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Strategy for Complaint Procurement of Medicines in Acute and non-Acute Hospitals

The direct purchasing of medicines by the HSE or entities funded by it is a public contract. It is subject to the EU Procurement Directive 2014/24/EU and the HSE National Financial Regulations (NFR01) Purchase to Pay.

The HSE must comply with the relevant procurement procedures in procuring all categories of goods and services, including medicines. These are set out in European and National legislation.

Following a detailed review of the legal framework, the HSE Drugs Management Programme developed a strategy for the Procurement of Medicines in Acute and non-Acute Hospitals (link to doc).

National Dynamic Purchasing System (DPS)

The strategy recommends the introduction of a National Dynamic Purchasing System (DPS), as the preferred model to facilitate compliant procurement of medicines by HSE and HSE-funded hospitals.

The Dynamic Purchasing System represents a new approach to the procurement of medicines by hospitals in Ireland. The national pharmaceutical procurement support team (NPPST) will help to support this change. Their procurement and contractual knowledge will assist the legally compliant procurement of medicines through the DPS.

The current model of Pharmacist-led procurement of medicines with support from HSE Procurement is continuing. The introduction of the DPS will not affect patients or their treatment.

How to get further information 

  1. Strategy for the Compliant Procurement of Medicines in Acute & non-Acute Hospitals (link to strategy)
  2. Health Business Service (HBS) Procurement link to HBS PASS website or email NPPST@hse.ie
  3. A series of hospital group visits were undertaken to outline how compliance with legislation will be achieved through innovative approaches. These include a nationally co-ordinated electronic Dynamic Purchasing System and the publication of a Prior Information Notice (PIN) identifying sole source medicines. (link to be attached)
  4. Frequently Asked Questions (FAQ) (link to be attached)

Falsified Medicines Directive

The EU passed the Falsified Medicines Directive in 2011 to prevent falsified medicines infiltrating the legal supply chain and reaching European patients.

The directive requires medicine packs to carry special safety features. 

These are:

  •  an anti-tamper device (e.g. foil seal, breakable cap)
  •  a barcode containing ‘unique identifiers’ (includes serial number) - the authenticity of the pack can be checked prior to dispensing.

This has been given effect in Irish law by S.I. No. 36/2019 - Medicinal Products (Safety Features On Packaging) Regulations 2019.

Requirements for hospitals

All medicines which fall under FMD and are supplied to patients must be checked for authenticity. This is achieved by checking that the anti-tamper device is intact and scanning the 2D FMD barcode. The data encoded in the barcode is checked versus the European database of medicines for authenticity and decommissioned from the European supply chain.

Hospitals with dedicated pharmacies and/or blood transfusion laboratories are classified as ‘Healthcare Institutions”. They must perform anti-tamper device checks and scanning of 2D FMD barcodes.

The Directive requires scanning to be performed as close to supply to the patient as possible. However, healthcare institutions can scan and decommission medicinal products on a ‘goods inwards’ basis at the time of delivery to overcome logistical issues. All affected HSE and HSE-funded healthcare institutions have been supplied with hardware and software to facilitate scanning on this basis.

Article 23 Sites

Certain sites without a dedicated pharmacy can avail of a derogation under Article 23 of the Delegated Regulation. Wholesalers are obliged to perform decommissioning on behalf of these sites.

A list of sites which can avail of the derogation can be found in section 5 (2) of S.I. No. 36/2019 - Medicinal Products (Safety Features On Packaging) Regulations 2019 (insert link).

SOP for the verification and decommissioning of medicines using ezFMD to ensure Falsified Medicines Directive (FMD) compliance

To support hospital pharmacists healthcare institutions, the HSE, in collaboration with key stakeholders in the Department of Health, the Irish Medicines Verification Organisation (IMVO), and others within the medicines supply chain have developed a standard procedure for the verification and decommissioning of medicines using bespoke software, (ezFMD) to ensure compliance with the Falsified Medicines Directive (FMD).

The purpose of this SOP is to ensure compliance.

To achieve this it outlines the :

  •   the background behind FMD
  •   compliance requirements
  •   the software and hardware platform to ensure compliance.

It is a guide for updating site-specific SOPs relating to goods inwards and dispensing.