In
the wake of government initiative to constitute J&K Medical Services
Corporation, streamline procurement and ensure availability and supply of
standard quality drugs Dr Geer Mohammad
Ishaq enumerates best practices in supply chain management of medicines in
tune with international norms and standards
Government of
Jammu and Kashmir has in its cabinet meeting held on May 21st, 2013
approved the establishment of J&K Medical Supplies Corporation (JKMSC) with
an objective to streamline the terribly derailed drug procurement and supply
chain management system for government hospitals in the state. In view of the
recently surfaced spurious drug debacle, credibility and faith of patients upon
hospital drug supplies has received a serious jolt. Consequently it has turned
out to be truly a Herculean task for the state govt. to restore its credibility
and peoples’ trust upon the quality of drugs that are supplied at its
healthcare centres. Constitution of JKMSC though late, can still be termed as a
right step in this direction. As they say, “better late than never”. Civil
Society Forum Kashmir had persistently been insisting upon the government to
frame JKMSC and replicate TNMSC taking due care of local contexts,
sensitivities and requirements.
Now that the
govt. has made up its mind to establish JKMSC, it is time to set the drug
procurement mechanism in order through “Standard Operating Procedures” and
highlight best practices in tune with international norms and standards. The
effectiveness of the medication management system depends on adherence to
policies (broad, general statements of philosophy) and procedures (detailed
guidelines for implementing policy). Four strategic objectives of Drug
Procurement in the state should be to procure the most effective and safe drugs
in right quantities; select reliable suppliers of high quality products; ensure
timely delivery, reduce lead time and achieve the lowest possible total cost.
Other best practices are as under:
Selection of Drugs:
The selection of
pharmaceuticals is a basic and extremely important professional function of the
JKMSC that may be charged with making decisions regarding products, quantities,
product specifications, and sources of supply. It is the JKMSC’s obligation to
establish and maintain standards assuring the quality, proper storage, control,
and safe use of all pharmaceuticals and related supplies. ABC/VED analysis of
past procurement has to be conducted regularly and drugs categorized into basic,
supplementary and specialized lists. Drugs should preferably be selected for
procurement from the specific Essential Drugs List of the state. While
selecting drugs local factors like local diseases, regional differences in
sensitivity and resistance of micro-organisms, local climate, topography,
environmental factors etc, should be duly considered. While selecting
formulation types, stable forms should be chosen, giving preference to tablets
over capsules, ointments over creams, powder for reconstitution over injectable
solutions and avoiding syrups, to achieve a low-cost, high impact intervention
in maximizing the therapeutic lifespan of medicines. Expensive combination drugs should be kept out
of the supply list to reduce the actual
cost of drugs to the state by as
much as half. As far as possible
generic drugs should be
purchased to reduce the cost.
Quantification of Drugs:
To avoid wastage through over-stocking or stock-outs of pharmaceuticals, a
reliable system of forecasting
or quantification of drug needs should be used that includes a combination of
past consumption based and morbidity based methods. Accurate quantification of
drug requirements, competitive drug procurement based on generic names, prompt
payment and regular audits, and efficient distribution are some of the major
aspects of effective pharmaceutical management. Budgetary allocations for drugs
and pharmaceuticals should be kept anywhere between Rs. 100-200 per capita per
annum.
Procurement of Drugs:
Competitive bid
purchasing is an important method for achieving a proper balance between
quality and cost when two or more acceptable suppliers market a particular
product meeting the JKMSC’s specifications. Drugs should be purchased directly from the manufacturers and not from their agents, stockists or sub-stockists. Drug
procurement through brokers and agents has to be avoided since brokers are
prone to using corrupt practices such
as paying kickbacks to secure their businesses. Economic considerations should be made
subordinate to those of quality. A company which does not fulfill the
technical criteria of a minimum annual turnover
of Rs 50 crores, market standing of minimum five years and adherence to
prescribed Good Manufacturing Practices (GMP), should be disqualified from
making a price bid. ORG rankings of pharmaceutical companies may also be
followed wherever required.
A
double-envelope system should be used for bidding and the drugs should always
be purchased using VFM (Value For
Money) criteria instead of Low Bid criteria. Envelope B (price bid) of Companies not fulfilling technical
criteria should be returned to
them without opening. To
eliminate sole dependence on one supplier, the next two lower suppliers willing to match the lowest price should
also be approved. To the extent possible, all products should be made available by the supplier in single unit or
unit dose packages. Procurement should
be effected in the largest possible
quantities in order to achieve economies of scale.
