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NPA Essential: July

NPA Essential

NPA Essential: July

Things to do and things to know in community pharmacy across the UK

Serious Shortages Protocol following NHS Contract Amendment in England


The National Health Service (Amendments relating to Serious

Shortages Protocols) Regulations 2019 (the NHS SSP 2019) came

into force from Monday 1 July 2019.

These regulations amend aspects of the NHS terms of service for

community pharmacists, NHS dispensing appliance contractors,

dispensing doctors and mandatory terms for Local Pharmaceutical

Services schemes, in relation to SSPs. They also amend the NHS

(Charges for Drugs and Appliances) Regulations 2015 (known as

“the charges regulations”).

SSPs allow for alternative arrangements to be put into place

for supply of a drug or appliance ordered on a prescription where

there is, or may be, a serious shortage of that drug or appliance.

Legislation governing SSPs was introduced in early 2019 as part of

no-deal Brexit planning, but it is not dependent on it.

The Human Medicines Regulations 2012 (known as “the 2012

regulations”) have already been amended under The Human

Medicines (Amendment) Regulations 2019 to allow pharmacists

from a retail pharmacy business to supply a different Prescription-

Only Medicine (POM). The NHS SSP 2019 regulations laid before

parliament now extend the scope of SSPs to all drugs and appliances

that may be dispensed as part of providing pharmaceutical services

in England, not just POMs.


Early May bank holiday 2020 – change

The early May bank holiday is set to move to Friday 8 May 2020

from Monday 4 May 2020 to coincide with the 75th anniversary of

victory in Europe (VE) day on 8 May 2020. The movement of the

bank holiday will allow people to pay tribute to current and previous

members of the UK armed forces. The change in bank holiday is

only applicable to England, Wales and Northern Ireland.

Pharmacy contractors should be aware that the change in bank

holiday may impact normal service and in particular may affect

the dispensing of controlled drug (CD) instalment prescriptions

on days when the pharmacy is closed. The NPA Pharmacy Services

team has developed guidance on the dispensing of instalment CD

prescriptions over bank holidays.


Yellow Card Scheme

The Medicines and Healthcare products Regulatory Agency (MHRA)

is asking community pharmacy teams to share two videos it has

produced, which highlight the Yellow Card Scheme, with patients.

The Yellow Card Scheme is an essential tool that the MHRA uses

to monitor the safety of medicines, medical devices and herbal


NHSmail password validity – extended to 365 days

NHS Digital has reduced the frequency of NHSmail password

changes through a new password policy. The policy has been

changed in line with National Cyber Security Centre (NCSC)

guidance which states that frequent password changes can harm,

instead of improve security.

NHSmail users will receive email reminders to change their

password within 45 days of the policy coming into effect. New

passwords will expire after 365 days instead of the current 90 days.

In addition, they must meet the following requirements:


• Be a minimum length of 10 characters which do not require a mix

of character types

• Not match the previous four passwords

• Not be identifi ed as a common password, eg password123

• Not be identifi ed as a password that has been breached (a

password which was used for a previously compromised account).


NCSC suggests that a memorable and strong password can be

created using three random words which hold personal signifi cance

to the user so that others cannot guess the password.

Pharmacy teams should be aware that failure to change their

passwords following the reminder emails will result in an expired

password which will need to be changed at the next login attempt



For further information please contact the NPA Pharmacy

Services team on 01727 891 800 or email


What independents need from the pharmacy contract in England

The NPA is urging everyone involved in

negotiating the community pharmacy

contractual arrangements for England to:


Be ambitious and don’t accept that

decline is inevitable

This is a significant moment in the long

history of community pharmacy and we

hope all parties to the negotiation will be

ambitious about the future. Decline is not

inevitable. Instead, we want to see techenabled

community pharmacies, better

integrated with other health services,

operating effi ciently as neighbourhood

health and wellbeing centres, providing

excellent patient care and recognised as

the front door to the NHS. The contract

negotiations now underway are a chance to

make a decisive shift, incentivising clinical

services, integrated with safe access to



Be fair to independent pharmacies

The current system does not deliver the

margin element of funding equitably

across the sector. Most independents are

disadvantaged by averaging, because

smaller businesses cannot easily spread

risk or hope to have losses averaged out.

