1. Objective Setting:
   • Define the scope and objectives of the penetration test. Focus on systems that store, process, or transmit patient data, including pharmacy management systems, electronic health records, and online prescription services.
2. Compliance Considerations:
   • Ensure the test aligns with NHS and General Pharmaceutical Council (GPhC) guidelines.
   • Understand the requirements of the DSPT and the UK’s General Data Protection Regulation (GDPR).
3. Choosing a Testing Provider:
   • Select a reputable and certified penetration testing provider.
   • Ensure they have experience in healthcare and are aware of the specific needs and regulations of the sector.
4. Pre-Test Preparations:
   • Notify all relevant parties, including staff and possibly the Information Commissioner’s Office (ICO), if required.
   • Back up all systems and ensure that there are contingency plans in place in case of system disruptions.
5. Conducting the Test:
   • Perform the test during off-peak hours to minimize disruption.
   • Include both external (networks, applications, and perimeter defenses) and internal (behind the firewall) aspects.
   • Test for a wide range of threats, including SQL injection, cross-site scripting, and ransomware.
6. Data Handling:
   • Ensure that all data collected during the test is handled securely and in compliance with GDPR.
   • Sensitive data should not leave the premises or be exposed to unauthorized personnel.
7. Post-Test Analysis:
   • Review the test results with the testing provider.
   • Prioritize vulnerabilities based on their potential impact and the likelihood of exploitation.
8. Remediation Plan:
   • Develop a prioritized action plan to address identified vulnerabilities.
   • Consider both technical fixes and changes in processes or staff training.
9. Documentation and Reporting:
   • Document the entire process and results for compliance purposes.
   • Report significant vulnerabilities and incidents to the relevant authorities as required by law.
10. Review and Continuous Improvement:
    • Schedule regular penetration tests (at least annually).
    • Review and update security policies and procedures in light of test findings.

Additional Considerations:

• Staff Awareness and Training: Ensure staff are aware of the test and understand the importance of cybersecurity.
• Legal and Ethical Considerations: The test should be legal, ethical, and not harm patients or their data.
• Budget and Resources: Allocate sufficient budget and resources for both the test and the subsequent remediation actions.

Remember, the specifics of the plan will vary based on the size of the pharmacy, the complexity of its IT systems, and the types of data handled. It’s also important to stay updated with NHS and GPhC guidelines, as they may change over time.

i. What their key operational services are,

ii. What technologies and services their operational services rely on to remain available and secure,

iii. What other dependencies the operational services have (power, cooling, data, people etc.),

iv. The impact of loss of availability of the service.

Understanding Health and Care Services Provided by [Organization Name]

I. Key Operational Services:

[Provide a comprehensive list of the key operational services offered by the organization. These services are at the core of the organization’s mission and activities. For example:]

1. Patient Care: Delivering medical care, diagnosis, and treatment to patients.
2. Prescription Management: Ensuring the accurate dispensing of medications to patients.
3. Medical Records Management: Maintaining and safeguarding patient health records.
4. Appointment Scheduling: Facilitating patient appointments with healthcare professionals.

II. Technologies and Services Dependencies:

[Detail the technologies and services that are crucial for the availability and security of the key operational services. For example:]

1. Electronic Health Records (EHR) System: A secure EHR system is essential for managing patient data and ensuring its availability to healthcare providers.
2. Pharmacy Management Software: Reliable software for prescription management, inventory control, and patient interactions.
3. Telecommunication Infrastructure: Ensuring a stable network for telehealth services and communication between healthcare providers.
4. Cybersecurity Solutions: Implementing robust cybersecurity measures to protect patient data and maintain service availability.

III. Other Dependencies:

[Identify other dependencies beyond technology that are critical for operational services. These may include power, cooling, personnel, and more. For example:]

1. Power Supply: Reliable and uninterrupted power is necessary to run medical equipment, computers, and communication systems.
2. Cooling and Environmental Controls: Maintaining suitable environmental conditions for sensitive equipment and medication storage.
3. Qualified Healthcare Staff: Having a skilled and adequately staffed healthcare team to deliver patient care and manage operations.
4. Supply Chain Management: Ensuring a steady supply of medications, medical equipment, and other essential materials.

