NHS England (NHSE) has today (October 29) published its specification for community pharmacy prescribing, providing the legal basis for prescribing to commence under Pharmacy First.
Integrated care boards are currently assessing applications from a number of pharmacies interested in the service, meaning no pharmacies will be able to offer NHS-funded prescribing consultations at present. Only a small number are expected to take part in the service.
The specification sets out the core requirements for pharmacies providing the service and the independent prescribing pharmacists (IPs) who will deliver consultations, including the need for IPs to only prescribe within their competency and the strict recording requirements for prescribing consultations delivered as part of Pharmacy First, the contraception service and prescription management – which involves IPs issuing new prescriptions to help mitigate the impact of shortages.
In most circumstances, it is expect that IPs will issue one-off, non-nominated EPS prescriptions, with NHSE clarifying that IPs must adhere to local and national guidance and “prescribe the best value product for the NHS to meet the clinical need of the patient”. They may not prescribe medicines to themselves in any circumstances.
NHSE said contractors must consider how prescribing and dispensing by the same pharmacist “will be managed to maintain patient safety” and assess how the “integration of prescribing and dispensing functions may impact clinical objectivity or patient choice due to commercial incentives and conflicts of interest”.
The document states that patients “are free to have items dispensed at whichever pharmacy they choose” and that no attempt may be made to influence their nomination.
NHSE said the use of prescription management is “discretionary” but is “encouraged” wherever it is in a patient’s best interests, with the qualifications that routine dispensing alternatives must be exhausted first, that IPs should only prescribe within their competence and that the original prescriber must be informed of any interventions.
The specification also sets out that prescription management activity will “not qualify for a payment claim”.
“Patient safety and clinical benefit take precedence over operational or financial considerations,” said NHSE.
Contractors must ensure that any prescribing activity is limited to the IP’s core competencies and that the IP is competent to use equipment such as otoscopes, it added.
IPs “should have a clear development plan to upskill themselves” to deliver any part of the prescribing pathways they are not yet competent in, said NHSE – offering some flexibility for pharmacies to begin offering consultations if an IP is not yet trained in all aspects of the service.
Pharmacy First prescribing consultations must meet an outcome to qualify for payment. These include a closed episode of care – which may or may not involve the generation of a prescription – and escalation or referral to other providers.
Contractors providing NHS prescribing services must have an IP available for a minimum of 24 hours a week during core opening hours and for at least 45 weeks in the financial year.
Community Pharmacy England chief executive Janet Morrison said: “In reality, there will be no authorised prescribers or pharmacies to commence prescribing today, but this is nonetheless a noteworthy day in the history of community pharmacy in England.
“The addition of prescribing to the CPCF is a strategically important service development for all in the sector. But the size of the challenge for pharmacy owners and prescribers to implement prescribing in their pharmacies is very large and our concerns about the available funding not covering the costs which will be incurred remain; they demand very careful consideration by any pharmacy owner considering signing up to provide prescribing.
“We will continue to work with DHSC and NHS England to seek funding that does cover the costs of this important clinical role development for community pharmacists and allows prescribing to flourish in community pharmacies across England for the benefit of patients and the NHS.”
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