The CPAF was developed by NHS Primary Care Commissioning as a toolkit to assist Primary Care Trusts in assessing compliance and quality under the Community Pharmacy Contractual Framework (CPCF). The first toolkit was published in September 2005 as the CPAF and updated versions were produced by PCC, working with PSNC, over the subsequent years.

CPAF is made up of two parts – a pre-visit questionnaire which is completed by the pharmacy contractor before the monitoring visit and a section used by the commissioner during a monitoring visit.

In late 2020 new NHS regulations were laid to introduce changes to the Terms of Service for pharmacy contractors. This included requiring contractors to send on request to NHSE&I any information that could be requested at an inspection, such as a duly completed questionnaire (e.g. the CPAF screening questionnaire or full questionnaire). See Regs reminder (#11): NHSE&I inspections and access to electronic information for more information.

Within the Terms of Service, a contractor must allow persons authorised in writing by NHSE&I 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.

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 NHSE&I to carry out a detailed analysis of the content of the SOPs. Indeed, it would be unwise for NHSE&I 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 NHSE&I itself being involved in litigation.

For this reason, the most appropriate way for NHSE&I 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.

As part of the NHS Terms of Service for community pharmacies in England, there are various requirements for pharmacies to keep records of advice, interventions and referrals.

What sort of records need to be kept?

Records need to be kept in relation to:

What is the reason for keeping the records?

The terms of service require records to be kept ‘where appropriate’ or when ‘clinically significant’ so the pharmacy will need to consider for each provision of advice, intervention, or referral whether a record should be kept.  The record will be of no value if it is made just for the sake of making it – it must be linked to improving patient care, maintaining high quality service from the pharmacy or in some cases managing risk. For example records enable:

• the pharmacy to ensure that there is continuity of care e.g. a particular brand of medicine is supplied for a patient, allergies to particular excipients, medication is supplied with larger label fonts or in specific containers etc.
• other pharmacists and staff to understand what you discussed with a patient if you are not working in the pharmacy the next time the patient comes in to the pharmacy
• you to follow up on advice given or treatment recommended to enhance patient care particularly if you would want to double check that a patient had taken on board important advice.

Another reason to keep records is to manage risk. It is important to keep records of anything that concerns you in case you need to refer back to it in the future.

Where should we keep the records?

The records should be kept in the best way for your pharmacy that enables all pharmacy staff to make use of them to provide a high quality of service for the people who use your pharmacy.

This is most likely to be somewhere on your PMR ideally linked to the patients dispensing record.

If the records are kept separately in a book or a log for example, you will be less likely to be able to use them for the purposes described above.

NHS England may wish to discuss records of advice, interventions and referrals with you as part of a contract monitoring visit. It is important that you can describe what you do and provide some evidence.

How should we decide which pieces of advice and which interventions to record?

Pharmacies are unlikely to be able to record all the advice, interventions and referrals they make and indeed there is little benefit in recording every single piece of advice given. In deciding what to record think about:

• Risk management – is there something that has worried you?
• Have you made a significant difference to the patient?
• Is it something that another pharmacist or member of staff might need to know about the next time the patient visits?
• Is it something that you may need to refer back to in the future?

Who should make the records?

Any member of staff can make the records and this may be covered in your SOPs. It will depend where you make the records and how your pharmacy works.

It may be more likely that the pharmacist or other staff in the dispensary makes records in relation to dispensing and repeat dispensing. For public health, signposting and self-care, there could be a whole team approach.

How many records should we make?

The number of records will vary from pharmacy to pharmacy.  Experience has shown that pharmacy recording of advice, interventions and referrals have varied significantly and it is likely that patient care could be improved if more records were kept, which could then be acted upon at a later date.  There is no specified number of records required by the terms of service because each pharmacy will be different, but if you are giving advice every day, you are having to intervene several times a week and you find that referrals back to the GP are frequent, then your procedures which should encourage consideration of every incident to determine whether a record is needed, could lead to more records being kept than previously.