IV. Impact of Loss of Availability of the Service:

[Describe the potential consequences and impact on patients, staff, and the organization if the key operational services become unavailable. This may include:]

1. Patient Safety: Disruption in healthcare services may jeopardize patient safety and well-being.
2. Data Security: A loss of availability can lead to data breaches and compromise patient privacy.
3. Reputation Damage: Service unavailability can harm the organization’s reputation and trust among patients and stakeholders.
4. Financial Implications: Loss of revenue, fines, and legal liabilities resulting from service unavailability.
5. Operational Disruption: Delays in patient care, appointment cancellations, and increased workload on staff.

[Include any additional information specific to your organization’s services and dependencies.]

This document serves as a foundational understanding of the critical elements related to health and care services provided by [Organization Name]. It highlights the importance of safeguarding these services, their dependencies, and the potential impact of service unavailability on patient care and the organization’s overall performance.

Pharmacy near Edgware rd (1^st inspection)

Summary of GPhC findings:

• The pharmacy cannot clearly demonstrate how it manages the risks associated with the prescribing services it operates.
• It does not have comprehensive procedures explaining how this service operates and there is no evidence that it has been properly risk assessed.
• Its system for handling complaints is unclear
• The pharmacy’s record keeping does not always comply with the law and there is a lack of documentation supporting the pharmacist prescribing service.
• The team members keep people’s personal information secure and they understand the principles of safeguarding and how to support vulnerable people.
• The pharmacy SOPs had been recently updated but they did not cover some aspects of the pharmacy’s services, such as the private doctor and pharmacist prescriber consultation, so it was not totally clear how these operated or what the parameters for offering these services were.
• It was unclear if the private doctors’ service was registered with the Care Quality Commission.
• The superintendent explained he did use a prescribing framework and he would only prescribe for adult patients who were mainly from overseas and requested medication they had used before or for treating minor acute conditions.
• And some SOPs lacked detail; for example, the SOP for record-keeping did not explain how records were maintained.
• Some team members had signed SOPs to show they had read and agreed them, but others had not, so some they might not always fully understand their roles and responsibilities.
• A privacy notice was not displayed in accordance with the General Data Protection Regulation.
• Records relating to pharmacist prescriber consultations were not available although the superintendent said he did document all consultations.

Improvement action plan:

• Complete comprehensive procedures explaining how the prescribing services operate including SOPS and prescribing clinical framework
• Practice good risk management by providing staff training protocols for proper assessment triage and signposting for the prescribing service and other related medical services
• Review record keeping procedures to ensure full record keeping is maintained including new electronic patient records and review of complaints procedures.

2^nd inspection

• Prescribing framework reflecting therapeutic areas covered by the prescribing service included but not limited to high-risk drugs.
• Risk assessment does not identify all therapeutic areas covered by prescribing service, classes of meds included or key risks involved and a plan explaining how these are mitigated. Also does not routinely assess safety and quality of its prescribing service, does not hold consultation notes which means can not demonstrate that prescribing decisions are appropriate.
• Does not have appropriate safeguards in place to prescribe some higher risk categories of meds i.e. CDs.
• Prescribing framework that includes all conditions that medication is prescribed for i.e. mental health, weight loss.
• Pharmacy had a risk assessment which identified some areas of risks in prescribing service and how to mitigate them but not individual risk assessments.
• Not completed any clinical audits of prescribing to determine whether it was safe and appropriate.
• People asked to complete consultation form, ID was checked then consultation carried out by prescriber and any additional notes were added to form? IP were usually not initiating treatments, patients usually presenting with old medication packs or documentation which was double checked were possible and if necessary with their practitioner? If any CDs prescribed which they rarely are, a maximum of 30 days supply given? (Needs to be mentioned on prescribing SOPs)

