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Pharmaceutical Services Negotiating Committee

Contract Monitoring

NHS England's Area Teams (ATs) have responsibility for monitoring the provision of Essential and Advanced services. Arrangements for monitoring locally commissioned services may be set out in local contracts or Service Level Agreements.

PSNC recommends the use of the Community Pharmacy Assurance Framework (CPAF) (see below) as the basis of contract monitoring; the approach that NHS England's Area Teams will take to contract monitoring during 2013/14 is yet to be made public.

Historically monitoring by PCTs involved an annual visit to the pharmacy premises. The use of a self-assessment questionnaire (see below) may precede the monitoring visit; these questionnaires can be a helpful tool for contractors to assess their readiness and to highlight areas of service provision which may require additional attention.

PSNC Contract Workbook

Many pharmacy contractors use the PSNC Contract Workbook as a self assessment tool to check their compliance with the terms of service and to record information for use during contract monitoring visits. A new 2013/14 version of the electronic PSNC Contract Workbook will soon go live on the new PharmOutcomes system.

This PharmOutcomes module is the updated electronic version of the PSNC Contract Workbook, which was first published in 2005, and which has been updated annually.

The module allows a pharmacy to voluntarily check through each element of the CPCF’s terms of service and where necessary record details that might be requested during a monitoring visit.

Community Pharmacy Assurance Framework (CPAF)

As part of the support to the NHS on the implementation of the community pharmacy contract, NHS PCC was asked to co-ordinate and support the work of Strategic Health Authorities (SHAs) and PCTs in developing a toolkit for assessing compliance and quality under the new contract arrangements. SHAs felt that it would be helpful to have a nationally designed and agreed framework with a core set of indicators and quality markers for assessing implementation, rather than PCTs ‘reinventing the wheel'.

The final toolkit was published in September 2005 as the CPAF and it has been used successfully by many PCTs. Updated versions of the toolkit have been produced by NHS PCC, working with PSNC, over the last few years; the latest version is available on the NHS PCC website

In areas where the CPAF is used, LPCs and pharmacy contractors can be assured that the contents have been agreed nationally and fulfil the requirements of monitoring whilst ensuring only those items required under the contractual framework are covered. 

NHS England's Area Teams (AT) have a right to enter pharmacy premises and ask for access to documents which are necessary for audit or monitoring purposes. This power does not extend to requiring pharmacy contractors to copy and send to the AT such documents, although many pharmacists are happy to do so.

Self-assessment & Pre-visit Questionnaires

PSNC supports the use of contractor self-assessment as the first step of monitoring and a pre-visit questionnaire is included within the CPAF.

While there is no requirement under the Terms of Service to provide documents to the AT in advance of a monitoring visit, PSNC does encourage pharmacy contractors to provide some information to ATs on compliance with the contract, especially if this will avoid the need for a visit, or reduce the time needed for a visit. The pre-visit questionnaire published by NHS PCC was agreed by PSNC, so completing this would be appropriate.

Monitoring Visits

Within the pharmacist's terms of service, a pharmacist shall allow persons authorised in writing by the AT to enter and inspect his pharmacy at any reasonable time for the purpose of ascertaining whether or not the pharmacist is complying with the requirements of their terms of service. Where the pharmacist requests it, the LPC can be present at the inspection.

Any visit should be planned carefully so as not to impact negatively on the day-to-day running of the pharmacy. Patients of pharmacies do not require appointments therefore any inspection teams should not necessarily expect to have the pharmacist devoted to them during any visit, nor should any inspection disrupt the concentration of pharmacy staff in the provision of care to patients.

Monitoring the use of SOPs

The Essential Service specifications require the pharmacy to have appropriate SOPs for dispensing, repeat dispensing and support for self-care.

Monitoring compliance requires only the determination of whether the pharmacy has an appropriate SOP. It does not require the AT to carry out a detailed analysis of the content of the SOPs. Indeed, it would be unwise for an AT to carry out any detailed examination, because it will be unable to determine what is appropriate for the individual pharmacy concerned, and any shortcomings not identified, or suggestions made which themselves cause problems in delivery of the services, could lead to the AT itself being involved in litigation. 

For this reason, the most appropriate way for an AT to determine whether the pharmacy has an appropriate SOP is to ask to see it during a monitoring visit (but without reading it in detail), then to ask appropriate members of staff suitable questions about their procedures to establish the level of understanding and compliance with the SOP.