According to the 38-page report – released internally in October 2016 and revealed during the High Court hearing last week – the DH also said “there may be a disproportionate effect on deprived communities were any closures to occur".
While the report maintains "there is no reliable way of estimating the number of pharmacies that may close as a result of [the funding cuts]", patients with protected characteristics – "who rely to a greater extent on pharmaceutical services" – would be impacted the most if any pharmacies did close, it said.
The protected characteristics referred to in the document are age, disability, gender reassignment, pregnancy, religion, race, sex and sexual orientation. The National Pharmacy Association challenged the DH in the High Court on the grounds that it failed to consider the impact its funding cut will have on these patient groups.
The DH's original impact assessment was published publically in October 2016, but as recently as January the DH denied to C+D that a second, related report existed.
According to this second report, the DH's "mitigating actions" – including the Pharmacy Access Scheme – will help ensure vulnerable patients still have access to pharmaceutical services if any pharmacies close.
However, the DH acknowledged the access scheme is “more likely to benefit rural, sparsely populated areas, rather than “built-up urban areas”.
Independents and services at risk
The DH also acknowledged that single independent pharmacies and chains of between two and 20 pharmacies would be most at risk of closure as a result of its funding plans. "But even multiples may choose to close community pharmacies that do not bring in significant footfall," it stressed.
However, if any pharmacy were to close, there would be "immediate positive impact on the viability of remaining pharmacies", the DH argued.
The assessment lists scenarios – such as reductions in opening hours and reduced investment in staff training – as “other ways” in which the funding drop could be felt by patients and the public.
“There remains some risk that access will be reduced or that service quality may be affected,” the DH added.
But it stressed that this would be “minimised” to a level where “all patients would have access to community pharmacy services”. "It is very difficult to know whether community pharmacies are likely to close and – if so – what could replace them," it said.
Negative impact on women and certain religions
The DH also touched on how pharmacy closures could impact on pharmacy owners and employees.
It recognised that if there are a significant number of job losses as a result of pharmacy closures or financial belt-tightening, there could be a “negative follow-on effect on those of Asian origin, Hindus, Sikhs, Muslims and women", due to "the distribution of ethnicity, religion and gender across the pharmacy profession", it said.
"There are likely to be opportunities for pharmacists to be employed elsewhere in the health and care system, particularly as a result of the pharmacy integration fund," it added. The push for more pharmacists in GP services would also bring opportunities, while "employment in hospital pharmacies will also continue to be an option".
C+D has contacted the DH to ask why it never published this second report.
Catch up on all of C+D's #CutsInCourt coverage from last week here.