Improvement action plan:

1. Create a risk mitigation plan for each therapeutic area. Develop risk assessments specifying each therapeutic areas the prescriber(s) will be prescribing within and the classes of medication included for each, and identify the likelihood of key risks for each, the likely impact and a written plan on how these risks are mitigated.
2. Consultation records will be updated, at minimum every week, using the digital patient management software. All clinic records will be available upon inspection.
   Clinical audits will be made on a regular basis, starting with high-risk therapeutic areas.
3. The prescribing framework will be updated to reflect the therapeutic areas covered by the prescribing service including but not limited to high-risk categories. Prescribing of CDs will follow UK guidelines. Prescribers will have access to the patient’s medical records or contact the person’s usual doctor before prescribing CDs. And no more than the recommended 30 days’ supply of CDs will be issued unless in exceptional circumstances.

All patients that are to receive medication from the pharmacy’s independent prescriber or private doctor will be consulted on the important maintenance of an up-to-date medical record with their regular doctor. Consent will be requested from the patient to inform their regular doctor of any medication prescribed on their behalf. In the instance that consent is not given for any reason from the patient, the patient should be asked if they wish to be provided with a copy of a letter that would otherwise be given directly to their regular doctor in order for the patient keep their doctor up to date with medication being prescribed.  From previous visit the year before, seems this has been ongoing issue hence led to the above improvement action plans.

The pharmacy would be expected to tell us within 5 days of the action they intend to take to meet the standards and improve practice in the pharmacy. We will consider some flexibility in this timescale if there are exceptional reasons why this deadline cannot be met.

We require improvement action plans to be filled in by the owner and superintendent pharmacist and returned to us. The inspector will already have identified whether the improvement action in relation to each standard, must be completed within 10, 20 or 60 working days

Then schedule another visit at 6 months after to make sure all changes have been sustained and inspector is happy, at which point new report is generated.

Pharmacy No.2

• Audited each others prescribing, however, audit was lacking number of prescriptions audited, which guidance they were working in line with, parameters they were auditing against, which guidance was used for people from abroad?
• Risk of this service, identify specific risks i.e. following up, monitoring, ensuring no interactions or contraindications, how would practitioners abroad be aware of what has been prescribed to patient etc.
• Which medications does the pharmacy consider as high risk give examples.
• SOP covering independent prescribing was reviewed and updated.
• Prescribing policy not comprehensive, state which guidance is being complied with, maximum supplies within any given time frame and monitoring required.
• Near misses need to be formally reviewed.
• Records for unlicensed specials dispensed were not always completed in line with MHRA guidance. Some certificates of conformity could not be found whilst others were not filled in.
• One dispenser was responsible for reviewing notes and prescriptions every month to check for missing items or information.
• Both prescribers were reviewing each other’s prescriptions every quarter, they checked each other’s notes were complete, monitoring parameters had been noted, counselling was provided and references used such as published guidance.
• A complaints procedure was in place. Members of the team said that they would refer people to the pharmacist if they wished to raise a complaint.
• All staff had completed online training and MCQs on GDPR. Staff briefed on safeguarding and told to raise any concerns directly to pharmacists
• Systems it uses to verify authenticity of overseas? Consultations were still conducted by the pharmacists even when a prescription from a doctor was seen. High-risk medications were never initiated, only prescribed if prescription from patient’s doctor was provided.
• IP did not routinely share information with the patient’s doctors as most were abroad. Example of refusing to supply Lithium to patient in Kuwait, then patient came back with up to date bloods which were documented at the pharmacy, before supply was made, how can you be sure it was there bloods done etc?
• Labelling and counselling points regarding sodium valproate
• Patients asked to do urine dipstick test before prescribing antibiotics for UTIs, example were they prescribed only three days worth of Nitrofurantoin to patient with recurring UTI (example to show that they know some stuff) spoke to her regular pharmacist to confirm previous supplies and referred her back to her GP (again example he knows hes doing diligence and also signposting back).

