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Pharmaceutical Services Negotiating Committee

Patient Nomination of a Dispensing Site

Nomination is a new process that is being introduced in Release 2 of the Electronic Prescription Service. It gives patients the option to choose, or ‘nominate', a preferred dispensing contractor(s) to which their prescriptions can be sent electronically using the Electronic Prescription Service. This section of the site provides detailed guidance for contractors on this new functionality. Use the quick links below to access specific areas of the guidance:

Which Sites can a Patient Nominate?

Adding or Changing a Patient's Nomination

Appropriateness of Nomination

Obtaining a Patient's Consent for Nomination

Nomination Consent Forms

Nomination SOPs

Nomination & Change of Ownership

Controls to Ensure Patient Choice

Updating NHS Choices

What If Scenarios

FAQs


Which sites can a patient nominate?

When a nominated electronic prescription is generated, it is then sent to the Electronic Prescription Service and can be retrieved by the nominated dispensing system - without the need to scan a barcode on the prescription token.

Patients or their carers can set their nominated dispensing site at any Release 2 enabled pharmacy or at the GP Surgery that they are registered with (if Release 2 enabled). The patient will be able to set up to three dispensing sites: a community pharmacy and/or an appliance contractor and/or a dispensing doctor. It will not be possible for a patient to select more than one dispensing site of the same type, for example more than one pharmacy, however consideration is being given to enabling this in the future. Also, it will not be possible for patients to nominate a chain of pharmacies, only a specific dispensing location.

Unlike with established prescription collection services, patients will be able to request that their prescription is sent to any pharmacy regardless of the geographical location or the working relationship between the pharmacy and the prescriber.

Dispensing doctors will continue to only be able to dispense to patients where the criteria in the regulations is satisfied, including that the patient is resident in a controlled locality, at a distance of more than 1.6 kilometres from any pharmacy. It would be a breach of a dispensing doctor's Terms of Service to use the Electronic Prescription Service to dispense for a patient for whom they are not entitled to provide pharmaceutical services. For this reason, patients will not be able to nominate a dispensing doctor through a provider other than the dispensing doctor that they are nominating.


Adding or Changing a Patient's Nomination 

The patient's preference is held on the ‘Personal Demographics Service' (PDS) a component of the NHS Care Records Service. Pharmacies and GP Surgeries with Release 2 enabled systems will be able to send messages to the PDS to make a change to a patient's nomination settings.

Setting the nominated dispensing contractor will require the patient's NHS number. It is increasingly common for this to be printed on NHS prescriptions and is always contained within an electronic prescription message. If a pharmacy does not have ready access to this number, Release 2 enabled systems will support pharmacy staff, with patient consent, in conducting a simple trace on the Personal Demographics Service to locate a patient's NHS number. Pharmacy staff must enter sufficient information to achieve a 1:1 match, for example the patient's name, gender, date of birth or postcode.

A lesson learned from implementation of EPS Release 2 to date is that if the pharmacy is using EPS Release 1, patient's NHS numbers are automatically populated on the PMR system, significantly increasing the efficiency of the nomination process. Where the NHS number is not available, pharmacy systems support pharmacy staff in conducting a simple trace to locate this information, however this is a slower process. 

Updating the patient's nomination status can occur at a convenient time to support smooth workflow; it does not need to be carried out at the same time as dispensing a prescription. Only staff with an individually registered smartcard will be able to set a patient's nominated dispensing site, but it is anticipated that any pharmacy staff members supporting the dispensing process will be able to apply for an individual smartcard with the appropriate access rights. Therefore, the administration of nomination change requests will not need to be undertaken by a pharmacist.

It will be possible to add, cancel or change a patient's nomination settings. Where a patient changes their nominated dispensing contractor, all nominated prescriptions that have not yet been retrieved for dispensing from the original nominated dispensing contractor will be transferred across to the new nominated dispensing contractor. Once a nomination has been set, there is no 'expiry' date on the system.

Pharmacies will not be notified when they have been nominated or when the patient changes their nomination setting. However, pharmacies can, with patient consent, query a patient's list of nominated dispensing sites, for example to aid patients who are trying to obtain their medication at an incorrect location.

Every time someone accesses information held on the Personal Demographics Service, a record is made about who is accessing that data and how it is being used. This would include when a pharmacy queries a patient's list of nominated dispensing sites. Privacy officers, in specific circumstances, are automatically alerted when actions have been taken by staff which may constitute a breach of confidentiality.

