Medicines Pharmacy & Industry Group
Dear consultation team,
Re: ‘Generic Substitution in Primary Care’ consultation
I am writing to submit my thoughts regarding “The proposals to implement 'generic substitution' in primary care, further to the Pharmaceutical Price Regulation Scheme (PPRS) 2009” consultation document.
As a person with epilepsy, I am concerned that anti-epileptic drugs would be allowed to be substituted. There is strong evidence that brand switching for many people with epilepsy has caused breakthrough seizures, worsening of their seizure control or worsening of side-effects.
[It would help if here you can talk about your personal experiences of drug switching and your own worries and concerns. Examples of this could be the problems you had when picking up your prescription, or the changes to your epilepsy as a result of taking a different version of your drug.]
Having read the document I do not feel able to respond to all the questions asked, but would like to put forward some points for consideration.
I would like to see Option 2 adopted, provided anti-epileptic drugs are on the list of drugs not to be substituted. This option would be best to ensure that people with epilepsy are not put at unnecessary risk.
I do not support the government’s preferred choice (Option 3) unless it is changed so that there is a public consultation before a drug is added to a substitution list. I am worried that anti-epileptic drugs could be added to this list at any time without this process.
As well as a process for adding drugs to the substitution list, I also think there should be a second list of drugs that can never be added to a substitution list, which should include anti-epileptic drugs.
I hope you will take my comments into account when deciding which proposal to adopt.