Improvement action plan:

1. Have proper insurance for prescribing
2. Revised Prescribing Policy
   – Revised Prescribing Audit template

Pharmacy 3

Below is a summary of the inspection report from the primary visit by the GPhC.

• Did not have proper SOPs.
• Pharmacy cannot demonstrate that the private Dr service that it works with is meeting the regulatory requirements.
• Pharmacy’s information governance and safeguarding procedures lack formality.
• Most SOPs overdue review and out of date might not reflect current legal requirements or best practice, some duplicated or not relevant to Pharmacy’s current activities
• No policies or procedures explaining how they work with private Dr or the scope of pharmacist prescribing services.
• Pharmacy currently working with a private Dr but he was not working for the pharmacies CQC registered service.
• Pharmacy did not have any record of dispensing incidents, the last entry in near-miss log in 2018.
• Dispensing labels not always signed by pharmacist.
• Complaints procedures not always promoted in pharmacy or on website, so people may not know how to raise concern,
• Pharmacy did not always use mechanisms to actively seek feedback about pharmacy’s services, so it might miss opportunities to make improvements. Also give examples of what we have done as a result, this can be used to kill time.
• Unlicensed medicines were sometimes supplied on prescription and the pharmacy maintained appropriate records.
• Team members briefed on principles of data protection and confidentiality
• There were no formal information governance policies so risk as staff may not fully understand their responsibilities.
• SI stated they had completed safeguarding training some years ago but had no evidence of this.
• Pharmacy’s website did not include GPhC no. or superintendent’s details, promoted clinic with GMC Drs but did not provide any details, absence of information did not support people to make informed decisions when opting to access the pharmacy’s services.

Improvement action plan

1. The pharmacy cannot demonstrate that its pharmacist prescribing service is operating safely. It does not have SOPs or a prescribing framework covering this activity. And it hasn’t completed risk assessments for this service identifying the therapeutic areas and classes of medication included, or the key risks involved, with a plan explaining how these risks are mitigated.
2. The consultation records for the pharmacist prescribing service do not contain enough information to support prescribing decisions.
3. The pharmacy’s prescribing service does not have sufficient safeguards in place to provide assurance that medicines are always prescribed safely. It cannot demonstrate how it verifies information about the patient and their existing health conditions or communicates with their usual doctor to ensure the continuity of their care. And it cannot show that prescribing of CDs in line with UK guidelines.

Action taken by pharmacy – Pharmacist prescribing service suspended

“the uninterrupted provision of essential services, during the opening hours of the premises, to persons anywhere in England who request those services, and”

A good reply to this comment would be…

We confirm that we shall comply with the above referenced regulation:

We further confirm that as a distance-selling pharmacy, we will provide uninterrupted service throughout the opening hours of the pharmacy. For this reason, the responsible pharmacist (RP) is not allowed to leave the premises in the same way as an RP at a Non-Distance Selling pharmacy is allowed (for up to 2 hours per day) unless another pharmacist is present. The pharmacy will have a second pharmacist available during the core and any additional hours that it operates. Any breaks in working time taken by the RP will be covered by a second pharmacist who will then assume the responsibility of the RP. NHS Essential services will be provided to any patient living in England who requests services. Nothing in our practice leaflet, publicity material, in the material published on our behalf, any communication is written or oral or from our members of staff to any person seeking the provision of essential services will represent, either expressly or impliedly, that:

a) the essential services provided at or from the premises are only available to persons in
particular areas of England, or
b) we are likely to refuse, for reasons other than those provided for in our terms of service,
to provide drugs or appliances ordered on prescription forms or repeatable prescription
forms which are presented by particular categories of patients (for example, because the
availability of essential services from us is limited to other categories of patients.)

If you need further help in replying to an NHS rejection letter get in contact with one of our representatives here.

