Prescribing within the CPCF

As part of negotiations on the Community Pharmacy Contractual Framework (CPCF) arrangements for 2026/27, it was agreed that prescribing (independent prescribing) will be introduced into the CPCF as an extension of Pharmacy First and the Pharmacy Contraception Service (PCS) from the autumn of 2026.

Community pharmacist prescribers will be enabled to:

• Prescribe within the existing Pharmacy First clinical pathways, instead of using the PGDs*.
• Prescribe within the Pharmacy Contraception Service (PCS), instead of using the PGDs*, with the ability to prescribe existing contraceptive products covered by the PGDs and some alternative contraceptive products.
• Provide five new Pharmacy First prescribing-only pathways. These consultations will count towards the monthly clinical pathways minimum activity requirement.
• ‘Prescription management’ i.e. prescribe an alternative item where there is a need to meet the needs of an individual patient, e.g. where there is a supply chain issue relating to the original prescription or a clinical error, and there are arrangements in place with the original prescriber to allow such an approach.

* Once a pharmacy starts to provide prescribing services within the CPCF, the NHS-authorised prescribers must prescribe medicines, where appropriate, when they provide Pharmacy First clinical pathways or PCS consultations; they cannot continue to supply medicines using the PGDs. Any pharmacists working at the pharmacy who are not an NHS-authorised prescriber can continue to provide those services using the PGDs.

The five new Pharmacy First prescribing pathways are:

1. Acute otitis externa – for adults aged 18 years and over
2. Seasonal allergic rhinitis – for children aged 4-11 years
3. Mild to moderate acne – for young people
4. Migraine – low frequency, episodic, adults aged 18-64 years
5. Mild skin and soft tissue infections and scabies

Supporting documentation and changes to the Terms of Service, Drug Tariff, Secretary of State Directions and service specifications will cover a range of clinical governance requirements related to prescribing activities.

Funding

Funding will include a one-off setup payment of £500 payable when a pharmacy owner has signed up to provide the relevant services and has a confirmed go-live date with an NHS-assured Electronic Prescribing Service (EPS) IT system.

Additionally, there will be a monthly infrastructure payment of £525 to support ongoing costs such as prescribing software, clinical supervision and other governance costs. This payment is subject to having a minimum prescriber availability of 24 hours per week (with some caveats – further details will follow shortly within the Drug Tariff).

Pharmacy owners will also receive the usual Pharmacy First or PCS consultation fees.

CPE’s view on the funding

In principle, we are supportive of the addition of prescribing to the CPCF, as it represents a strategically important service development for all in the sector.

However, while the funding for the sector is under such strain, we did not believe it was the right time for such a service to be introduced into the CPCF, with funding coming from the contract sum.

Instead, during negotiations we proposed to DHSC and NHS England that they agree with us a National Enhanced Service for prescribing that could then be commissioned locally by ICBs, with their local budgets funding the service.

For the Government, adding prescribing to the CPCF was a must, as it was a manifesto commitment.

However, despite our acceptance of the final CPCF offer, we are not persuaded that sufficient investment is being made to enable the full and effective introduction of prescribing, given the workload, enhanced clinical responsibility, clinical governance and infrastructure requirements that it will entail.

The clinical governance requirements (see below) are necessary to ensure a safe prescribing service, but they also require appropriate resourcing. That will not just be monetary, as in many cases, pharmacy owners will likely also need external support with implementing and sustaining the clinical governance requirements.

Throughout the negotiations, we raised our concerns that with the proposed funding, the addition of prescribing to the CPCF risked being set up to fail.

DHSC did increase the monthly payment level for pharmacies providing a prescribing service as a result of our arguments during the negotiations, but we do not believe it is set at a sufficiently high level when the IT and governance costs are considered.

Similarly, we believe a higher consultation fee should be paid for prescribing services compared to those provided using a PGD, due to the enhanced clinical responsibility of practising as a prescriber.

Ultimately, the CPE Committee had to decide on the overall final 2026/27 CPCF offer made by Ministers, which included the addition of prescribing to the CPCF. The wider benefits to the sector of a 10.3% funding increase and other elements of the final offer meant the offer was accepted, despite some elements not being to our liking, such as the funding for prescribing.

It will be down to pharmacy owners, cognisant of the above information, to decide on an individual basis whether it makes commercial sense for their business or whether they will instead prioritise the use of IP skills elsewhere in their business.

It will be imperative that next year, and in future years, sufficient funding is secured to fully support prescribing within the CPCF and we will be lobbying intensively for this.

Clinical governance requirements for prescribing

NHS England published two documents relating to the assurance of CPCF clinical services and the commissioning of NHS prescribing services in community pharmacies at the end of July 2026.