That means they are at the mercy of

factors beyond their control, such as hikes

in medicines prices and branded generic

prescribing. A model in which a smaller

proportion of funding is derived from

margin should be explored.


Provide clarity and certainty

A successful outcome to the negotiations

would include a clear direction on clinical

service development, as well as a multi-year

funding settlement, to give pharmacy

owners the confidence to invest in services

that will meet the priorities described in the

NHS Long Term Plan.


Provide sufficient and sustained

funding for change

Funding has been declining for several

years, despite the increasing cost of doing

business, which has led many pharmacies

to reduce service levels and cut staff. The

current, dire financial situation is a powerful

disincentive to pharmacy owners to invest in

NHS services. More funds should be made

available to community pharmacy where we

can demonstrate that the sector is delivering

on NHS priorities. To make the necessary

investments in staff, services and tech,

pharmacy owners need to know there is a

realistic prospect of a return.


Act with urgency

Day by day, the gap is growing between

what pharmacies have the capacity and

impetus to achieve and what NHS England

wants them to deliver. An urgent response

is required to stop irreparable damage to

the network. One change that could make

a difference relatively quickly is reform of

the concessionary pricing system, to ensure

accurate and prompt payments and give

pharmacies more forward visibility, plus

assurances that they will not be working

at a loss.

The NPA has written to the PSNC with

a more detailed description of how we

view the contractual framework and the

future position of independent community

pharmacy in England.

The PSNC performs its very diffi cult

functions diligently, seeking to balance the

needs of all contractors, so we are confi dent

it will take our views into account as it

continues its negotiations with NHS England

and the Department of Health & Social Care.


NPA at the APPG

The NPA joined other pharmacy bodies

at a recent All Party Pharmacy Group

(APPG) event at the House of Commons

in Westminster to discuss the NHS longterm


The NHS is planning for the next decade but

many pharmacies are currently managing

only on a month-by-month basis because

of overwhelming pressures on their funding

and rising medicines costs.

Mark Lyonette, the NPA chief executive, told

MPs: “A new, multi-year, funding settlement

for community pharmacies in England

is needed, to give pharmacy owners the

confidence to invest in services that will

meet the priorities described in the plan.”


Community pharmacy sector

concerned about new tax proposals

The NPA, alongside the Company Chemists’

Association (CCA), the Association of

Independent Multiple Pharmacies (AIM), the

Royal Pharmaceutical Society (RPS), Team

Locum and Locate a Locum have issued a

joint response to an HMRC consultation

highlighting concerns about how proposed

changes to tax law might impact the sector.

HMRC consulted on its proposals for

implementing changes to tax law known

as IR35, or “off-payroll” working rules,

between 5 March to 28 May 2019.

From April 2020, medium and large

businesses (companies employing more

than 50 people) will become responsible

for assigning the tax status of locums

contracted through their own limited

company, to refl ect the correct employment

status position.

However, there are other changes taking

place with HMRC conducting a wider review

of the use of self-employed locums which

could affect a larger proportion of the sector

than the IR35 reforms.

Our response to the off-payroll

consultation identified that:

• HMRC needs to ensure that the Check

Employment Status for Tax tool (CEST),

which is being promoted as the means

of determining tax status, is fit for

purpose. We believe that this tool is not

refi ned enough to meet the needs of the

community pharmacy sector. Those using

the tool need to be confi dent that it’s

accurate and fair in all cases.

• We have signifi cant concerns that,

following these reforms, the flexibility of

the pharmacy workforce may be affected

to the extent that it disrupts the necessary

supply of medicines and services to


• The IR35 reforms are complex changes

which will be diffi cult to embed across the

diverse populations of workers that exist

in the private sector.

We need HMRC to provide a detailed

timetable for rolling out the reforms and

clear, ongoing, communications about

how to prepare.


What actions should locums and

‘engagers’ (or employers) take?

Don’t assume your tax status if you’re

self-employed or a locum. If you are an

employer, don’t assume the status of those

you engage.

• Make yourself aware of what your

CEST determination is. Access it here:


• Visit the government’s website and read

about IR35:


• Read the HMRC’s guide for organisations

that sets out what actions they should be

taking now to prepare for the changes

ahead of April 2020. You can fi nd this at


• Keep an eye out for further messaging

including the HMRC’s publication of draft

legislation and the summary of responses

to the consultation.