Examples of tasks that may be covered by SOPs in a pharmacy include:

• Receiving and processing prescriptions
• Dispensing medications
• Providing patient counselling
• Handling and disposing of hazardous materials
• Processing insurance claims
• Maintaining accurate records
• Managing inventory
• Training new staff

SOPs are typically developed by the pharmacy management or by a designated SOP committee, and they may be reviewed and updated on a regular basis to reflect changes in laws, regulations, or best practices. SOPs are important because they help to ensure that tasks are performed consistently and accurately, and they can also serve as a reference for staff when they are performing unfamiliar tasks or procedures.

Overall there is a wide range of SOPs, below is a list of the most important ones used in healthcare:

COVID Vaccine Clinic Standard Operating Procedures including:

• COVID-19 Pharmacy Vaccination Services
• COVID-19 Social Distancing and Infection Control Risk

Prescribing Specific Standard Operating Procedures including:

• Referral Criteria Policy
• Chaperoning Policy
• Safeguarding and protecting people from abuse policy (adult protection/child protection)
• Privacy, dignity and respect of service users
• Medication policy (dispensing process)
• Information management policy
• Infection prevention and control
• Participation policy
• Complaints policy
• Duty of Candour policy
• Recruitment and induction policy
• Staff training and development policy
• Bullying and harassment policy
• Whistleblowing policy
• Equality and Diversity Policy
• Clinical governance policy
• Staff Handbook

Pharmacy and Medical Standard Operating Procedures including:

