On 20th October 2020 new NHS regulations were laid to introduce changes to the Terms of Service for pharmacy contractors. Some of these changes relate to the ongoing coronavirus pandemic, but most are changes which were previously agreed as part of the 5-year Community Pharmacy Contractual Framework (CPCF) and were originally planned to be introduced in July 2020.

This is the final article in this series, explaining what the changes mean for pharmacy contractors and their teams.

This change applies from:

1st January 2021

What are the new requirements?

As a result of the Healthy Living Pharmacy Level 1 (HLP) criteria becoming Terms of Service requirements from 1st January 2021, almost all pharmacies will need to have a consultation room.

The requirement for the consultation room is based on the existing requirement for a consultation room which is included in the service specifications of most of the Advanced services; most pharmacies already comply with these requirements.

The requirements for the consultation room are that it is:

• clearly designated as a room for confidential conversations, for example a sign is attached to the door to the room saying Consultation room;
• distinct from the general public areas of the pharmacy premises; and
• a room where both the person receiving the service and the person providing it can be seated together and communicate confidentially.

Contractors who have not previously installed a consultation area will need to develop and implement a plan to do so. If the pharmacy is included in a pharmaceutical list on 1st January 2021, but no Advanced services were provided at or from the pharmacy during the 12 months ending 31st December 2020, the contractor will have until 1st April 2023 to install a consultation room within their pharmacy.

Contractors who open new pharmacy premises on or after 1st January 2021 will need to have a consultation room from the first day they open for business.

Small pharmacies

Where a contractor believes that their pharmacy is too small for a consultation room, they will need to complete and submit a request to their NHS England and NHS Improvement (NHSE&I) regional team (NHSE&I have published a form on which to make this request).

NHSE&I will consider the information provided by the contractor and where it is of the opinion that the pharmacy is too small for a consultation room, it will confirm this with the contractor. The contractor must then ensure that they put arrangements in place at the pharmacy which enable staff and patients to communicate confidentially by telephone or another live audio link and a live video link.

Where NHSE&I are of the opinion that the pharmacy is not too small for a consultation room, the contractor will be advised of this and they will need to install a consultation room.

Distance Selling Pharmacies (DSPs)

DSPs must ensure that there are arrangements in place at the pharmacy which enable staff and patients to communicate confidentially by telephone or another live audio link and a live video link.

DSPs can choose to install a consultation room at their pharmacy to allow the provision of Enhanced and Advanced services on the premises, but this is not a requirement of the Terms of Service.