Equality Act – reasonable adjustment – things to consider

Community Monitored Dosage System Suitability Assessment – template assessment tool for local adaption by pharmacy teams (this is in the process of being reviewed and updated)

The ICB has put together some information for patients and carers for those who are struggling to remember to take your medicines or having difficulty getting medication out of the packaging. This is of course also useful for healthcare professionals too especially as there may be options that people are not aware of and you may wish to share this material with your local GP practices.

Managing Your Medicines Leaflet

This information can be found on the ICB website here Managing your medicines – NHS Nottingham and Nottinghamshire ICB

Recommendations to support review of Dossetts

That there is patient assessment to identify the most appropriate intervention to help people use their medicines effectively and safely
Existing patients should not be stopped without warning
That original packs of medicines are preferred in the absence of specific need for an MCA
That carers have appropriate training to administer medicines from original packaging
Best practice is followed where an MCA is assessed as the most appropriate intervention for a patient
That policies and processes are reviewed or created that ensure they are patient-centred
Are the risks associated with dossett trays eg: risk of no available PIL, risk for incorrect filling outweighed by the benefit to the patient?
Has a review of ongoing need been performed in the last 12 months?
Is the patient stable? Dossett trays should not be amended but where changes are required recalled, and re-issued with full new prescription for all items. Patients where changes are occurring are unlikely to be suitable for MDS or will require weekly prescriptions

Dossetts are to assist the patient, not to assist 3^rd parties and it is prudent to review dossett provision where it is not the patient who is the primary beneficiary of the tray

Further context and information:

MDS supply is not recommended as best practice by the Royal Pharmaceutical Society (RPS) and other organisations and different pharmacies will decide when it is best utilised, if at all. The current RPS Guidance is that the use of original packs, supported by appropriate pharmaceutical care is the gold standard for medicines supply. Pharmacies may consider supporting this with charts and reminders, which can help carers and patients to administer medicines from their original packs. It is also not an element of the pharmacy contract and no funding is explicitly supplied for the provision of monitored dosage systems and therefore pharmacies have no obligation to provide this to anyone.

The Equality Act 2010, the requirement has always been to ”make reasonable adjustments” for individuals with disabilities, and the provision of unlicensed medicines (removal and supply of the significant majority of medicines outside of their original container is outside of their marketing authorisation and so medicines become unlicensed), additional labour and costly equipment required for monitored dosage systems may, by an individual contractor, be seen as beyond reasonable. Pharmacies may therefore seek to offer alternative mechanisms to support patients, such as reminder charts, large print labels etc. It is also important to note that the Equality Act 2010 would apply only to the patient; pharmacies have frequent requests for MDS to support carers, and as such the act of having a carer could be considered the appropriate adjustment to support the patient to take their medicines – MDS is not a substitute for lack of training by paid-for carers.

The limited evidence available to date indicates a lack of patient benefit outcomes with the use of MDS, and this has meant a change in viewpoint for most pharmacy providers. Following best practice guidelines, many pharmacies are now assessing or reviewing patients using their detailed knowledge of the medicines being prescribed to understand the best options to support the patient. Whenever a medicine is placed in a multicompartmental aid, the medicine is then being used outside of its marketing authorisation and becomes unlicensed, and the responsible pharmacist takes accountability and the associated risks that this carries on each occasion that an MDS pack is supplied. Detailed stability data for medicines outside of their original packaging is sadly lacking, and the limitations of MDS systems mean that things such as timing of doses, for example before or after meals becomes very difficult to manage. With MDS, compromises have to be made, and this has the potential to significantly affect the care the patient receives. This may mean prescribers have to make adjustments to prescribing in order to minimise the overall risk to patients.

Useful links below to guidance on MDS for pharmacy teams:

CQC guidance

https://www.cqc.org.uk/guidance-providers/adult-social-care/multi-compartment-compliance-aids-mcas-adult-social-care

GPhC Equality Guidance

https://www.pharmacyregulation.org/sites/default/files/document/gphc-equality-guidance-for-pharmacies-december-2022_0.pdf

Specialist Pharmacy Services pages

https://www.sps.nhs.uk/articles/summary-of-guidance-and-evidence-for-use-of-multi-compartment-compliance-aids-mccas/

Royal Pharmaceutical Society toolkit

https://www.rpharms.com/resources/toolkits/improving-patient-outcomes-through-mca

NICE guidance

https://www.nice.org.uk/guidance/cg76