IR35 regulations

Many people today choose to work in a

more fl exible and diverse way. This can

mean that determining the employment

status of workers who are directly

contracted or engaged via third party

service providers has become more complex.

Employment status can have an impact on

the way in which tax and national insurance

is paid and, in some cases, the amount

paid. The IR35 regulations were introduced

in 2000 to address this variation and bring

equity between the amount of tax paid by

employed and off-payroll workers for doing

the same role, in the same conditions.


Off-payroll working

Employed pharmacists pay their tax through

salary deductions and the ‘pay as you earn’

(PAYE) system. Many pharmacy contractors

use locums to provide ad hoc cover for the

duties of employed pharmacists. Locums

may be working ‘off-payroll’, either as selfemployed

individuals or through personal

service companies they’ve set up and,

currently, they are responsible for determining

the employment status of their engagement.


Changes to the IR35 regulations

The Chancellor announced reforms to

the IR35 regulations in 2018 to increase

compliance and bring the private sector

into alignment with the public sector. From

April 2020, medium and large businesses

(companies employing more than 50 people)

will become responsible for assigning the tax

status of locums contracted through their

own limited company, to refl ect the correct

employment status position.


For more information, please

contact the NPA’s Employment

Advisory Service on 0330 123 0558 or


The NHS issued guidance for local pharmaceutical committees

on how to help contractors get involved with primary care

networks (PCNs)

NHS England and NHS Improvement want LPCs to help

pharmacies “on a local footprint” to engage collectively with a

PCN, by:


• Engaging with CCGs and local medical committees.

• Starting the conversation with local contractors.

• Understanding mutual benefi ts and local priorities.

• Agreeing ways of working between community pharmacies. There

are expected to be an average 10-11 pharmacies per PCN.


An NPA spokesperson said: “The fact that the NHS has issued

this guidance to LPCs shows that it sees community pharmacy as

a signifi cant player and wants community pharmacies to be fully

engaged with PCNs when the time is right. This guidance suggests

sensible preparatory steps for LPCs to take and we look forward

to further guidance in due course. We don’t yet have a complete

roadmap to PCN engagement, but in truth there is bound to be an

element of learning as we go. What’s important at this stage is to

make a start. This is a good start.”

According to the guidance, the opportunities for integrated

working with PCNs will include:


• Urgent care and minor illness

• Prevention and public health

• An increased clinical role

• Medicines safety and optimisation.


Collaboration with non-GP providers, such as community

pharmacies, will be a requirement for PCNs from April 2020.

A further briefing aimed at pharmacists and pharmacy technicians

across the NHS, including those working in community, general

practice, mental health, care homes, hospitals and commissioning

organisations, has also been published on the NHS England website.

It states: “As community pharmacy focuses more on its clinical role

of managing the minor illness aspects of urgent care; helping to

improve safety, outcomes and value from medicines; and supporting

patients to prevent ill health, it will need to have strong links with

PCN clinical pharmacists.”

NPA members may know that Michael Lennox, the chief officer of

Somerset LPC, is working with the NPA, on a part time basis, to help

independent community pharmacists get to grips with emerging

NHS structures such as PCNs and integrated care system (ICSs) at a

local level. At the same time Michael has a part time role at PSNC

where he will be helping to shape its PCN strategy and support for

LPCs. This should facilitate further close working between the NPA

and PSNC and ensure that our PCN support is all aligned. Michael

will help the NPA to:


- Support independent representatives on LPCs.

- Inform and educate NPA members about the opportunities and

threats that exist within the NHS long-term plan, the GP contract

and the development of integrated care systems.

- Work co-operatively with the National Association of Primary

Care and others on a joined up plan to help the sector make the

most of the long-term plan.


Go to to see

the NPA’s lastest webinar on primary care integration.



How to have a stress-free summer

As an employer, you may be anxious

about the chaos that this time of year

can bring.

Between weddings, barbeques and

trips abroad, work can often take a back

seat, leaving you to deal with a loss of

productivity and costly absences.

Here’s some advice on overcoming

summer HR challenges.


