Patient choice and IT

The NHS Constitution guarantees patients’ continued entitlement to fair choice.

If new technologies limit this freedom, healthcare providers and patients must take action to ensure that patient choice remains unrestricted. Additionally, the Care Quality Commission (CQC) and the General Pharmaceutical Council (GPhC) require GP practices and pharmacies to uphold patient choice and autonomy. They must also adopt tools that facilitate and support this principle.

Patients have the right to choose any pharmacy for their services, and their choice should not be unduly influenced.

{Download this guide in pdf format}

Community pharmacies sometimes encounter situations where a patient’s choice of pharmacy is being limited — for example, when an app or digital service redirects Electronic Prescription Service (EPS) prescriptions or NHS services without clear permission.

Protecting patient choice is a core NHS duty for all people working within health and care.

Here we explain how patients, pharmacy teams, and LPCs can raise concerns, what information NHS England needs.

1. When patients want to make a complaint

Patients have the right to choose which pharmacy they use for NHS prescriptions and services.

If a patient believes their choice is being restricted — such as:

• being steered towards a particular pharmacy,
• an app auto‑routing prescriptions without clear consent, or
• any form of pressure or suggestion that limits their options,

They can contact their local NHS team (ICB) to make a complaint. Local NHS contact information can be found via NHS regional webpages.

Complaints can be submitted anonymously or directly, and patients can request that their GP practice not be informed.

They may also decide whether to cc other relevant parties into their complaint, such as their preferred pharmacy.

2. How pharmacy teams or LPCs can raise concerns

Pharmacy teams and LPCs can raise concerns directly with their Integrated Care Board (ICB).

To help the ICB assess the issue quickly, please set out the concern in writing with clear and structured information.

a. Which organisation(s) were involved

• Include ODS codes where known
• Specify whether the organisation is a pharmacy, app, website, or service provider

b. What the impact was

Describe the practical and clinical impacts on:

• your pharmacy (e.g. diverted prescriptions, reduced EPS nominations),
• your patients (e.g. confusion, complaints, delays), or
• your local area (e.g. widespread redirection patterns).

c. Any evidence you can provide

Useful examples include:

• activity data or statistics
• relevant EPS information
• patient comments or written feedback
• screenshots or messages from apps or services
• timeline of events

d. A proposal on how the issue might be resolved (optional)

Queries may additionally be directed from pharmacy teams and LPCs directly towards technology providers for digital choice-related issues, who will sometimes be able to adjust or resolve the issue.

3. How ICBs and the NHS progress issues

ICBs may escalate issues to the central NHS England pharmacy team.

Where a concern relates to an NHS IT system, EPS behaviour, or a technical supplier the ICB or the NHS England pharmacy team may contact as needed:

• a system provider for clarification.
• specialist NHS digital teams (e.g. the NHS EPS team and the NHS GP IT team), if the matter is technical or system‑

These NHS digital teams may do other joint work directly with many of the IT providers.

4. Sharing updates with Community Pharmacy England’s IT team for it’s information

LPCs may share email threads or summaries sent to ICBs or IT providers with Community Pharmacy England’s IT lead for its information. Whilst we do not contract with the technology companies, and the regulation of technology companies is outside of our role, this intelligence strengthens our ability to influence and improve pharmacy arrangements and IT nationally. We may be able to support relevant parties through the patient choice IT escalation process if escalation has not yet been carried out or the parties are not already aware of this patient choice IT escalation route (points 1-4 immediately above).

What this supports

This escalation route aligns with:

• NHS patient choice duties
• Community Pharmacy IT Group principles, including digital inclusion, user-centred design and burden reduction
• NHS Fit for the Future ambitions around fair access and trusted digital services
• Equitable, interoperable pharmacy IT: The sector’s long-term vision

EPS nomination and systems

• Enable automated checks of a patient’s nomination setting.
  Systems should not routinely check or monitor which pharmacy a patient is nominated to. This helps avoid unintended interference with patient choice.
• Support the capture or use of “enduring consent” for nomination.
  Systems must not store or apply long-term consent that could override a patient’s active decision to nominate a different pharmacy. Consent should always reflect the patient’s current wishes.

Read more see our EPS nomination page.

Patient Facing Services (PFS) & assurance

NHS England assurance of IT tools which have completed PFS integration

Key points about patient choice and Patient Facing Services (PFS) (also known as “GP online services”) include the following:

• NHS England assures certain PFS functionalities, such as tools with these PFS features:
  1. Access to Electronic Health Records.
  2. Ordering repeat prescriptions.
  3. Booking GP appointments.
  4. Specific GP-practice communications to patients.

Some pharmacy owners provide apps, tools, or platforms that enable PFS for their patients. Pharmacy owners should explore ways to help patients leverage PFS, such as promoting the NHS App or equivalent tools that allow access to PFS without unduly influencing pharmacy choice.

IT providers, website providers, and app developers offering tools that assist patients in selecting a pharmacy must provide balanced information to ensure patients can make fair and informed choices.

Patients should always retain the ability to decide whether to use an app and their preferred pharmacy.

Principles of patient choice of pharmacy within technical tools

The list:

1. Patients must be free to select a pharmacy of their choice to dispense their prescription or provide other clinical pharmacy services.

2. Patient sign-up for the nomination process or service must be separate and unbundled from any other sign-up procedures. It should also require proactive agreement (not a pre-ticked box).

3. Patient information using the NHS logo must not, directly or indirectly, direct a patient’s choice of pharmacy (take a patient’s choice of pharmacy) for dispensing or other pharmacy services.

4. Patient information using the NHS logo should follow the NHS England processes for nomination and freedom of patient choice.

5. Patient information must comply with the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013 regarding nominations and the relevant NHS England service specifications.

6. Patient information provided by General Practitioners to assist with the choice of pharmacy must include a suitable and relevant  fair list.

7. Pharmacies (including those using third-party apps) must have the informed consent or agreement of a patient to dispense the patient’s prescription and the provision of pharmacy services.

8. Pharmacies must comply with the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013, specifically, the regulations on the nomination of prescriptions and prescription inducements (including when using third-party apps).

9. General practitioners must not attempt to persuade a patient to choose a specific pharmacy (as specified in the GP contract), including when using third-party apps.

10. The NHS logo should be used only in accordance with NHS identity guidelines, e.g., by service providers, and not by third parties.

11. The criteria for NHS-approved technologies, or any similar NHS approval procedure (NHS IM1 integration, NHS GP IT Futures, etc), and continued assured status, should be given/continued only if there is adherence to the above criteria (1-10).

The NHS Constitution guarantees patients’ continued entitlement to fair choice. Service specifications also outline service-specific arrangements to protect patients’ choices of a pharmacy.