Proposal of the "Health" Committee to KRIB for emergency measures in the Health sector in connection with dealing with the spread of COVID-19

Mr. Kiril Ananiev
MINISTER OF HEALTHCARE

COPY:
MRS JENNY NACHEVA
DEPUTY MINISTER OF HEALTH

ABOUT: Proposal of the "Health" Committee to KRIB for emergency measures in the Health sector in connection with dealing with the spread of COVID-19

DEAR MR ANANIEV,

In connection with the complicated situation in Bulgaria, related to the imposed State of Emergency, the members of the Health Committee of the Confederation of Employers and Industrialists in Bulgaria, we would like to propose several measures that we believe will ease the health system and help to deal with the spread of COVID-19.

First of all, at this point state of emergency, we would like to express support to all Bulgarian pharmacists who work in extremely difficult conditions and represent the most critical part of the complex supply chain of pharmaceutical products, providing the population with medicines and health services. Pharmacists are the health professionals most accessible to the general population and are therefore exposed to significant risk and direct danger of infection, given that those entering pharmacies may be asymptomatic carriers and not wearing protective equipment. Unless the pharmacists' employer has taken care at their own expense and within their means to supply the deficient protective equipment, they are not provided with professional protective clothing or accessories. Pharmacists are the ones who take on the accumulated tension and panic of patients and work in extremely difficult conditions with a huge flow of citizens with health problems.

In this situation, in which other European governments are taking measures for financial and other support to pharmacies, Bulgaria is observing the opposite approach. Pharmacies are subject to continuous inspections, and the inspecting authorities do not have the purpose of the inspection, do not comply with the requirements and prescriptions of the Crisis Staff for limiting the gathering of people and other safety measures. The lack of specificity of the inspection leads to a number of critical consequences - from the inability to serve the large flow of patients who are waiting in front of the pharmacy, to the escalation of tension between the pharmacists and the waiting patients.

Additionally, in the highly regulated healthcare sector, the definition of "price speculation" has an extremely fuzzy meaning given the heavy price regulation of both prescription and OTC drugs. This also leads to a wide range of requested information and to the length of the check while patients are crowding in front of the pharmacy. Screeners are not always aware of the legislation in the sector and are not familiar with basic regulatory requirements such as - which drugs are prescribed, how drug prices are regulated and OTC products, what are the requirements for the activity of drug retailers. Last but not least, pharmacists and their employers bear the entire risk of the site being shut down due to quarantine, which risk exists to a very high degree in the case of the mass and unsecured presence of examiners.

The role of the Ministry of Health, which is recognized as a leader in the crisis, is critically important for ensuring the continuity of the activity of all economic entities along the supply chain. This will ensure the population's access to medicinal products in an emergency situation. We would also like to emphasize that a trend of suspension of activity has already started in the sector - in the wholesale and retail trade of medicines, which further increases the workload and criticality of the operations of the existing wholesale and retail traders of medicines.

We are therefore calling for an end to the pressure on pharmacists and drug retailers with checks for no clear purpose and we are confident to no avail. Companies part of the pharmaceutical sector are subject to constant regulatory control, which is necessary and ensures compliance with the regulatory framework. The checks undertaken in recent weeks do not meet this criterion.

Dispensing prescription drugs with a white prescription online

We admire the efforts of the Ministry of Health to facilitate patients in the re-issuance of necessary health documents in order to avoid visiting relevant institutions. Although this creates an additional workload for pharmacists, as well as a financial risk for their employers due to the ambiguities of such a change, the measure is extremely valuable precisely for the most vulnerable patients in the current situation.

Given the described extremely difficult situation in pharmacies and the impossibility of complying with some of the prescriptions for measures against the gathering of people in order to limit the spread of COVID-19, we would like to propose the introduction of white prescription dispensing through the online channels of retail license holders.

However, the introduction of online drug dispensing is extremely valuable precisely for the most vulnerable patients in the current situation.

• This measure will be most useful precisely for sick people, which would limit their need to leave the house and accordingly reduce the spread of the virus.
• The traffic of patients with already manifested symptoms in the pharmacies will be able to be reduced, which will reduce the risk of infecting the pharmacists, as well as the spread of the infection among the patients.

Our proposal to dispense medicines under a "white prescription" online is in sync with the measures planned by the Government for the preliminary preparation of the upcoming stages of the state of emergency and in particular the possibility of imposing a complete ban on citizens leaving and, accordingly, the need to have an organization to order medicine and food online.

We are available for discussion of the proposals in order to develop specific regulatory and other mechanisms for introduction.

With respect:                                                                                        

Eugene Ivanov
Executive Director and Member of the Board