Get to grips with the new Community Pharmacy Contractual Framework in England (CPCF)
NPA members in England should familiarise themselves with the new community pharmacy framework after PSNC, the Department of Health and Social Care and NHS England announced a new five-year deal. The funding settlement is for £2,592bn per year (almost £13bn over the five years).
PSNC has stated that from this October, there will be some immediate structural changes to funding including the phasing out of MURs and the Establishment Payment, with these monies being reinvested into the sector.
Other changes, listed on the PSNC website, include:
• Contractors will receive monthly transitional payments in the
second half of 2019/20 and again in 2020/21 in recognition of
costs associated with changes such as integration into Primary
Care Networks, preparation for Serious Shortage Protocols and
implementation of the Falsifi ed Medicines Directive.
• Contractors can earn payments for meeting quality targets under
the renamed Pharmacy Quality Scheme (formerly the Quality
Payments Scheme). The new scheme has a review point in
February 2020 and several revisions to the previous criteria.
• A new national NHS Community Pharmacist Consultation Service
is being commissioned from this autumn, which will bring
together the national NUMSAS and local DMIRS pilots into one
• An increasing use of technology and other enablers will seek to
make the dispensing process as effi cient as practicable.
• Other elements of the deal include the continuation of the
Pharmacy Access Scheme (PhAS) and the use of the Pharmacy
Integration Fund to fund pilot services which may, if successful, be
commissioned nationally from pharmacies.
10 things you can do right now to prepare for changes
to the pharmacy contract in England.
1. Read the information supplied by PSNC on its website (www.
psnc.org.uk) and the NPA’s initial reaction (see p44). Pharmacy
owners are advised to watch PSNC’s webinar for community
pharmacy contractors to understand the fi ve-year CPCF.
2. Familiarise yourself with the new Community Pharmacist
Consultation Scheme. The NPA has produced a webinar titled
‘NHS Community Pharmacist Consultation Service: a golden
opportunity for your pharmacy?’ Go to www.npa.co.uk/newsand-
3. Gen up on the clinical knowledge you will need to deliver the
range of services now in the NHS service development pipeline,
and record this as CPD. Consider refreshing your knowledge on
minor illnesses and Hep C testing. You can access the NPA’s CPD
hub at www.npa.co.uk/training/cpd
4. Make sure you are, or are on track to become a Healthy Living
Pharmacy. It will be a requirement by the Terms of Service to
have attained HLP Level 1 status by April 2020. NPA training can
be accessed here: www.npa.co.uk/learning-and-development
5. In light of the fact that there will be no more new money for
dispensing volume, think again about how you can either
cut costs or work smarter and effi ciently in your business
and consider the skill mix in your pharmacy. There are lots of
practical tips in the Spring edition of InPharmacy magazine.
6. Take stock of where you are financially. Watch our webinar on
fi nancial advice and consider speaking to our business partners
by going to www.npa.co.uk/services-and-support/businesssupport/.
Watch the NPA’s webinars on Understanding the
Global Sum and Understanding Your Finances and Distribution
of Margins so that you can better assess the impact on your cash
flow. Go to www.npa.co.uk/news-and-events/past-events/
7. Start thinking about your engagement with Primary Care
Networks, liaising with your LPC. Take a look at this blog from
some intrepid NPA members already beginning their own PCN
journey and follow them over the months ahead to learn from
their progress. Go to www.npa.co.uk/2019/07/24/were-taking-aprimary-
8. Build your local connectivity by speaking to your LPC’s
independent representative and team and work to develop
positive relationships with GP.
9. Let us know your thoughts on plans to change pharmacy
reimbursement systems. The current DHSC consultation seeks
to deliver a fairer share of margin, but some changes may
have unintended consequences. Have your say at
10. Review the new Pharmacy Quality scheme criteria for the second
half of the fi nancial year. Start thinking about how you can meet
them – NPA resources to support you will be available soon.
Five year deal on the Community Pharmacy Contractual Framework
PSNC, the Department of Health and Social Care and NHS England have announced a five-year deal for community pharmacy, from October 2019 through to 2023/24.
It includes what PSNC calls “a clear vision for new pharmacy services” including a NHS Community Pharmacist Consultation Service being introduced later this year.
The funding settlement is for £2,592bn per year (almost £13bn over the five years). There is also a commitment to achieve “smoother cash fl ow and fairer distribution of margin”.
Mark Lyonette, chief executive at the NPA, said: “We strongly support the emphasis on clinical services and the recognition that pharmacies can play a signifi cantly greater role in urgent care and public health.
