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RESPONSE TO FEES CONSULTATION - please read and comment ASAP!

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  • RESPONSE TO FEES CONSULTATION - please read and comment ASAP!

    Hi all,
    Below is my response to the fees consultation - I intend to tide up any typos and stuff tomorrow morning, but I've had some pinot grigio now so can't be arsed tonight. But.....I'd really like your views on the response. Do you think it's a bit over the top? Am I being too harsh? OR not harsh enough? Are the facts correct?

    Br grateful if you could respond ASAP cos I need to post this thing tomorrow morning. (saturday).

    Here goes:

    Subject: Formal response to 2008 fees consultation

    Dear Sir/Madam,

    Thank you for the opportunity to comment on the proposed increase in fees in connection with the 2008 registration cycle as outlined in the consultation document released on 2nd August 2007. I am writing as I am strongly opposed to the increase in fees, for reasons detailed below and in the response form [Annex 1] provided by the Society.

    Firstly, I wish to draw your attention to the following. A press statement released by the RPSGB on 27th July 2007 [Annex 2] stated “At it’s July meeting, the Council of the Royal Pharmaceutical Society of Great Britain agreed a new practising retention fee of £425 for 2008”. This press release makes no mention of the fee increase being a ‘proposed’ fee increase – it appears to be a definite increase. As I am sure you are aware article 40(4) of the Pharmacy and Pharmacy Technicians Order 2007 (Statutory Instrument 2007 No. 289) states “Before making rules under paragraph (1), the Council shall consult such registrants or classes of registrants as it considers appropriate”. Prior to the announcement of a definite fee increase, on 27th July 2007, there is no publicly available record of any registrants being consulted on the fee increase. If no ‘private’ consultation of a small group of registrants took place prior to 27th July 2007 it would appear that the Society has exceeded the powers conferred upon it by article 40(4) of the Pharmacy and Pharmacy Technicians Order 2007. The consultation document released six days after the announcement of the fee increase appears to be a ‘knee-jerk’ reaction – when the Council released the membership would not ‘go quietly’. This was evidenced by the online petition against the fee increase (which, at its end had been signed by the equivalent of approximately 25% of the membership) and a Facebook (a social-networking site) Group protesting against the increase in fees.

    The consultation document is poorly written, it is illogical in progress and in some places repetitive and contradictory. The principles are vague, some are irrelevant and most do not all address some key issues which I believe should have been considered when adopting a financial strategy. For example, there are no principles which relate to restricting costs, principles 6 and 9 merely relate to recovery costs for current and new activities. Also, no principle addresses a policy for Government lobbying – a matter which should be a continued concern for any regulatory body, especially at the time of a de-merger. As a result of this illogical document and poorly defined principles I find it difficult provide a clear and valid response to the questions posed in the response form and as such most of my arguments opposing this fee increase will be laid out in this letter.

    Whilst some of the principles form a basis for a sound financial strategy (i.e. maintaining healthy resources and financial independence) it must be remembered that increasing fees is only one method of revenue generation. It appears from the consultation document that other methods of revenue generation have not been considered. The Society also appears not to have given serious thought to cost-cutting exercises. Ambitious projects which are not self-funding, such as Pharmacy 2020, should not be considered at this point.
    To the best of my ability I will attempt to address the principles one by one:

    Maintain healthy resources I agree that this is the basis for a sound financial strategy. However, at the end of 2006 the reserves stood at £4million. Andrew Gush stated that £3million raised through the increase in fees will be used to boost reserves (Pharmaceutical Journal, 19th August 2007). This 75% increase in reserves seems a little odd. Ideas for revenue generation, aside from increases in fees, need to be considered by the Society if it wishes to increase its reserves by this amount.

    Financial independence I agree that this is the basis for a sound financial strategy. Ideas for revenue generation, aside from increases in fees, need to be considered by the Society if it wishes to increase its reserves by this amount.

    Publishing income to build reserves I agree that this publishing income is a sensible way to build reserves. I trust that the Society’s tax planning measures will attempt to achieve the lowest tax liability at all times.

    Encouraging professional innovators I commend the Society on their proposal to remove the requirement for additional fees for those who wish to retain a prescribing annotation. However, due to the small number of registrants who have a prescribing annotation, this principle will have a minimal impact on revenue generated therefore is not really appropriate as a principle to be taken into consideration when setting fee levels for most of the profession.