With the dual
objectives of maintaining quality and preventing wastages and pilferages, all tablets and capsules should be
procured with only strip or blister
packing, as against bulk packing
which requires manual handling at
the time of distribution. Both inner and outer packages of all items may bear
the logo of JKMSC or labeling
instructions to show that the drugs are manufactured only for JKMSC and
are not meant for sale outside JKMSC.
On account of this, the credibility and
acceptability of the drugs by the public shall improve immensely. Doctors
should be advised to prescribe only products
on the procurement list,
although anywhere upto 10% of drug
budget can be used on unlisted products. The procurement office should
have at least one senior qualified pharmacist
as part of its senior staff, in addition to having qualified
pharmacists’ all along the pharmaceutical procurement chain.
Pre-Qualification of Suppliers:
Pre-qualification
should assess the quality of the manufacturer
(respect for Good Manufacturing
Practices-GMP); the quality of the product
(registration status, Certificate
of Pharmaceutical Product) and the quality of the batch (Certificate of analysis,
labeling, appearance, packing
and shelf life inspection, chemical analysis). It should be the responsibility
of the drug supplier, if any, to
sell only drugs from GMP-compliant
manufacturers and drugs that are duly
licensed. Technical specifications should include Analytical control
data, Sterility testing data, Bioavailability data, Bioequivalence data,
Descriptions of testing procedures for raw materials and finished products,
Testing data developed by independent laboratories, and any other information
that may be indicative of the quality of a given finished drug product. All
information should be supplied at no charge. A Model Questionnaire consisting of four main sections: Business Information, Manufacturing Information,
Quality and Product Information should be used for prequalification of
suppliers. Pre-qualification should
be done continuously as
prospective suppliers express their interests and even before tenders are floated.
Evaluation of Bids:
Selection of
suppliers should be done through a transparent, clear and explicit bidding
process. After thoroughly
evaluating the bids, a special committee or tender board usually awards the
tenders. It is important that a pharmacist or a person with technical knowledge
of pharmaceutical products and its manufacture be a member of the tender board.
As often the case, the determining factor for awarding a tender is price.
Quality must be a more important consideration due to the fact that purchase of
cheaper pharmaceuticals without quality assurance invariably result in losses like
expiration of stocks soon after delivery because of too short shelf-life;
substandard drugs and health hazards. In selecting a vendor, the
Corporation must consider price, terms, shipping times, dependability, quality
of service, returned goods policy, and packaging; however, prime importance
always must be placed on drug quality and the manufacturer’s reputation. Transparency must be maintained
throughout the procurement cycle by following formal written procedures.
Decisions should be based on explicit criteria. A list of all contracts
awarded, specifying the supplier and price for each product, should be made
available to all bidders.
Monitoring Supplier’s Performance:
A continuous
supplier performance monitoring system which tracks lead time, compliance with
contract terms, partial shipments, quality of drugs, remaining shelf-life,
compliance with packaging and labelling instructions of drugs should be
evolved. Monitoring should
include an annual external audit too. The
supplier’s compliance with the terms and conditions of the contract should be
recorded, with emphasis on timely delivery, quantities delivered as ordered,
shelf life after delivery and quality. A system for reporting and recording quality problems noted by the
healthcare professionals throughout the state should be part of the post
qualification procedures.
Quality Assurance System:
A comprehensive
Quality Assurance system involving both surveillance and testing of drug
quality and including both technical
and managerial activities, spanning the entire supply process from drug
selection to patient use should be established. Quality should be checked through visual inspection of incoming consignments and randomly drawn samples from different
batches should be coded and sent to private
approved laboratories to ensure effective quality control. Drug quality should
be assessed as compliance with
pharmacopoeial specifications concerning a drug’s identity, purity, potency and other
characteristics like uniformity of the
dosage form, bioavailability and stability.
Proper Storage of Drugs:
Correct storage of drugs to avoid
deterioration distribution and wastage should be developed through systematic stock inventory control system should
be ensured using modern tool of computerization and management information
system so that drugs are always available when needed in the state. IT enabled
infrastructure is therefore an essential component of the supply chain management
of medicines so that real-time monitoring of drug stocks at district and
divisional levels could be monitoring round the clock.
(Author is senior faculty at the Department of Pharmaceutical Sciences, University of Kashmir and can be reached at ishaqgeer@gmail.com)