“What’s more, the five-year term of this settlement gives us the long view we asked for. But static funding year on year means
it will be very difficult to deliver the transformational improvements we all want to see. We know that many of our members are not breaking even, let alone in a position to invest in new services that would greatly benefi t patients and the NHS.
"The government must be prepared to direct more money into community pharmacy, to avoid uncontrolled closures, or if it becomes clear that funding is insuffi cient to maintain current core services and invest in positive new developments like the Community Pharmacist Consultation Service.
“We note the proposed annual review each October. To ensure the service levelsn required for patients, we suspect the £2.59bn needs to be a fl oor not a ceiling.”
The NPA will seek meetings with DHSC and NHS England to advocate for more progress on areas not dealt with during the current round of negotiations. This includes thorough reform of the concessionary price system to ensure that pharmacies are not dispensing at a loss. We also want a guarantee of full, accurate and timely drug reimbursement and payment of fees.
National framework to improve public health
The National Pharmacy Association has helped bring about the first ever “high-level, system-wide commitment” in England to improving quality in all
areas of public health.
The Public Health System Group, which includes a wide range of key partners across health, local and national Government, worked together to set out the framework.
The group includes the NPA, alongside others such as the National Institute for Health and Care Excellence (NICE), Care Quality Commission and the Health Foundation.
Helga Mangion, policy manager at the NPA, said: “As providers of public health services community pharmacists and their teams now have a framework that outlines and measures what quality in public health means.
“Pharmacies are disproportionately located in deprived areas – a rare exception to the so-called inverse care law under which people with the highest needs have the least access to advice and treatment.
“With growing challenges facing the health and care system, maintaining a focus on quality in public health is more important than ever in order to improve health outcomes and reduce health inequalities.”
The six key principles and actions which the Public Health System Group have agreed upon include the following:
1. Developing a system-wide focus
• Ensuring that prevention is prioritised with
focus on strengthening communities.
• Ensuring individuals and communities are
empowered to manage their physical and
mental health and wellbeing.
2. Reducing health inequalities
• Ensuring the reduction of inequalities in
• Ensuring equity of access and usage on
all services as well as providing targeted
services where needed (proportionate
3. Embedding health in policy
• Promoting and advocating with
others action to infl uence the wider
determinants of public health.
• Assessing policies to evaluate impact.
• Identifying opportunities for cross sector
4. Evidence and needs-based public
• Supporting the gathering, generation and
dissemination of evidence on what works.
• Listening to stakeholders’ needs and
wishes before making decisions.
5. Developing strong systems
• Ensuring mutual accountability and
system wide assurance
• Mobilising community assets and the
wider public health workforce
• Continually learning.
6. Responsibility to future
• Taking due consideration on present
day decisions and how they will impact
on the health and wellbeing of future
• Support the delivery of UN Sustainable
For more information email
A recent review of the NPA’s
current purchasing model
has given members a more
streamlined process for
purchasing their pharmacy
As a result of the review, the NPA is
pleased to announce a new partnership
with EMT Healthcare, a family-owned
and operated business which has been
serving community pharmacies since
1963 and is aligned with the NPA and its
Simon Tebbutt, head of relationship
management, said: “We’ve consolidated our
purchasing to make it better for members
and we’re working with EMT so we can
lower prices and reduce costs, offering a
wider range at the same time.”
The partnership includes an arrangement
whereby EMT still stock and review their
ranges with the NPA on a quarterly basis to
meet members’ needs.
Simon said that members can expect
to save an average of 15% on print stock
items previously available on the NPA
sales website. The current model used by
members and customers allows them to
purchase products from both the NPA and
“There are some things we sell that EMT
don’t and vice versa,” explained Simon.
“Currently things we sell include items
like CD inserts, stickers, and destruction kits.
Customers order from us but the products
are physically held by EMT Healthcare who
dispatch them to us.
“But now, rather than ordering through
us, customers can order everything from
EMT Healthcare which means we cut off an
extra step in the buying process.”
Simon added: “It’s a new way of buying
pharmacy essentials from a trusted partner
which creates price reductions and more
effi ciency. We’re always looking at ways
for members to get extra value out of their
Rod Muir, managing mirector of EMT
Healthcare, said: “EMT welcomes this new
dimension to our important partnership
with the NPA. We strongly believe this is a
mutually benefi cial strategy will streamline
the service going forward. EMT has long
been associated with helping pharmacy
save money, so marrying our ability to do
just that with today’s pressure to reduce
costs wherever possible puts us in a strong
position to help. The cost savings are real.”