    Apply fee increases to all registrants proportionally Fees should be applied in relation to the amount of work generated by each class of registrant. The fee setting process should be transparent. For example, I do not believe the proposed examination fee of £270 is fair considering the relatively small amount of administrative work involved in this.

    Administrative cost recovery This principle should be the cornerstone of any financial review. However, paradoxically, this principle does not support the proposal for registration fee increases. Surely if all non-fee related administrative tasks are recovering costs, then an increase in fees to account for this is not justified?

    Three-year rolling budget As I have not been provided with details of the three-year rolling budget I cannot comment on this principle. Again, this exemplifies how poorly written this document is.

    Simple and transparent I do not know what the revenue generated by the proposed fee increase will be used towards. Repeated requests to the Society by membership via the letters of the Pharmaceutical Journal and other channels have failed to provide us with concrete details of what the extra revenue will be used for. All I understand is that £6 million will be generated, £3million to build reserves; £1 million to cover Gift Aid changes and £2 for an increase in budgets generally. Clearly, this is not ‘simple and transparent’.

    Minimise cost of collection/administration for payer and Society Without further clarification on what ‘administrative burden’ means I am unable to comment properly on this principle. If it simply means those who chose to pay by cheque rather than Direct Debit then I do not agree with the principle as registrants should not be penalised for their preferred method of payment.

    In summary, it appears that the Society is relying on generating revenue from the membership via an increase in fees and is not giving due thought and consideration to other methods of revenue generation. I fear that the increase in fees will lead to large numbers of pharmacists retiring from the register. This resultant shortfall in pharmacists could lead to poor community pharmacy healthcare provision in some areas which are reliant on part-time pharmacists. Evidently, this will not help promote a positive public image of pharmacy.

    I urge the Society to review the increase in fees to help regain the trust of the ‘coalface’ pharmacist and ensure a positive future for the profession.

    Yours sincerely,

    Reg number: XXXXXXX

    The views in this letter and attached form are my personal views and are not representative of any organisation I work for or am associated with.

  • #2
    Re: RESPONSE TO FEES CONSULTATION - please read and comment ASAP!

    And........can everyone make sure they respond to the consultation.

    FORMAL RESPONSES TO THE CONSULTATION ARE THE ONLY THING THAT HAVE TO BE LISTENED TO BY THE SOCIETY - letters in the PJ etc are good....but they can just ignore those...

    Even, if you're a really lazy pharmacist who just can't be bothered after yet another long week at work then just fill out the online form - it'll only take one minute. Just answer 'no' to every question except Q9 and a 'yes' to question 9. This will count as a 'opposed' response and EVERY SINGLE RESPONSE counts.

    Here's the link to the online form Fees consultation questionnaire

    Go'll just take a minute.


    • #3
      Re: RESPONSE TO FEES CONSULTATION - please read and comment ASAP!

      If you can write like that after Pinot Grigio you need to stand for the council mate!

      The letter is great. Most of it is what I wanted to say but couldn't write it coherently.

      Your proposed ideas are good and the opening about the Council overstepping their bounds is brilliant.

      JUst seen that this is late for your response timeframe but if you ahve posted it good on ya!

      If you haven't yet then I can see no reason not to.
      Linnear MRPharmS

      Foetal Alcohol Spectrum Disorder: The biggest cause of brain damage and 100% preventable.

      In pregnancy: 1 fag is not safe, 1 x-ray is not safe and 1 drink is not safe.

      For handy pharmacy links try

      If you like my posts or letters in the journal try my books!


      • #4
        Re: RESPONSE TO FEES CONSULTATION - please read and comment ASAP!

        Originally posted by Linnear View Post
        If you can write like that after Pinot Grigio you need to stand for the council mate!
        THanks for the compliment!

        Yeah, I posted the letter more or less as what was written above....let's hope it helps.

        There's so much more I wanted to say, but then the letter woud have gone to about 10 pages! There's so much crap in the consultation document - I just wanted to tear it apart. e.g. Hemant Patel says in the consultation document that money is needed for the de-merger - but Andrew Gush in the Q+A session does not mention any of the money going towards de-merger. It's just so badly written - obviously a rushed 'Friday afternoon' much CRAP!

        The questionnaire is misleading too - implying that people should only address the principles - when this is not what the cosultation is about.