1. Distracted employees

With better weather and a jam-packed

sporting calendar, employees may be

more tempted to pull out their phones to

check the latest score or make plans for

after work.

It’s important to have a clear policy on the

use of mobiles phones. You may wish to:


• Restrict the use of mobile phones to rest

breaks or emergencies.

• Require that phones are kept on silent or

switched off during working hours.

• Ask that employees leave their phones in

a locker or staff room.


Of course, you may want to take a more

generous approach by allowing employees

to watch an important match as a one-off

social event or permitting an extra-long

lunch break.


2. Employees pulling sickies

If you suspect that a ‘sick’ employee is, in

fact, making the most of the weather, avoid

making allegations without clear evidence.

By jumping to conclusions, the employee

may have grounds to suggest that such

allegations constitute a breach of trust and

confi dence, and could make a claim for

constructive dismissal if they have been

employed for more than two years.

If you do have clear evidence, such as

photographs on Facebook, this should be

dealt with as a disciplinary issue.


What can I do?

Taking proactive steps to discourage

absences will avoid having to resort to

sleuthing on social media. Consider:


• Improving visibility by ensuring line

managers log all absences, including

reason and duration.

• Measuring and reporting on absence

by calculating employees’ Bradford

Factor scores, which will highlight repeat

instances of short-term sick leave.

• Conducting return to work interviews

to show employees that their absences

have been monitored, that managers

are recognising specifi c trends and that

disciplinary action may be taken.


3. Hungover employees

What employees do in their own time is up

to them; however, if they turn up to work

hungover, it immediately becomes your



What can I do?

As summer approaches and there are more

occasions to drink, minimise disruption to

your pharmacy by:


• Reminding employees that alcohol can

stay in the bloodstream for up to 24 hours

and that drinking heavily may render them

unfit for work.

• Creating an alcohol policy that outlines

what constitutes a violation and clearly

explains the consequences.

• Keeping written records of incidents to

support disciplinary action if required.


For advice on overcoming summer

employment challenges, contact

the NPA Employment Advisory

Service on 0330 123 0558 or email


Sign up for the NPA’s pharmacy

undergraduate training programme

The NPA’s pharmacy undergraduate training programme is

open for enrolments.

The course has been created to enable pharmacy employers to

provide a structured training programme for undergraduates in

their fi rst, second or third year. This allows community pharmacy

employers to provide quality placements and attract the highest level

of candidates as future pre-registration students.

In addition, the NPA will also incorporate training material to help

these students better prepare for Oriel assessments, if they choose

to broaden their recruitment options for their future pre-registration

placements both within and outside of community pharmacy.

This course provides pharmacy undergraduate students

undertaking placements or employment in community pharmacies

with essential knowledge and skills in relation to:


• Practice

• University exams

• Pre-registration training

• Obtaining a pre-registration placement (including Oriel).



After completing this course, students will be:


• More confident about working on the medicines counter and

within the dispensary, both as an undergraduate and preregistration


• More competent in working in the community pharmacy aiding

both safety and effectiveness.

• More prepared for applying for pre-registration placements and

undergoing university exams.



Pharmacy undergraduate students working in pharmacies, whether

this is during summer holidays or as a part time/weekend employee.



This modular learning programme is divided into three parts which

can either be completed in a single placement or spread over

multiple placements, dependent on the individual requirements of

the undergraduate student and the pharmacy.

The structure of this course is as follows:


• Module 1: Pharmacy practice skills.

• Module 2: Pharmacy practice knowledge.

• Module 3: Pharmacy job application skills.



At the end of modules 1 and 2 there will be a multiple choice

assessment to test a student’s knowledge on the content they have

covered. Module 3 also contains helpful information on multiple

mini interviews, situational judgement tests and numeracy tests.

The supervising pharmacist/tutor is expected to support the

student throughout the course, review their answers, mark their

assessments and provide constructive feedback.

The NPA serves to assist community pharmacy employers

recruiting both within and outside of the Oriel system. For those

employers that have opted out of Oriel, the NPA is offering

assistance to advertise independently via the website (www.npa.