When pharmacy teams go to npasales.
co.uk to order items they will be directed to
Licensed brand of
melatonin oral solution –
Pharmacy teams who dispense NHS prescriptions for
melatonin oral solution should be aware that a licensed brand
has been marketed by Colonis Pharma Ltd from June 2019 as
melatonin oral solution 1mg/ml. The product is a sugar-free
preparation and its only licensed indication is “short-term
treatment of jet-lag in adults”.
Colonis Pharma has confi rmed the licensed product is available to
order through mainline wholesalers Alliance Healthcare, Pheonix,
AAH and some short-line wholesalers including Mawdsley Brooks &
The NPA is receiving an increasing number of calls from pharmacy
teams querying reimbursement following advice from specials
suppliers that they should obtain the licensed brand of melatonin
oral solution to dispense against prescriptions calling for melatonin
oral solution 5mg/5ml.
NHS Business Services Authority, Business Services Organisation/
Community Pharmacy Scotland/Community Pharmacy Wales have
confi rmed the following information regarding reimbursement:
Pharmacy contractors will not be reimbursed for dispensing the
licensed brand of melatonin oral solution against prescriptions
calling for the unlicensed version.
In addition, pharmacists must dispense in accordance with the prescriber’s
instructions and therefore must not make substitutions without contacting the
prescriber and having the prescription amended as appropriate.
The Medicines and Healthcare products Regulatory Agency
(MHRA) has issued guidance on supply of unlicensed medicinal
This states: “Although MHRA does not recommend ‘off-label’ (outside the licensed indications)
use of products, if a UK licensed product can meet the clinical need, even
off-label, it should be used instead of an unlicensed product.”
On that basis, pharmacy contractors who receive a prescription for
an unlicensed melatonin oral solution in any strength should take
the following action:
• Contact the prescriber to advise that a licensed product is now
available and even if it is being used for an off-licence indication,
it should be prescribed in preference to the unlicensed version
• If the prescriber agrees with the advice;
1. Have the prescription amended to state “melatonin 1mg/ml
oral solution sugar-free.”
2. Document the details of the discussion on the PMR.
• If the prescriber does not agree with the advice and wishes the
patient to have the unlicensed version;
1. Confirm that the prescriber is aware it is unlicensed.
2. Document the details of the discussion on the PMR.
For further information, please contact the NPA
pharmacy services team on 01727 891 800 or email
Employee claims rise for
the second year running
The latest round of Employment Tribunal
statistics has now been released – giving
employers a full year picture to compare
against the year prior.
Broadly speaking, the findings are as
expected, with the overall claims trajectory
continuing in much the same way as it has
been since Tribunal fees were abolished
back in 2017. These latest statistics serve
to remind employers of the importance
of taking proactive steps to minimise the
risk of claims. The stats relate to the whole
UK economy, not specifically community
Volume of claims
The bottom line is that Employment Tribunal
claims are up 26 per cent year on year:
• There were 27,916 single claim receipts
lodged between April 2017 to March 2018.
• There were 35,429 single claim receipts
lodged between April 2018 to March 2019.
The Supreme Court scrapped Employment
Tribunal fees back in 2017.
Types of claims
Sex discrimination has seen the biggest rise
in claim numbers, from 5,522 in FY18 to
9,336 in FY19 – an increase of 69 per cent.
At fi rst glance, this seems to suggest that
the #MeToo movement may have gained real
traction. However this fi gure is skewed by
the receipt of over 2,700 sex discrimination
claims in the Scottish Tribunal in August
2018. Take that out and sex discrimination
claims are actually up 20 per cent.
Other claims which have risen include:
• Breach of contract, up 15.07 per cent.
• Race discrimination, up 17.75 per cent.
• Unfair dismissal, up 19.97per cent.
• Disability discrimination, up 24.54 per cent.
• Redundancy (failure to inform and
consult), up 35.76 per cent.
Claims for age discrimination, equal pay
and part-time workers regulations are down.
Where we’re headed
There’s no sign of the number of claims
slowing down and no indication this will
change any time soon. Fees were introduced
in July 2013, and in the 12 months prior to
this, 53,487 single claims were received. This
means there’s still potential for a further 50
per cent increase in claim numbers if we’re
headed back to the kinds of claim levels we
saw in the original pre-fee era.
For trusted legal advice on any
employment matter, contact
the NPA Employment Advisory
Service on 0330 123 0558 or email
NPA launches ePGDs
An ePGD is an electronic, user-friendly alternative to paper
consent forms, which has a substantial number of inbuilt
safeguards that are impossible to implement in a paper
format. It is quicker and easier to complete than paper and
removes the need for expensive long-term storage of paper
The NPA has partnered up with Medical Prescription Services
(MPS) for the provision of the PGD and certifi cate once the training
has been completed.
