The current workforce pressures are leading to unplanned temporary closures that are beyond contractors’ control. In these circumstances, if contractors follow appropriate procedures to mitigate the effects of the closure on patients, the public, the NHS, and other community pharmacy contractors, they should avoid breaching their terms of service.
The procedures – as well as closing the premises and restricting entry/access – include the following:
Notifying NHS England as soon as practical: There is an unplanned temporary suspension of services notification form which contractors should complete to notify NHS England of the temporary closure and the reasons for it.
Updating the Directory of Services (DoS) and NHS website entries: Using NHS Profile Manager, contractors must update their DoS and the NHS website entries to ensure that they provide accurate information of the pharmacy’s opening hours to patients, the public, and other relevant NHS service providers.
Trying to re-open the pharmacy: Contractors must use all reasonable endeavours to re-open and provide NHS pharmacy services as soon as practicable.
Making alternative arrangements for the provision of NHS pharmacy services: Contractors must, where practicable, make alternative arrangements with one or more pharmacies in the area, for the ongoing provision of NHS pharmacy services.
Alternative arrangements for the ongoing provision of NHS pharmacy services are likely to include:
Clinical: Identifying any urgent prescriptions which are awaiting dispensing, collection or delivery, such as those for antibiotics or analgesics, and making arrangements for the ongoing supply of medicines prescribed by installment prescriptions or supplied in monitored dosage systems. It is important that staff do as much as they can before they leave the premises to ensure patients are able to access their prescriptions.
Information: Displaying clear notices advising patients and the public of the closure, including any arrangements for accessing their medicines and the estimated time when the pharmacy will re-open, and providing relevant information to those with, for example, urgent prescriptions.
GPs: Informing local GP practices of the situation and any arrangements made with local pharmacies while the pharmacy is closed.
Further information and actions to consider taking are available in PSNC’s existing guidance on planning for temporary closures and checklist for emergency temporary closures. Further guidance on opening hours is also available.
In some areas, NHS England regional teams may ask contractors to complete a new notification form for any temporary closures that requests more information than the standard form, for example, on the mitigating actions taken by the contractor. Completion of these forms is voluntary but may help to show NHS England that the closure was for reasons beyond the contractor’s control, or that the overall circumstances of the closure, including time closed and steps taken to ensure patient and public needs are met, indicate that there is no public interest in taking any regulatory/performance action (such as a breach notice) against the contractor.
If the temporary closure is not for reasons beyond the contractor’s control, this may be a breach of the terms of service.
PSNC is working with NHS England and the Department of Health and Social Care, as indicated in the CPCF Years 4 and 5 letter to contractors, to consider what can be done to relieve the current pressures contractors are facing.
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