Louise Baglole, head of learning and development, said: “The

NPA’s pharmacy undergraduate training programme is a great way

for community pharmacies to support students on placements. Over

the last few years, some community pharmacies were disappointed

not to be allocated a pre-registration student via the Oriel process

– supporting a student with a quality placement earlier on in their

studies may help them to secure that student as a pre-registration

trainee in the future.”


Veterinary CD prescriptions (UK)

In recent weeks, there has been a significant increase in

requests from pharmacists for information relating to legal

requirements for veterinary prescriptions, particularly those

involving Controlled Drugs (CDs). This has been more apparent

since the reclassifi cation of pregabalin and gabapentin.

Furthermore, the Veterinary Medicines Directorate (VMD) has

recently released a summary of responses to a survey conducted on

the disposal and use of CDs.

The legal requirements for a veterinary prescription are stated in

Schedule 3 Part 1 of The Veterinary Medicines Regulations 2013. In

addition, the Royal College of Veterinary surgeons (RCVS) guidance

states veterinary prescriptions for Schedule 2 or 3 CDs must also



• The Royal College of Veterinary Surgeons (RCVS) registration


• A declaration that the product has been prescribed for treatment

of an animal or herd under the care of the prescriber.

• Details of the prescribed CD(s).

o Strength must be stated where more than one exists.

o The quantity – this must be written in words and figures.

• The dose to be administered (must state an amount and a

frequency- ‘take as directed’ would not be acceptable).

*Currently this is not a legal requirement in Northern Ireland.


One of the most common queries with regard to the use of a

standardised CD prescription forms for veterinary use.

There is no requirement for a standardised form to be used for

veterinary purposes as there is for human use (eg FP10PCD,


Some of the other common queries received by the NPA are

shared below.


Can I dispense CDs from a faxed, electronic or A

emailed veterinary prescription? 

No. A faxed, electronic or emailed prescription is not a

legally valid prescription, therefore a supply of Schedule

2 and 3 CDs against a faxed, electronic or emailed prescription

is not permitted. The original prescription must be obtained

before dispensing the medicine.


How long are veterinary prescriptions for CDs valid


Veterinary prescriptions for Schedule 2, 3 and 4 CDs are

valid for 28 days from the appropriate date; Schedule

5 CDs are valid for six months from the appropriate date.

Schedule 1 CDs are not used in veterinary medicines.


Are repeatable veterinary prescriptions allowed

for CDs? 

Repeatable prescriptions (single prescriptions with

multiple dispensing) for Schedule 2 and 3 CDs are not

allowed. Veterinary repeatable prescriptions for Schedule 4 CDs

are only valid for 28 days. All repeats must also be dispensed

within 28 days of the appropriate date. This only applies to

veterinary repeat prescriptions and is different from repeat

prescriptions for Schedule 4 CDs for humans.


Can instalments be prescribed on a veterinary CD


Yes. Schedule 2, 3, 4 and 5 CDs are permitted

to be prescribed as instalments on veterinary

prescriptions as long as:


• The instalment quantity to be supplied is stated

alongside the dispensing interval and dose.

• The first instalment must be dispensed within the

prescription validity period of 28 days for Schedule

2, 3 and 4 CDs – further instalments can be dispensed

outside this period.


How long do we need to retain veterinary CD

prescriptions for? 

All veterinary prescriptions (including those for CDs)

must be retained on the premises from which it was

dispensed for at least five years from the date of supply.


Is there a maximum quantity that can be prescribed

on a veterinary CD prescription? 

The VMD recommends prescribing CDs for a maximum

period of 28 days treatment unless it is for the treatment

of a long-term condition (for example, epilepsy in dogs). Where

more than 28 days treatment is prescribed, the prescriber must

be satisfi ed that the owner is able to use the medicine safely.


Can I supply a CD to veterinary surgeon on a signed


It is a legal requirement* for veterinary practitioners

to use the relevant mandatory requisition form when

requisitioning Schedule 2and 3 CDs from pharmacies as follows:


• England – FP10CDF.

o This can be downloaded from the NHS Business Services

Authority (NHSBSA) website.

o The FP10CDF is not required to be sent to the NHSBSA; it

should be retained on the pharmacy premises for 5 years.