As the system only supports the patient to nominate one dispensing site of a particular type at a time, if two pharmacies change the nomination settings for the same patient, prescriptions will be sent to the pharmacy that last set the patient nomination request.


Appropriateness of Nomination

Nomination is more suitable for some patients than others, depending upon their individual circumstances. Nomination is most suitable for patients who receive regular medication and who tend to collect their medication from the same pharmacy most of the time. Patients on a repeat prescription collection service or existing repeat dispensing patients are ideal groups to discuss EPS and nomination with.

A lesson learned from EPS R2 sites is that where pharmacies have captured large volumes of nominations prior to a local surgery going live, this has enabled staff to cement business process change early. Where low numbers of nominations are recorded, the re-education of staff to new processes has been slower.

There are some prescription items that cannot be transmitted electronically, for example it is currently not permitted to issue an electronic prescription for a Controlled Drug specified in Schedule 1, 2 or 3 of the Misuse of Drugs Regulations. This can mean the prescription is split causing problems where patients have received both paper and electronic prescriptions. A key lesson from EPS R2 implementation to date is that pharmacists need to work with GPs to have a process in place to be able to identify patients who may have split prescriptions and ensure that affected patients are aware of the risks that nomination could create. Nomination may not be the best option for these patients. Despite the risks, if the patient still wants to nominate a pharmacy, an alternative solution is for prescribers to include a note in the electronic message to indicate that there is also an FP10 for the patient.


Obtaining Patient Consent for Nomination

Pharmacies must have ‘local accountable auditable processes' for obtaining explicit consent from the patient or their representative before changing a patient's nomination settings.

Pharmacists or their staff can obtain consent. The following information should be provided when obtaining consent:

  • The service involves the electronic transfer of prescriptions in a secure environment. Paper is not required. Patients do not have to receive their prescriptions via the EPS however where a paper prescription is issued, services associated with EPS such as nomination cannot be used.

  • Any dispensing sites operating full EPS (Release 2) can be nominated; patients are not restricted to nominating a pharmacy near their GP practice.

  • Where patients have nominated a dispensing site, their prescription will automatically be received by that site unless the patient chooses not to receive a particular prescription in that way and notifies the prescriber at the time of requesting the prescription.

  • Patients can change their nominated dispensing preferences at their GP surgery or any Release 2 enabled dispensing site at any time, including whilst part way through a repeat dispensing cycle. Any remaining repeat prescriptions, which have not been pulled down to the local system, will be accessed by the new nominated dispensing site.

  • Where a patient has nominated a dispensing site, the site will be able to access the prescription in advance of the patient presenting at the site, in order to prepare the prescription. However, if the patient then goes to a different site, there may be delays before the non nominated site is able to access the electronic prescription.

This information could be provided in writing to the patient, for example a standard leaflet handed to patients, or it could be provided orally.

If explicit consent is collected in advance of a pharmacy deploying Release 2, the pharmacy contractor should ensure before setting the patient's preference on the Personal Demographics Service, that there has been no change in the patient's circumstances, including their choice of nominated dispensing site, since the original consent was obtained.

A patient can nominate a Release 2 enabled pharmacy before their GP surgery is offering Release 2. There is no need to re-confirm a nomination that is already recorded  on the Spine at the point that the GP goes live. 


Consent Forms

 
Template Patient Consent forms

Royal Pharmaceutical Society: Template Nomination Form (External Link/MS Word)

HSCIC: Template Nomination Form

Both the NPA and Numark have developed pre-printed EPS nomination patient information leaflet/consent forms which are available to purchase.   


Nomination SOP

In their Good Dispensing Guidelines, the RPSGB confirmed a requirement that pharmacies should put in place a SOP for Nomination. This is to ensure that nomination is communicated consistently to patients, and is captured in an auditable way so that, if challenged, processes are in place to back up information following on from a customer complaint or from an audit perspective. Both the NPA and Numark have developed template SOPs.

It would not be appropriate for an NHS England Area Team to request to individually sign-off a pharmacy nomination SOP or state that a pharmacy cannot begin to collect consent for nomination until the NHS England Area Team has seen a SOP.

In joint PSNC/NHS PCC Guidance on monitoring the contract’s Essential Services, it was agreed that the monitoring should only extend so far as to whether a pharmacy has an appropriate SOP, for example ask to see it during a monitoring visit. The guidance stated that it would be unwise for a PCT 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 PCT itself being involved in litigation.  


