Formulary transparency

So we need to publish all relevant local formulary decisions on line in a clear, simple and transparent way so that patients, the public and stakeholders can easily understand it.

A simple requirement you might think, but it asks several questions that must be thought through.

What constitutes ‘all relevant local formulary decisions’. There would seem to be two components to this:

  • decisions on how the formulary process operates 
  • decisions on individual medicines.

We already know that the terms of reference, the formulary process, the application form and the decision matrix should be available. I would assume any decision that affects the way that the committee is formed or how it carries out its business.

And then there are decisions related to individual medicines which need to be simple, clear and transparent so that patients, public and stakeholders can easily understand. Wow now that really is a task.

To achieve this we do need to think about the way that we run the process. A standard format agenda and minutes would help when these are published on the Internet, but we can now just say that a medicine has been added or removed without offering an explanation that a member of the public could understand.

The application form, completed and with supporting information is required for stakeholders to understand the decision that was requested and the information used. This is important when you consider the usual quality of the application form and the way that the supporting/competing information is presented. Now more than ever the application process should be an iterative process in which the application and the supportive information is melded into one. (See a previous blog on discovery and on the evidence pit.)

So we all need to work together to present an adult and cohesive approach to this. It does beg the question as to whether more formulary applications should be proactive and initiated by the formulary pharmacist, but that is another discussion. The process should filter out the poor applications at the ‘triage’ stage of the process and the consultant/applicant should feel happy that their application form is going to be published on the Internet along with a range of information which obviously either backs the application or not as the case may be. We mustn’t show the public anything other than reasonable people considering what is best for patients. I must admit that in a previous life as a secretary of a drugs and therapeutics committee about half of the applications got to committee stage – I have seem a wide range of specialists say ‘they aren’t going to approve this’ and then the application is either changed or withdrawn – and the committee had a high pass rate – just how it should be!

The final question is how we present the decision. Obviously to standardise the decision and to make sure it complies with the ethical and commissioning frameworks and our agreed priorities we are using a decision matrix. So the answers need to either be ‘compliance’ or a score which we can add us and present as a joint decision.

Then the only tricky bit is when we explain that the decision matrix is only an average of 6 responders – four pharmacists and two GPs. Ask Richard at the MMP for a solution to this problem.


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