What are the benefits?
• Enhanced patient safety – ePGD has integral secure features and
alerts which make it safer to offer PGD services. Pre-screening
applications are automatically displayed as Passes or Failed and
further tailored advice is generated.
• It can save a pharmacist time and money as ePGD reduces a
typical consultation from 20 minutes to less than fi ve minutes.
Patients are also able to complete their applications from home or
work at a time that suits them, before attending a consultation,
saving even more time.
• Clear and easy-to-follow patient journey which prevents patients
from moving forward until they have read all the relevant
• In line with best practice, a GP letter is generated which can be
printed and given to the patient.
• Free, secure electronic data storage removes the need for
expensive, long-term paper document storage. Paper copies are
not required as the system can be accessed at any time and data
• Electronic archiving and reporting makes robust governance quick
• Free internet presence and enhanced accessibility to patients
and customers – the service has a free “Pharmacy Finder” which
is used to link patients searching for services to participating
• Quick, safe, clinically robust, as well as creating a full audit trail.
How can I get an ePGD?
You will be asked to select your preference for the format of
your PGD(s) as part of the online enrolment process for our PGD
packages and training. If you select the ‘ePGD and Paper’ option,
there are a few more questions to enable you to be registered for
the ePGD facility.
I’ve already bought my 2019 PGD packages and
training - can I still get an ePGD?
Yes, you are still entitled to a free upgrade to an ePGD for each of
the packages you have bought. Our Member Services team will be
in touch with you shortly to advise how to claim your free upgrade.
Read the free upgrade process here.
If you have any questions regarding PGD training and packages,
please email email@example.com
Launch of NPA Community Pharmacy
Hypertension Detection SOP (NI)
The NPA has published a new standard operating procedure
(SOP) to help participating pharmacies to prepare for
provision of the Community Pharmacy Hypertension
Detection service in Northern Ireland.
The service aims to detect undiagnosed hypertension in patients
aged over 45 years and will run for 6 months.
The NPA welcomes the announcement from the South Eastern
Integrated Care Partnership, in conjunction with the Health and
Social Care Board (HSCB) and Community Pharmacy NI (CPNI), that
the Community Pharmacy Hypertension Detection Service will be
available through participating pharmacies in the South Eastern area
from July 2019.
Pharmacists should ensure that they submit their training and set
up a claim after five patients have been reviewed in the service.
For further information on this or any other query, please
contact the NPA Pharmacy Services team on 01727 891 800 or
Common dispensing errors resulting in
indemnity claims (UK)
Example 1: dispensing patient returns
A significant claim has arisen from an error involving patientreturned
vials of heparin which were accidently re-dispensed to
a pregnant patient. The patient had administered a few doses of
heparin before realising that the vials had been used before, and
alerted the pharmacy. The pharmacy accepted that the heparin vials
were patient-returned medicines which had been accidently redispensed.
Once the patient realised the error, she was treated with
preventive medication against the potential risk of infections such as
HIV and hepatitis B. The patient went on to give birth to a healthy
baby. However, the experience allegedly resulted in a signifi cant
ongoing psychological impact on the patient, both during her
remaining pregnancy and after.
A key element which resulted in this error was the failure to
segregate and store patient-returned medicines appropriately, and
a potential failure in implementing the patient-returned medicines
standard operating procedure (SOP) in the pharmacy.
The NPA advises that superintendents should:
• Ensure that all pharmacy team members, including locums,
are fully aware of the patient-returned medicines SOP and are
• Ensure that all waste medicines, patient-returned or expired
pharmacy stock, are properly segregated and not left lying around
in the pharmacy dispensing area.
• Ensure that the dispensing SOP is in place and being followed
– in this incident, it is not clear if the fi nal accuracy check was
conducted properly or not, and who was responsible for the
• Use the NPA template essential SOPs for to help you to review and
update your pharmacy SOPs if required.
Example 2: MDS errors where medication were given
to the wrong patient.
1. A prepared MDS was incorrectly dispensed to the wrong patient.
It contained anti-diabetic medicines but the patient it was given
to, did not have diabetes. The patient’s solicitors alleged the
patient, who lived alone, took the medicines from the incorrect
MDS and collapsed, before being found by a carer. The patient
was admitted to the hospital and his solicitors allege he has been
left with a signifi cant cognitive brain injury. One of the issues
identifi ed has been the advance preparation of this MDS being
stored in a stack with all other prepared trays on a shelf with the
wrong tray selected to hand out to the patient.
