Community Pharmacy Contractors

Greater Manchester Pharmacy Handbook

Greater Manchester Pharmacy Handbook

This handbook has been developed by the NHS Greater Manchester Optometry & Pharmacy Team (“the team”) to support you with the delivery of NHS Essential Services in line with your Terms of Service, which are set out within The National Health Service (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013 (legislation.gov.uk)

Every pharmacy should download a copy and keep in the Pharmacy as the handbook contains key information about pharmacy services, disposal of unwanted medicines, the CPAF process, PQS, temporary closures and much more!

Waste management issues and general enquiries 

The email address for NHS GM Primary Care team is  england.gmtop@nhs.net. You can contact this address for general enquiries include waste management issues.

Please direct any enquiries (e.g. missed collections or requests for an increase or decrease of units) in a timely manner via email to england.gmtop@nhs.net. For your query to be dealt with efficiently, please ensure you provide your pharmacy’s full details, have your last transfer note to hand, and give a brief description of the specific issue. Further information can be found in the Pharmacy handbook

Prescription Direction

Background Information

Direction of prescriptions describes the exercise of undue influence by a medical practice over the choice of where a patient takes or sends their prescription to be dispensed. It can also be used to describe situations where pharmacy owners and pharmacists encourage medical practitioners to recommend their pharmacy, by way of offering a gift or reward.

Prescription direction should not take place as it undermines the patient’s decision about where they want their prescriptions to be dispensed. Therefore, if a patient prefers to use a particular pharmacy, the NHS Constitution requires that this preference is respected. Please see below for further guidance on how to deal with and manage potential prescription direction issues.

There have been increasing numbers of Prescription Direction issues being reported to the LPC and also the Greater Manchester Health and Social Care Partnership (GMHSCP).

Please see useful resources below:

1. A letter to all GP practices and Pharmacies from the GMHSCP

2. Poster on freedom of choice  (Pharmacy contractors can obtain additional copies of the poster from the PSNC by contacting shantel.christian@psnc.org.uk)

3. Poster on freedom of choice (high res version)

In order to ensure patients are fully informed of their choice, please display the poster prominently close to where patients receive prescriptions. Distance-selling and internet pharmacies should display this information prominently on their websites and take reasonable steps to bring this notice to the attention of all patients.

A number of these cases are being investigated at this time and the LPC have been working closely with the GMHSCP to address these issues, and they take the matter of prescription direction very seriously.

They will discharge their duty to ensure that patients’ rights under the NHS Constitution and also for data protection are met. This assurance may be by way of taking appropriate contractual action against contractors to protect those rights by the GMHSCP , where evidence of prescription direction or switching patient nominations without consent is found.

There are increasing numbers of cases reported where  patient EPS nominations have been changed either by a pharmacy or GP practice:

• without the patient’s explicit consent, or
• where patients have allegedly been influenced to choose one pharmacy over another (either by another pharmacy or a GP practice); or
• where patients have allegedly been actively discouraged from choosing a particular pharmacy (either by another pharmacy or a GP practice)

It is reported that patient care has been significantly detrimentally affected in some cases, e.g. where delays in obtaining medication have occurred while the nomination issues are identified, investigated and rectified (see useful resources below for a template letter for EPS promotion).

Reporting Prescription Direction Issues

Pharmacist or member of a pharmacy team complaints

• If a pharmacist or member of a pharmacy team wants to make a complaint, they will need to follow the in-house procedure which involves completing this complaint form and sending via email to  to england.gmtop@nhs.net. Please also send a copy of this form to enquiries@gmlpc.org.uk

Other useful resources

BMA, Pharmacy Voice and PSNC statement on prescription direction

Joint BMA and PSNC guidance on prescription direction

Template letter for patients who have stopped visiting a pharmacy – Pharmacies can use this letter to write to the patients that have stopped visiting the pharmacy and ask why they have chosen to do so – the pharmacy can then use any responses to help review the quality and range of services it provides.

Template patient leaflet for EPS promotion – Pharmacies can use this leaflet to promote their pharmacy whilst informing patients of the benefits of EPS and clearing up any potential misunderstandings about the ways that pharmacy services are provided. The text can be modified to reflect local circumstances.