The first document – a professional assurance framework – applies to all CPCF clinical services and outlines the best practice guidance for all pharmacists and pharmacy technicians involved in the provision of NHS commissioned community pharmacy clinical services in England.

The document also contains expectations of pharmacy owners too. Any elements of the best practice guidance where pharmacy owners may not yet be compliant are likely to relate to the provision of NHS prescribing services. Those elements of the guidance only apply to pharmacies where NHS prescribing services are commissioned.

Professional assurance framework for delivering NHS community pharmacy clinical services

Pharmacy owners, and pharmacists and pharmacy technicians working in community pharmacies should all read the Professional Assurance Framework to assess whether they already comply with the best practice set out in the document and to identify any gaps in compliance that they can work towards meeting in their professional practice.

The second document provides guidance to Integrated Care Boards (ICBs) to apply when they are commissioning prescribing services from community pharmacies, both as local commissioning and the addition of prescribing into Advanced services within the CPCF:

Commissioning guidance for community pharmacy prescribing-based services

The document includes a range of expectations of pharmacy owners, where they are commissioned to provide an NHS prescribing service at a pharmacy.

As such, the document should be read by any pharmacy owners that provide an NHS commissioned prescribing service from their pharmacy or are planning to provide such a service in the future. Those pharmacy owners should then consider what steps they need to take to be compliant with the expectations of pharmacy owners set out in the document.

Alongside the publication of the two documents, NHS England has also written to ICBs setting out their expectations of ICBs in relation to establishing safe, effective and sustainable prescribing-based national services within community pharmacy. This will include ICBs agreeing and implementing an operational governance process for overseeing prescribing provision across community pharmacies in their geographic footprint.

Letter to ICBs: Preparing for prescribing in national community pharmacy services

The letter also highlights that NHS England will shortly share plans with ICBs for a Prescribing Development Programme to support locally commissioned, neighbourhood-based care models for community pharmacy.

CPE’s view on the guidance documents

NHS England sought our views on the draft versions of the two documents during the last round of negotiations. The Committee carefully reviewed them and concluded that the requirements in the documents did represent best practice, much of which most pharmacy owners would already comply with.

The requirements related to the introduction of prescribing into the CPCF are appropriate and will support the safe introduction of prescribing into NHS community pharmacy services, but some elements may not be straightforward to implement and in discussions with DHSC and NHS England, we have suggested that ICBs will need to provide practical support in relation to some of these elements, such as supporting the provision of clinical supervision and peer support networks at a local level.

As we said at the time of the announcement of the 2026/27 CPCF agreement (and above on this webpage) we are not persuaded that sufficient investment is being made to enable the full and effective introduction of prescribing, given the workload, enhanced clinical responsibility, clinical governance and infrastructure requirements that it will entail. The publication of these two documents now allows pharmacy owners to make their own assessment of the costs associated with the clinical governance of prescribing services.

Amendments to the Terms of Service related to prescribing

Another element of the governance for prescribing within the CPCF is amendments to The National Health Service (Pharmaceutical and Local Pharmaceutical Services) Regulations (within the Terms of Service). These were laid before Parliament on 3rd September 2026 and apply from 1st October 2026.

They codify the circumstances when NHS prescriptions can be written by a prescriber at a pharmacy and can then be dispensed at the pharmacy.

The relevant wording from the Amendment Regulations is set out below:

A summary of those requirements

A pharmacy owner may not dispense an NHS prescription issued by a prescriber (e.g. a pharmacist prescriber) they employ or engage unless:

(1) The prescription is issued as part of, and in compliance with, a directed service, i.e. an Advanced or Enhanced service. For the time being, prescribing will be allowed in the following Advanced services: Pharmacy First and the PCS. ICBs may also commission prescribing services as part of a local Enhanced service; or

(2) The EPS prescription issued by a prescriber at the pharmacy replaces a prescription issued by a prescriber at a general practice and the replacement prescription is issued with the agreement of the prescriber of the original prescription which is being replaced. This activity is being called ‘Prescription management’ and separate guidance on this will be published by NHS England shortly.

The agreement may relate to the replacement of a specific prescription or it could, for example, be a general agreement to the replacement of a certain category of prescriptions in specified circumstances.

The pharmacy employed or engaged prescriber must carry out a best interests assessment and prescribe in accordance with that assessment.

The replacement prescription must be a prescription only medicine or appliance that general practice prescribers are permitted to prescribe under their NHS contract.

The pharmacy must have an SOP for prescribing and dispensing at the same pharmacy and for carrying out a best interests assessment.