Nomination and Change of Ownership

A pharmacy's ODS code (previously known as the OCS code, NACS code and F code) is used in a number of national NHS IT systems. When an electronic prescription is sent to a nominated pharmacy, the electronic message contains a flag with the ODS code of the nominated pharmacy. Only a pharmacy with a matching ODS code registered on their local system can pull down a message without the prescription ID number contained on a token. Where a dispensing site is changing ownership on a non-debts and liabilities basis, a change of ODS code is required (note this is the only scenario in which a new ODS code is required). Pharmacies in this situation should alert their pharmacy system supplier as early as possible; system suppliers can work with the HSCIC to co-ordinate technical changes that enable pharmacies to access prescriptions that have been issued linked to the old or new code - ensuring continuity of care for patients.

Regardless of whether there is a change to the pharmacy ODS code, the National Health Service (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013 (No. 349) which come into force on the 1st April require the new owner to inform patients who had previously nominated the pharmacy that the ownership has changed and check that they wish to continue to nominate the pharmacy. This needs to be undertaken within the first 6 months of ownership.  


EPS Release 2 Sign

To support patients in recognising which sites are Release 2 enabled, the HSCIC has developed a sign which can optionally be displayed within prescribing and dispensing sites. The sign will be supplied to a site at the time of going live with Release 2 and will be available in three different formats, A5 window sticker, A4 poster or A5 counter-top sign. If this sign has not been received, it can also be obtained from Department of Health's Publications Orderline while stocks last. 

  


Ensuring Patient Choice is Maintained

A number of safeguards have been introduced to ensure that patient choice is maintained when the system is in use.

Patient can always request a paper FP10: The patient can choose whether to have an electronic prescription or a paper prescription. For the time being (during Phase 3 of implementation of the Service), an electronic NHS prescription can only be issued where the prescription is being sent electronically to a patient's nominated dispensing site. Patients who have not nominated a dispensing site or who do not wish their prescription to be sent electronically to one of their nominated dispensing sites on a particular occasion will receive a paper prescription form that can be taken to any pharmacy.

Nomination by GP Practices: The National Health Service (Primary Medical Services) (Miscellaneous Amendments) Regulations 2005 require that a prescriber must not seek to persuade a patient to nominate a dispensing site recommended by the prescriber. If asked to recommend a pharmacy, the prescriber is to provide a list of all dispensing sites in the area that operate EPS. Information on EPS Release 2 enabled providers will be provided by the NHS Choices Website (www.nhs.uk) therefore it is essential that pharmacy contact details held on the NHS Choices site are up-to-date and accurate.

Nomination by Pharmacies: The National Health Service (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013 prohibit pharmacies and appliance contractors from providing patients with inducements to encourage nomination of a pharmacy. 

Proactive Monitoring: NHS England have a duty to act on complaints about abuse of the service where the GP or pharmacy Terms of Service may have been breached. The HSCIC are providing the NHS with both summary and detailed reports about nominations to support the investigation of complaints.

Are your Pharmacy contact details up to date on the NHS Choices Website?

Information on which pharmacies are EPS Release 2 enabled will be provided by the NHS Choices Website (www.nhs.uk) which will be updated automatically as individual pharmacies become Release 2 enabled. It is essential that the information held on nhs.uk is up to date to support prescribers in locating and setting the nomination of a particular pharmacy on their prescribing system at the patient's request. Pharmacy contractors can check now whether the information held online at the NHS Choices website is up to date. It is particularly important to check whether the pharmacy name displayed on the NHS Choices site is the pharmacy's current trading name and that the postcode is accurate.

Requests for changes to the pharmacy name and address should be put in writing to the NHS England Area Team. Pharmacies can register to independently edit other information on their NHS Choices profile.


What If?....Scenarios

What If? Scenario 1: A proportion of the prescriptions that the patient regularly receives cannot be transmitted electronically 

There are some prescription items that cannot be transmitted electronically, for example it is currently not permitted to issue an electronic prescription for a Controlled Drug specified in Schedule 1, 2 or 3 of the Misuse of Drugs Regulations. Patients not being able to obtain all medicines electronically has created problems. The key lesson is that pharmacists need to work with GPs to have a process in place to be able to identify patients who may have split prescriptions and ensure that affected patients are aware of the risks that nomination could create. Nomination may not be the best option for these patients. Another option is for prescribers to include a note in the electronic message to indicate that there is also an FP10 for the patient. PSNC is continuing to call for the law to be changed to allow Schedule 1, 2 and 3 Controlled Drugs to be sent via the service. 

What If?  Scenario 2: A patient has a regular nominated pharmacy (Pharmacy A) but has requested that as a one-off, their prescription is sent to another pharmacy (Pharmacy B).