• Fire Risk Assessment
• Arrangements for dealing with emergencies including resuscitation
• Care Quality Commission Governance (CQC Care Providers only)
• Statement of Purpose
• Patient Guide
• British Code of Advertising
• Patient Disclaimer
• Disability and the Equality Act 2010
• Seeking Clients’ Consent
• Complaints Procedure
• Whistle Blowing Policy
• Confidentiality Policy
• Clinical Governance
• Clinical Audit
• Safeguarding Policy
• Stress Management
• Sickness and Absence Policy
• RIDDOR Procedure
• Policy on violent or abusive patients
• Mental Capacity
• Medicine Incident Reporting Policy
• Medication Review Policy
• Protocol for the Identification of Patients with Learning Disabilities
• Electronic Transfer of Patient Data Policy
• Medicines Safety Alerts Policy
• Disciplinary Policy
• Disclosure and Barring Policy
• Computer Misuse Policy
• Computer and Data Security Procedure
• Caldicott Protocol
• Business Continuity Plan
• Repeat Prescription Rationalisation (‘Tidy-Up’) by Medicines Management Team in Primary Care
• Pre-Agreed Practice Specific Medication Switches to the Health Board Preferred Generic, Brand or Branded Generic by Medicines Management Team in Primary Care
• Updating Repeat Medication from Community Pharmacy Medication Use Review by Medicines Management Team in Primary Care
• Adding the Medication of a Newly Registered Patient onto the Repeat Prescription by Medicines Management Team in Primary Care
• Medicines Reconciliation from Hospital Outpatient Documentation by Medicines Management Team in Primary Care
• Medicines Reconciliation from a Hospital Discharge Notification by Medicines Management Team in Primary Care
• Domiciliary Medication Adherence Assessment by Medicines Management Team in Primary Care
• Level 2 Medication Review (including repeat medication reauthorisation) by Medicines Management Team in Primary care
• Level 3 Medication Review (including repeat medication reauthorisation) by Medicines Management Team in Primary Care
• Memorandum of Understanding with the Medicines Management Team
• Wholesale Dealers Licence Overidding Single Pharmacy
• Supplying Specific Products (GPhC Registration Holders only)
• Supply of Insulin
• Supply of Lithium
• Supply of Methotrexate
• Supply of Oral Anticoagulant Medication
• Supply of Paraffin Based Skin Products
• Sale and Supply of Veterinary Medicines
• Supplying Oral Anti-Cancer Medicines
• Information Governance (All Healthcare Providers)
• Summary Care Records Privacy Officer
• Staff Confidentiality Agreement
• IG Policy
• Code of Conduct for Employees in Respect of Confidentiality
• Data Handling Procedures
• Mobile Computing Guidelines
• Information Security Incident Management
• Access Control and Password Management Procedure
• Ensuring Staff Compliance with RA01 Terms Template SOP
• GDPR Privacy notice for employees workers and contractors UK
• Privacy Statement for GDPR
• Add New File
• Staff Induction (All Healthcare Providers)
• Locum Induction
• Staff Induction
• Signposting (GPhC Registration Holders only)
• Signposting
• Private Services (GPhC Registration Holders only)
• Salbutamol Supply to Schools
• Blood Diagnostics via Finger Prick
• Dispensing Private Prescriptions
• Operational (All Healthcare Providers)
• Cleaning
• Cold Chain Maintenance
• Equipment Maintenance
• Health and Safety – Risk Assessment
• Internet Pharmacy (GPhC Distance Selling Registration Holders only)
• Dispatching an Internet Order
• Final Checking an Internet Order
• Providing Services via an Internet Pharmacy
• Overarching Internet Pharmacy
• Preparing an Internet Order
• Receiving and Internet Order
• Setting up an internet pharmacy in the UK
• Pharmacy Social Media
• Cold Chain Delivery
• Selling OTC or P Medicines Online
• Pharmacy Cybersecurity
• Checking NHS Exemptions (GPhC + NHS License Holders only)
• Taking an NHS Prescription Charge (GPhC + NHS License Holders only)
• Remote Appliance Fitting
• Remote Compliance Aid Need Assessment
• Remote Patient Assessment of Repeat Dispensing Need (GPhC + NHS License Holders only)
• Remote Promotion of Healthy Lifestyle and Public Health Campaigns (GPhC + NHS License Holders only)
• Remote Signposting (GPhC + NHS License Holders only)
• Remote Disposal of Medicines
• Remote Support for Self-Care
• Essential Services
• Accuracy Check by an Accredited Checking Technician
• Accuracy Checking
• Assembling and labelling prescriptions
• Chaperoning
• Date Checking
• Delivery of Medicines
• Dispensing Medicines with a Compliance Aid
• Dispensing of Prescriptions
• Disposal of Unwanted or Waste Medicines
• Electronic Prescription Service Release 2
• Emergency Supply
• End of Month Procedures
• Owing Medication Supply
• Prescription Collection Service
• Promotion of Healthy Lifestyle
• Receiving Stock into the Pharmacy
• Roles and Responsibilities of Pharmacy Staff
• Support For People With Disabilities (Disability Act 2010)
• Support for Self Care
• Uncollected Prescriptions
• Responsible Pharmacist
• Sale of Medicines
• Repeat Dispensing
• Add New File
• Errors, Interventions and Complaints (All Healthcare Providers)
• Complaints, Concerns, Enquiries and Compliments Procedure
• Dealing with Dispensing Errors
• Interventions and Problem Solving
• Near Miss Audit
• Pharmacy Patient Safety Incident Report and Follow Up
• Preventing errors and recording near misses
• Enhanced Services (GPhC Registration Holders only)
• Blood Glucose Monitoring
• Monitoring Blood Pressure
• Cardiovascular Screening
• Chlamydia Testing
• Cholesterol, Glucose, Hemoglobin Point of Care Testing
• Emergency Hormonal Contraception
• Hosiery Fitting
• Minor Ailments Scheme
• Monitored Dose Systems
• Needle and Exchange Service Scheme
• Palliative Care Enhanced Service
• Pharmacy Urgent Repeat Medicine Service
• Smoking Cessation
• Controlled Drugs
• Balance Check and Record-Keeping
• Delivering Controlled Drugs Standard Operating Procedure
• Destruction of Controlled Drugs
• Dispensing Codeine And Dihydrocodeine
• Dispensing of Controlled Drugs
• Dispensing Supervised Methadone
• Extemporaneous preparation of methadone
• Instalment dispensing of Controlled Drugs
• Recording Concerns over CD management
• Security and Storage of Controlled Drugs
• Supervised Controlled Drugs
• Supply of Sativex
• Business Continuity
• Operating in the Absence of a Responsible Pharmacist
• Pandemic Protocol
• Business Continuity Plan
• COVID Social Distancing and Infection Control Risk Assessment Tool
• Advanced Services (GPhC Registration Holders only)
• Appliance Use Reviews
• Medicine Use Reviews
• New Medicine Service
• Stoma Appliance Customisation Service
• DMIRs
• Seasonal Vaccine Clinics
• Infection Control
• Influenza Vaccination
• Needlestick Injuries and Contamination
• Travel Clinic
• Malaria Chemoprophylaxis
• MMR Vaccination
• Shingles Vaccination
• Travel Core
• Yellow Fever Centre

