering all savings of €370 million can deliver far more services the Irish public needs and reimbursable vaccines; over a three-year period. than are currently delivered; deserves. Now is the time to patients, the public and the allow them to do so. health service all benefit. However, this cannot be done in isolation. In order to A copy of the full submission is provide these key services, our available at www.ipu.ie. IPUREVIEW SEPTEMBER 2019 19
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