It is not possible for a patient to select more than one dispensing site of the same type, for example more than one pharmacy and where a patient changes their nominated pharmacy, all nominated prescriptions that have not yet been downloaded for dispensing from the original nominated pharmacy will be transferred across to the new nominated pharmacy.

When this scenario arose in one of the first sites to implement EPS Release 2, staff in the GP Practice, changed the nomination to the new pharmacy (Pharmacy B) at the patient's request and sent the prescription but before Pharmacy B had downloaded the prescription, the staff in the GP Practice changed the nomination straight back to the original pharmacy (Pharmacy A) so that future prescriptions would be sent to Pharmacy A as per the patient's request. As the change to the nomination settings in this scenario was made before the new pharmacy (Pharmacy B) had downloaded the prescription message, the prescription that the patient wanted sent to Pharmacy B was instead transferred to Pharmacy A.To avoid this happening, the GP practice could instead have:

  • Issued a paper FP10, if the patient is present;
  • Advised the patient to ask Pharmacy B to change their nomination to Pharmacy A when they collect their prescription;
  • Sent a message to Pharmacy B in the electronic message alerting them that the patient has indicated they would like their nomination switched back to Pharmacy A after the prescription has been dispensed.
 

Frequently Asked Questions

Where a patient has requested a change to their nomination settings but I don’t have their NHS number, I have been undertaking simple traces on the Personal Demographics Service to locate this information. Occasionally, even where I have entered the correct demographic information in the search box, my system is not returning an NHS number. What should I do?

The demographic information contained in PDS is extracted from a range of local clinical systems. Problems can arise if this information is not transferred from local systems to PDS in the required form. Where there is confidence that the demographic information being used to perform a simple trace is accurate but it is not returning a result, it is important to contact your PMR supplier so that they can co-ordinate resolution of this issue through the HSCIC.

Does consent have to be obtained to change a patient's nomination settings?

Yes, it is a professional requirement. The Code of Ethics states that pharmacists must obtain consent for the professional services, treatment or care they provide and the patient information they use. The RPSGB document, ‘Professional Standards and Guidance for the Sale and Supply of Medicines' contains standards for prescription collection services and the RPSGB document, ‘Professional Standards and Guidance for Patient Consent' details more general requirements on collecting consent from patients for the provision of services, including guidance on providing sufficient information and presenting this to patients. Failure to adhere to these standards could form the basis of a complaint of professional misconduct.

Does consent always have to be given by the patient?

No, in some circumstances, consent can be obtained from the patient's representative:

  • on behalf of any child by either parent, or in the absence of both parents, the guardian or other adult who has the care of the child;

  • on behalf of any person under 18 years of age who is in the care of an authority to whose care he has been committed under the provisions of the Children Act 1989, by a person duly authorised by that authority or in the care of a voluntary organisation, by that organisation or a person duly authorised by them;

  • on behalf of any adult who is incapable of nominating a pharmacy, by a relative or the primary carer of that person;

  • on behalf of any other person by any duly authorised person. A pharmacy contractor is not able to provide consent on behalf of a patient nominating his pharmacy.

My pharmacy serves a large care home. Do the patients need to provide their consent to nominating my pharmacy or could this be done by care home staff?

The regulations state that patients or in some cases their carers can set a patient's nominated dispensing site, therefore the care home staff can on behalf of the patient provide the required consent for the patient's nomination setting to be changed.

Do I have to change my Standard Operating Procedures?

Pharmacies must have ‘local accountable auditable processes' for obtaining explicit consent before changing a patient's nomination settings.

The RPSGB publication ‘Professional Standards and Guidance for Patient Consent' advises that processes for obtaining consent must be taken into account when developing SOPs and that consideration needs to be given to which members of staff may obtain consent, the information that should be provided in obtaining consent and the way that consent is collected (e.g. written, verbal).

Both the NPA and Numark have developed template Nomination SOPs.

How long should I keep a nomination consent form that has been signed by the patient?

Pharmacies must have ‘local accountable auditable processes' for obtaining explicit consent from the patient or their representative before changing a patient's nomination settings. Whilst it is not mandatory for a pharmacy to collect a patient signature to confirm consent, this has been recommended by the Royal Pharmaceutical Society. The collection of a signature will support the pharmacy by providing an audit trail in the event that a complaint is made about the pharmacy’s use of the service.