2. Another claim has resulted because a prepared MDS tray was
allegedly given to the wrong patient. This incident also involved
anti-diabetic medicines which were allegedly taken by the patient
who did not have diabetes. Following a prolonged period of
serious illness in the hospital, the patient died. Despite questions
over causation issues, this has resulted in a claim against the
3. Yet another claim involving MDS came about because a patient
was administered medicines from the wrong MDS tray by a care
company without making the proper checks. However, the care
company is also asserting that the pharmacy supplied them with
the wrong MDS tray which resulted in their error and are seeking
to recover their outlay to the patient.
The MDS claims may have arisen because the MDS trays had been
prepared in advance, stored in a stack on a shelf, and potentially
proper processes not followed at the time of handing it over to
the patient to ensure that the right tray was being given to the
right patient. In the case of the care company, such organisations
also have a duty of care and must be able to demonstrate that
they have the right training and processes in place for their staff
for managing medicines in care settings and administering them
Of the claims resulting from look-alike-sound-alike (LASA) errors,
the most common errors currently resulting in claims involve the
following two drug pairs:
• Amlodipine / amitriptyline
• Risperidone / ropinirole.
For further information please contact the NPA
Pharmacy Services team on 01727 891800 or email at:
Superintendent update on
Following discussions with the
Medicines and Healthcare products
Regulatory Agency (MHRA) and the
Home Offi ce (HO), we clarify the
situation surrounding CBD-containing
products and the controls to which
these products are subjected.
If a product contains any amount (even
trace amounts) of controlled cannabinoids
— such as tetrahydrocannabinol (THC),
even unintentionally — it will be subject
to controls as it would be classifi ed as a
Schedule 1 Controlled Drug (CD) under The
Misuse of Drugs Regulations (MDR) 2001.
Products containing controlled
cannabinoids are only lawfully available
for human consumption if the product is
classified as one of the following:
1. Cannabis-based product for medicinal
use in humans (CBPM). Currently, CBPM
are only available on prescription from a
specialist doctor. As per the defi nition of
cannabis-based products for medicinal
use in humans (CBPM), they would be
classifi ed as Schedule 2 CDs, with the
exception of Sativex which is a licensed
product as a Schedule 4 (Part 1) CD.
2. An exempted product under Regulation 2
of the MDR 2001. The HO has confi rmed
to the NPA that food supplements
containing any amount of controlled
cannabinoids cannot be classifi ed as
The HO has stated that cannabidiol (CBD),
when isolated and in a pure form, is not
subject to controls under The Misuse of
Drugs Act 1971 or MDR 2001. However, it is
very diffi cult to isolate CBD in its pure form
and the HO has raised concerns that many
CBD-containing products (such as those
being sold as food supplements) do not
disclose information on their full contents
that is required to determine the control
status of the product.
The HO has therefore advised caution
based on the following presumption
“that a CBD containing product would be
controlled under the MDA 1971 / MDR
2001 as a result of its other cannabinoid
content”. Furthermore, a Certificate of
Analysis stating the content of controlled
cannabinoids within the product should be
obtained from the manufacturer before a
CBD product is sold or supplied.
• If a product is found to contain any
amount of controlled cannabinoids (for
example, THC), the product must not be
sold as it would be classifi ed as a Schedule
1 CD and such a sale would be illegal.
• The HO should also be alerted.
NPA Insurance has issued the following
statement regarding NPA members selling/
supplying cannabis oil and CBD-containing
products, including those licensed as
medicinal products or classed as food
“Members who are considering selling
or supplying cannabis, cannabis-based
products for medicinal use, cannabis oil
products, or any CBD products or derivatives
must ensure that they ascertain before
doing so the status of such products, and
whether they require a product licence
(marketing authorisation), or otherwise.
“Failure to do so (and to be able to
satisfy this requirement to NPA Insurance),
will mean that in the event that a third
party claim is made against the member’s
professional indemnity policy, or a
request is made by the member for legal
defence or representation to respond to a
Regulatory or Criminal investigation, that
indemnity, legal defence or expenses cover
may not be provided.
“If in any doubt, members are urged to
contact the NPA Pharmacy Services team for
advice in relation to selling or supplying of
any cannabis product, or the NPAI team in
respect of matters of policy cover.
“In terms of the indemnity, this will
be breached where the sale/supply of
the product is illegal both under UK and
EU law, or the product is being supplied
for an unlicensed use, or the necessary
permissions/authority to sell/supply the
product have not been obtained.