The leadership of the Pharmaceutical Society of Nigeria (PSN) recently submitted a memorandum on a Bill for an Act to provide legal framework to establish all Federal Medical Centres (hb. 1390 – hb. 1410).
The document dated 30 November, 2018, and addressed to the chairman, House Committee on Health Institutions, was duely signed by the PSN President, Pharm. (Mazi) Sam I. Ohuabunwa; and National Secretary, Pharm. (Chief) Emeka Duru.
Below is the full text of the memorandum:
MEMORANDUM ON A BILL FOR AN ACT TO PROVIDE LEGAL FRAMEWORK TO ESTABLISH ALL FEDERAL MEDICAL CENTRES (HB. 1390 – HB. 1410):
In response to your call for memorandum on the above subject matter as placed on Punch Newspapers of Tuesday, 27th November, 2018, the Pharmaceutical Society of Nigeria (PSN), an umbrella body of Pharmacists in Nigeria, finds it necessary to make its submission as paraphrased hereafter.
At the launch of the PRESCRIPTION LEGEND in the United States of America (USA) in 1962, President John F. Kennedy described the Pharmacist in the following words: “The Pharmacist is an indispensible link in the chain of National Health Protection and Promotion. If we do not have the Pharmacist, it would have been necessary to invent him.” In 1989, Dr Hiroshima Nakajima, former Director General of the World Health Organization (WHO) reaffirmed the indispensability concept of the Pharmacist and also underscored the importance of Pharmacy in the provision of healthcare when he said “Without drugs, a health service has no substance and credibility”.
It is also common knowledge that in some native Nigerian languages, a hospital is literarily translated in English Language to be “home of medicines”. The simple reason for this is because the use of medicines is key to the provision of healthcare to patients. The above fact underscores the importance and relevance of the Pharmacist in the health system.
Hence, the Society reasons that the bill, which seeks to confer legal identity to Federal Medical Centres is a good attempt to strengthen the health system and boost healthcare delivery to Nigerians given that the passage of the bill would provide the legal framework for the Medical Centres to function more effectively.
However, despite the noble intendment of the bill, the Pharmaceutical Society of Nigeria has identified several omissions of some salient provisions in the bill and some provisions which would affect service rendition in the institutions and hereby strongly canvass their incorporation and redress in the bill respectively as reflected thus:
1) Membership of the Board of Management: The need for inclusion of the Director of Pharmaceutical Services
2) Appointment of Directors and other staff of the Medical Centres: Appointment of Director of Pharmaceutical Services and the Establishment of a Directorate of Pharmaceutical Services.
3) Fund of the Medical Centre: Establishment and maintenance of a Drug Revolving Fund (DRF).
- MEMBERSHIP OF THE BOARD OF MANAGEMENT: THE NEED FOR INCLUSION OF THE DIRECTOR OF PHARMACEUTICAL SERVICES:
It is pertinent to make reference to section 3 (1) of the bill, which deals with the membership of the board of management of the medical centre. Since the sale and use of medicines play a central role in the provision of healthcare to patients and the sustenance of the medical centre by reason of its revenue generating potentials, the inclusion of the Director of Pharmaceutical Services in the composition of the board of management of the Medical Centre is quite appropriate to amongst other things advice and guide the board on policy matters relating to Pharmaceutical Services as they affect the administration of the hospital and also the overall management of the Drug Revolving Fund Scheme (DRFS). This has become desirable in order to maintain the continued growth of the DRF and ensure the sustainability of the DRFS as a revenue generating scheme. In this regard, the Pharmaceutical Society of Nigeria seeks the introduction of section 3(1)(o) in the bill to read thus; “The Board shall consist of (o) The Director of Pharmaceutical Services.” This will be in line with the scheme of the Pharmacists Cadre.
- APPOINTMENT OF DIRECTORS AND OTHER STAFF OF THE MEDICAL CENTRES: APPOINTMENT OF A DIRECTOR OF PHARMACEUTICAL SERVICES AND THE ESTABLISHMENT OF A DIRECTORATE OF PHARMACEUTICAL SERVICES.