NOTE:

If a patient/customer has already complained directly to a pharmacy about their prescription direction material, and they are not satisfied with the pharmacy’s response to that complaint, they should contact the Parliamentary & Health Service Ombudsman (PHSO). The PHSO makes final decisions on all complaints about NHS services. NHS England cannot investigate complaints that have already been made directly to the pharmacy.

To take a complaint to the Parliamentary & Health Service Ombudsman, visit www.ombudsman.org.uk or call 0345 015 4033.

Complaints about a pharmacy contractor or NHS professional

If you have an issue with a Pharmacy contractor or other NHS professional in GM that needs resolution;

1. We advise you to contact the contractor in the first instance ensuring you have recorded the dates and times of attempted communications with phone and email records. (For e.g Patient nomination issues, interface issues)
2. If the issue is not resolved, we request that you complete the attached proforma and send to England.gmtop@nhs.net
3. Please email enquiries@gmlpc.org.uk if you need any advice or support.

Reporting an incident or issue

If you would like to raise an issue regarding another pharmacy or GP practice, please use the Pharmacy Incident and Concerns GM Integrated Care Proforma form

Local Primary Care Complaints Contacts for Patients

If a patient wishes to make a complaint, contractors should direct them to their local complaints and feedback team. A list of relevant contacts for each locality is available here

Market Entry

You can also check the status of any application by logging onto the PCSE portal.

In order to raise any issues please visit the PCSE Contact Us page and complete the enquiries form.

Information relating to pharmacy consolidations (mergers) can be found here

Further information relating to market entry can be found on the PSNC website

New PLPS regulations – template forms

NHS England has published the template forms to be used when submitting applications and notifications for the new regulations that came into force today.

Contractors are encouraged to review the updated briefing before completing a notification or application using the templates and sending to the ICB.

NHS England – Pharmacy Manual – Pharmacy Template Forms

Change of hours

To make an application to change opening hours please contact the  NHS GM Primary Care team at england.gmtop@nhs.net

Patients and the Public

How you make a complaint about primary care services has changed

You have the right to make a complaint about any aspect of NHS care, treatment or service, and this is written into the NHS Constitution on GOV.UK.

From 1 July 2023 the way members of the public make a complaint about primary care services to the commissioner is changing.

 By primary care services we mean GPs, dentists, opticians or pharmacy services.

There are two ways you can make a complaint:

• You can complain to the healthcare provider: this is the organisation where you received the NHS service, for example a GP surgery or dental surgery.
• You can complain to the commissioner of the service: this is the organisation that paid for the service or care you received.

If you want to make a complaint about primary care services to the commissioner you will now contact Greater Manchester integrated care board instead of NHS England.

Details of how to do this can be found at the following website, under the ‘Local area feedback and complaints’ section:

https://gmintegratedcare.org.uk/have-your-say/contact-us/

If you want to make a complaint directly to the provider of the primary care service, you still can – that does not change on the 1 July 2023.

We also request that you notify your LPC so they have sight of these issues by emailing enquiries@gmlpc.org.uk

If you wish to escalate the case further or need advice please contact GMLPC by emailing enquiries@gmlpc.org.uk or phoning the office number on 0161 228 6163.

NHS England – General Patient Queries

NHS England’s Customer Contact Centre deal with general enquiries from patients, such as ‘how do I get a GP or Dentist’.

For such general enquiries, patients can still call 0300 311 22 33.

Members of the public with ongoing complaints received on/after 1 July 2022 will receive a letter from NHS England informing them that the ICB is now handling their complaint with confirmation of their case handler.

Members of the public with any ongoing complaints received before 1 July 2022 will receive a letter from NHS England informing them that their complaint is being retained by NHS England with confirmation of their case handler.

If you have any queries, please contact 0161 357 1599

Find out more about how to feedback or make a complaint about an NHS service 

Further information relating to the NHS complaints procedure can be found here:  https://www.england.nhs.uk/contact-us/complaint/complaining-to-nhse/

Further information and key messages are available here

Controlled Drugs Accountable Officer

If you have any CDs issues/concerns, visit www.cdreporting.co.uk.