It is for a contractor to judge how long forms should be kept for, balancing the need for an audit trail against the 5th Data Protection principle of not keeping information longer than necessary. Note, if the patient chooses to change their nomination setting at another pharmacy, the original nominated pharmacy will not be alerted to this. There is scope for PMR systems to generate reports of patients regularly receiving prescriptions at the pharmacy via the nomination functionality which will help identify patients with ‘active’ nominations.

I have an existing repeat prescription collection service. Do I need to obtain consent to change the patient's nomination settings to nominate this pharmacy as their preferred pharmacy for electronic prescriptions?

Yes. Explicit consent must always be obtained from the patient or their representative before changing a patient's nomination settings.

Explicit consent can be collected in advance of the pharmacy deploying Release 2. If there is a delay between collecting consent and changing the patient's preference on the Personal Demographics Service, the pharmacy contractor should ensure there has been no change in the patient's circumstances, including their choice of nominated dispensing site, since the original consent was obtained.

If a patient has nominated multiple dispensing sites, how will they know which dispensing site has been sent their prescription?

The patient can set up to three dispensing sites: a community pharmacy and/or an appliance contractor and/or a dispensing doctor. It is not possible for a patient to select more than one dispensing site of the same type. If a patient has nominated more than one dispensing site, they will need to discuss with the prescriber which dispensing site they would like a particular prescription sent to, for example if they wish to have their medicines dispensed by their nominated pharmacy but appliances dispensed by their nominated appliance contractor.

A patient has visited my pharmacy and asked that I set their nomination for both my pharmacy and an appliance contractor that provides the patient with their stoma products. Do I have to set the nomination for the appliance contractor?

Yes. The Terms of Service require that where the EPS service is available, the pharmacist must update a patient's nomination settings as requested by the patient, this would include adding a pharmacy or appliance contractor as the patient's nominated dispensing sites. A nomination to a dispensing doctor is only possible at that dispensing doctor's location.

What if the patient forgets which pharmacy they have nominated, how can the patient find this out?

Pharmacy systems will support querying a patient's current nominated dispensing sites. Pharmacy staff with appropriate access rights will, with patient consent, be able to view the contractor type (i.e. pharmacy, appliance contractor or dispensing doctor) as well as the organisation name, address and postcode for the patient's nominated dispensing site. Prescribers will also be able to view this information.

Can I provide patient's with loyalty points or a free gift if they choose to nominate this pharmacy?

No, the Terms of Service in the National Health Service (Pharmaceutical Services) Regulations 2005 prohibit pharmacies and appliance contractors from providing patients with inducements to encourage nomination of a pharmacy. A breach of the Terms of Service could result in the Primary Care Trust taking disciplinary action against the pharmacy contractor.

Could staff in a GP Practice, for example a GP receptionist, change the nomination settings at a patient's request?

Yes, if the individual has a smartcard and has been granted the appropriate access rights, they could, with the consent of the patient or their representative, record a patient's nomination on the Personal Demographics Service.

If a patient has nominated a particular pharmacy, does a particular prescription have to be sent to that pharmacy electronically?

No. Even though a patient may have set a nominated pharmacy, they are free to request that the prescriber issues a standard paper FP10 prescription or a barcoded FP10 prescription. This may be preferable if the patient is, for example, planning to go to a pharmacy in Scotland or Wales, where the EPS is not available.

In time, following further regulatory change, it is anticipated that it will be possible to also issue electronic prescriptions to patients who have not nominated a pharmacy. When this happens, the patient would be able to request that they receive an electronic prescription and a prescription token that can be taken to any Release 2 enabled pharmacy.

Does a patient require separate electronic prescriptions for medicines and appliances?

If the patient requires both medicines and appliances, the prescriber must decide, as now, whether to generate two separate prescriptions. This will depend on where the patient wishes to have their medicines and appliances dispensed, for example if they wish to receive all items from the pharmacy or whether they would like an appliance contractor to dispense their appliances.

How should I confirm the identity of a patient who has nominated my pharmacy to receive their prescriptions and does not have a prescription token?

As with repeat collection services, this would be for a pharmacy contractor to determine as part of local standard operating procedures, for example, if the patient is not known to pharmacy staff, the patient may be asked to confirm their address and date of birth or if there is doubt over the patient's identify, the patient may be asked to show some form of ID.

What is the timescale from a pharmacy deploying EPS Release 2 to NHS Choices being updated?

When a R2 system is installed a commissioning prescription is scanned and a message sent to NHS Prescription Services. This triggers payment of the EPS Release 2 allowance. Also NHS Prescription Services send a message to NHS Choices, this happens on a weekly basis (Thursday). Between commissioning and the next Thursday night the pharmacy would be able to set nominations.


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