• Wales – WP10CDF should be used.

o This can be obtained from the local Business Service Centre


• Scotland – CDRF.

o All private prescribers (including veterinary practitioners)

are required to join the Prescriber List for CDs. When

approval has been granted by the local health board, a

‘unique prescriber code’ is generated and the veterinary

practitioner can then purchase CDRF forms.

*Northern Ireland – In Northern Ireland there is currently no

standardised requisition form available.


The veterinary prescriber must include the following particulars

on a CD requisition:


• Name, address and profession of the recipient.

• Purpose for which the drug is to be supplied.

• Name, form, strength and total quantity to be supplied.

• Signature of the prescriber.


These FAQs were correct at the time of publishing. To read more visit


Serious shortages protocol

following NHS contract amendment

in England

From a community pharmacy

perspective, a number of key changes

are introduced under the NHS SSP

2019 regulations. Please note that

these changes relate specifi cally to the

provision of NHS services and dispensing

of NHS prescriptions in England only.

Key changes:


• NHS pharmacists “must consider whether

it is reasonable and appropriate to supply

in accordance with the SSP instead of in

accordance with the prescription form

or repeatable prescription.” A different

product or quantity or both may be

provided if in the professional judgement

of the pharmacist it is appropriate and

reasonable to do so with reasonable

promptness and in accordance with the SSP.

• Pharmacists must notify the patient’s GP

if the product provided in accordance

with the SSP is a POM that is different

to but has a similar therapeutic effect

to the product originally prescribed.

Furthermore, in other cases of supplies

made under SSPs, the patient’s NHS GP

practice must also be notifi ed if such a

requirement is implemented for clinical

reasons (further clarifi cation will be

provided on this in due course).

• When a SSP is in effect for a drug or

appliance prescribed on a prescription

form, but in the opinion of the registered

pharmacist, supplying a different product

or quantity would be inappropriate or

unreasonable, the pharmacist is able

to supply the product ordered on the

original prescription — even if the

pharmacist is able to supply this within

a reasonable timescale, but not with

reasonable promptness; their terms of

service will not be breached by doing

so. These amendments have removed

the need for supply to be made with

reasonable promptness where an SSP is in

place; instead, the supply should be made

within a reasonable timescale (this has not

been defi ned in measurable terms).

• Furthermore, where the requested drug

or appliance is covered under a SSP,

but in the pharmacist’s professional

judgement it is not appropriate or

reasonable to provide an alternative

product or quantity to that ordered,

and the pharmacist is unable to provide

the product ordered on the original

prescription within a reasonable

timescale – the pharmacist may simply

refuse to provide the drug or appliance

ordered. In such cases, the NHS

pharmacist must provide the patient (or

representative) with appropriate advice

about returning to the prescriber to

review the patient’s treatment.

• When a product is supplied under the

SSP, a notifi cation to this effect must

be included in the dispensing label on

the packaging of the product supplied,

including identifi cation of the particular


• Where a different drug or appliance has

been provided under the SSP covering

the drug or appliance requested on

the original prescription form, the NHS

pharmacist cannot make the supply under

the original prescription form in addition

to that made under the SSP.

• In parallel to the NHS SSP 2019

regulations, amendments have been

made to the Charges Regulations when

a product is supplied in accordance with

a SSP. The original prescription form,

when endorsed, will be repurposed for

recording the SSP supply for prescription

charge exemption and remission of

charges. Furthermore, for patients who

would normally pay a prescription charge,

no prescription charge will be payable

when a supply is made in accordance with

a SSP for a smaller quantity of a drug or

fewer appliances supplied.

• Under transitional arrangements, a

separate token (“a dispensing token”)

is to be used to record supplies made

under SSP. This is for the purposes of

prescription charge exemptions, remission

of charges and reimbursement. Further

guidance and clarifi cation on a number of

operational and legislative aspects related

to SSP will be available in due course.


From an indemnity perspective, NPA

professional indemnity insurance will

cover NPA members, customers (and

the pharmacists they employ/engage)

when supplying medicines/appliances

under the relevant enabling legislation

and the serious shortages protocols

(SSPs) which apply. It is acknowledged

pharmacists will be expected to exercise

professional judgement to determine the

appropriateness of making each supply.


For further information please

contact the NPA pharmacy services

team on 01727 891800 or email at:



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NPA Essential