In consideration of the reasons earlier canvassed in this memo, it is desirable that provisions are made in the bill for the appointment of a Director of Pharmaceutical Services in Federal Medical Centres and the Directorate carters for the provision of Pharmaceutical Care and services. The imperatives of positioning the Drug Revolving Fund Scheme (DRFS) to operate and be run as a business model in the directorate and the evolved and expanded roles of the Pharmacist as Caregivers has necessitated the creation of a Directorate of Pharmaceutical Services. The Pharmaceutical Society of Nigeria is strongly of the view that the bill should make provisions for the Directorate, headed by a Director, who assumes responsibility for the day-to-day management of the Drug Revolving Fund Scheme (DRFS). In this wise, the Society seeks the introduction and reflection of section 10(1)(e) in the bill to read thus; “The Board shall appoint for the Medical Centre (e) a Director of Pharmaceutical Services.”
Consequently thereof, subsection 2 of section 10 of the bill would be amended to read thus; “The Directors appointed under paragraphs (b), (c) (d) and (e) of subsection (1) of this section shall each be responsible to the Chief Medical Director for effective running of clinical services, the finance and accounts, the co-ordination of maintenance and Pharmaceutical Services and the Drug Revolving Fund Scheme of the Medical Centre, as the case may be.”
3) FUND OF THE MEDICAL CENTRE: ESTABLISHMENT OF A DRUG REVOLVING FUND (DRF)
There is a need to make provisions in the bill for the establishment of a Drug Revolving Fund (DRF) in the Medical Centre so as to legally strengthen the operations of the already existing Drug Revolving Fund Scheme (DRFS) in the hospital. The DRF is a special intervention fund set aside for the procurement and provision of essential medicines to guarantee the continuous and uninterrupted supply and availability of essential medicines in hospitals and also eliminate the prevalence of out-of-stock syndrome. The fund is set aside as a pool of fund to drive the operation of the Drug Revolving Fund Scheme (DRFS), a scheme designed to guarantee the provision of essential medicines needed for preventing and curing diseases and ailments suffered by Nigerians by collecting sufficient funds through charges to patients for drugs consumed to cover full replacement cost of new drugs as well as losses through deterioration and to ensure uninterrupted supply of drugs in the healthcare system.
Also, given the fact that the DRFS remains the most viable source of internally generated revenue (IGR) in the Medical Centre, the need to strengthen its operations through an Act of Parliament remains germane. To this end, the Society seeks an amendment to section 13 of the bill to make room for subsections (1) and (2) and provide for the establishment and maintenance of a Drug Revolving Fund for the Medical Centre. Accordingly, section 13(2) of the bill shall read thus; There shall be established and maintained for the Medical Centre a Drug Revolving Fund into which shall be paid and credited:
(a) all fees and funds from the sale of drugs, medical devices and consumables in the Drug Revolving Fund Scheme
(b) all funds from sale of drugs donated to the hospital by Pharmaceutical Companies, Federal Ministry of Health, Non Governmental Organizations or Donor Agencies.
(c) The fund shall be used to drive the operation of a Drug Revolving Fund Scheme (DRFS) to ensure the continuous and uninterrupted supply and availability of essential medicines, medical devices and consumables.
(d) There shall be for each Drug Revolving Fund Scheme (DRFS) a Project Manager, who shall be the Head/Director of Pharmaceutical Services in the Federal Medical Centre.
(e) The project manager shall be responsible for the day-to-day management of the Drug Revolving Fund Scheme (DRFS), but shall be answerable to the Medical Director/ Chief Executive Officer of the Federal Medical Centre.
(f) The Drug Revolving Fund Scheme shall be efficiently managed as a business model so as to serve as a source of internally generated revenue for the Medical Centre.
The Pharmaceutical Society of Nigeria respectfully solicits the House of Representatives to make amendments in the bill in the area of the following:
1) Membership of the Board of Management; The need for the Inclusion of the Director of Pharmaceutical Services
2) Appointment of Directors and other staff of the Medical Centres; Appointment of Director of Pharmaceutical Services and the Establishment of a Directorate of Pharmaceutical Services.
3) Fund of the Medical Centre; Establishment and maintenance of a Drug Revolving Fund (DRF).
The above provisions have been canvassed in this memo to make room for a statute that protects the interests of stakeholders in healthcare and ultimately serves the interest of patients. In the light of this, we entreat your Committee to effect the incorporation of the above provisions in the proposed Act in the interest of consumers of healthcare in Nigeria.
For: Pharmaceutical Society of Nigeria.
Pharm. (Mazi) Sam I. Ohuabunwa, OFR,MON, FPSN,FNAPHARM, FPCPHARM,NPOM.
Pharm. (Chief) Emeka Duru MAW,