New private pharmacies in the UK often find it difficult to establish a foothold in the dispensing market as initially they lack doctors prescriptions by which they can dispense and dispatch from. Some private pharmacy look to register with the NHS via the Market Entry Team, get a NHS dispensing license and then can bill the government for medicines that they dispense from a standard NHS Prescription.

The process of applying for an NHS license is very straightforward:

1. Fist you need to navigate your browser to the Pharmacy Market Management Services controlled under the jurisdiction of the PSCE.
2. Next click the button “Register for the online Market Entry service” this will bring you to your default email client and give you a pre populated email like so:

3. Once this has been filled and sent it will take a couple fo days for the PSCE team to get back to you.

4. Once they do login to the PSCE site and this should be the first thing you see…

5. Either click New application or Edit one you have already made and then select the following options.

6. Click next and you will be asked about the details of the proposed pharmacy location, the most important part here is the question about Regulation 31. This is referring to whether you understand that it is a national service you should offer. Default text is written below…

7. The next page details out the opening hours that you intend to be open for. In general pharmacies are open for 40 hours a week.

8. The next part of this is a little tricky if you do not know much about pharmacy services. The form asks you about which services you would like to provide, whether they be enhanced, essential or advanced. You need to make sure that you meet the NHS Pharmacy contract essential requirements, we have detailed out a sample for you below, however if you need further help with this please get in contact with one of our consultants.

The independent community pharmacy sector is fast evolving into a more service-based model. With the impending acquisition of Pharmacy2U by Amazon and the meteoric rise of internet pharmacies such as Well and Boots… (see image below) We don’t have much choice.

Our representative associations have promised more commissioned services to compensate for this loss, but where are they? We are now on equal par with GPs abilities i.e. we have the means to supply medicines and care via PGD or Independent Prescribing but why does the NHS not look at community pharmacy as a low priced alternative to commissioning in primary care? To date we have seen the withdrawal of MUR and Minor Ailments, but where are the new services that will keep us financially viable?

Unfortunately, it seems a round table for commissioning doesn’t exist. The NHS is at the top commissioning services, the money for which flows its traditional course, roaring down to the CCGs and GPs and then lastly trickling to pharmacies.

How can we independent pharmacies keep up?

One way is to address a need of your commissioner, find where there is an issue in the system and create a solution. But where can you find an established need? One place is going direct and searching for local NHS tendering websites and procurement requirements. However, competition here is fierce from larger chains and medical agencies.

A fascinating place to find an issue which needs resolving is the Courts Tribunals Judiciary website. This site publishes a list of preventable deaths attributed to alcohol, drug and medication. Here is a quick summary of the latest entries… (Or make an entry yourself by clicking this link…

Many of the issues listed relate to overdoses with tramadol, even though the medicine was reclassified as Schedule 3 in June 2014. As a pre-reg tutor why not get your Pre-Registration student to go through this list, get them to pick one issue that a pharmacy could potentially resolve and design a solution. In the case of tramadol, why could there not be a specialised MUR-like service which audits patients who may be at risk of overdose?