A best interests assessment is an assessment that a medicine or appliance is:

(a) clinically appropriate and in the best interests of the patient for whom the drug or appliance is ordered;

(b) consistent with best practice within the NHS with regard to obtaining value for money for the NHS; and

(c) in all other respects professionally appropriate.

Prescribing of replacement prescriptions as described above can only be undertaken by a pharmacy employed or engaged prescriber where the pharmacy is also providing an Advanced service which includes prescribing, as described in (1) above.

NHS reimbursement and remuneration for dispensing a prescription issued by a prescriber who is employed or engaged, will not be paid where NHS England is of the view that it is not authorised by the PLPS Regulations (i.e. not one of the two circumstances briefly outlined above).

Interim IT arrangements

NHS England are working with IT system suppliers under the Digital Services for Integrated Care (DSIC) IT framework to develop new standardised consultation record functionality for community pharmacy services, which will fully support prescribing services.

Until that new IT functionality is added to clinical IT systems, an interim approach will be required for the IT used to support the provision of prescribing services.

That will involve using CLEO EPS as the only prescribing system for community pharmacy-based prescribers currently approved for use by the NHS. NHS England expect other prescribing systems will be approved for use in due course.

The pharmacy owner’s existing clinical IT system modules used for Pharmacy First and PCS PGD consultation records cannot be used for prescribing consultations (any pharmacists working at the pharmacy who are not a prescriber can continue to use the existing clinical IT system modules for their PGD consultations). Consequently, an alternative consultation records system or module will have to be used.

That means GP Connect Update Record functionality will not be available and updating the patient’s GP will have to be via an NHSmail message.

There will be no API in place with MYS, so a manual claim for each consultation will need to be made in MYS, which will include patient details, the date of the consultation, the prescriber’s GPhC number, the pathway/service provided, the outcome of the consultation and the name of any medication prescribed.

NHS England is holding a webinar on 1st October 2026 (6.30pm – 7.30pm) for pharmacy owners on the IT systems they will need to have in place to provide prescribing within the CPCF.

Register to attend the webinar

CPE’s view on the interim IT arrangements

The interim IT arrangements for the rollout of prescribing within the CPCF are far from ideal and we have provided frank feedback to NHS England and DHSC on the significant shortcomings of the arrangements.

Pharmacy owners considering providing CPCF prescribing services need to reflect on those arrangements as part of their overall consideration as to whether the operational and governance requirements to provide the service and the funding on offer make commercial sense for their business.

The inclusion of prescribing within the CPCF is a strategically important development for community pharmacy and could be a gateway to a significantly expanded role for the sector. However, as we said at the time of the announcement of the 2026/27 settlement, despite our acceptance of the final CPCF offer, we are not persuaded that sufficient investment is being made to enable the full and effective introduction of prescribing, given the workload, enhanced clinical responsibility, clinical governance and infrastructure requirements that it will entail.

The sign-up process for pharmacy owners

We have agreed with DHSC that prior to any formal decisions on signing-up to provide prescribing services within the CPCF, pharmacy owners need to have all the necessary information on which to make a fully informed judgement.

At this time, they do not have all the necessary information, as clinical and wider guidelines related to the five new Pharmacy First pathways, prescribing within the PCS and issuing new prescriptions under ‘Prescription Management’ are not yet published.

Neither have the updated service specifications for Pharmacy First and the PCS been published, so pharmacy owners can review them prior to potentially signing up to provide prescribing services.

Pharmacy owners will have to formally sign-up to provide CPCF prescribing services by completion of a form hosted by the NHSBSA. We expect that form to be made available for completion at some point in October 2026, subject to all the other necessary work having been completed by NHS England and DHSC, with all the documentation pharmacy owners need to review before signing up having been published.

Frequently asked questions

 Q. How is the EPS IT necessary for the introduction of IP into the CPCF to be funded?
DHSC and NHS England expect the cost of the EPS system to be covered by the one-off setup payment of £500 and the monthly infrastructure payment of £525.

Q. Will consultations within the new Pharmacy First prescribing-only pathways count towards the monthly clinical pathways minimum activity requirement (for the £500/£1000 payment)?
Yes.

 Q. When will IP be implemented into services?
Subject to the necessary preparatory work being completed by NHS England and DHSC, IP will start in the autumn (likely in October).

Q. How does IP apply to Distance Selling Premises (DSP) pharmacies?
Where a DSP pharmacy provides the current Pharmacy First and PCS via remote consultations, an IP could prescribe within the scope of those services. Similarly, the provisions for issuing replacement prescriptions, e.g. where there are supply chain issues, would also apply to DSP pharmacies with an IP.

During the development of the five additional prescriber-only Pharmacy First clinical pathways, consideration will be given to whether those conditions are suitable for management via remote consultations.

For more information on this topic please email services.team@cpe.org.uk