Prescribing within the CPCF

The introduction of pharmacist prescribing into the CPCF has long been an ambition of Community Pharmacy England and the wider community pharmacy sector.

In their Vision for Community Pharmacy, published in September 2023, the King’s Fund and Nuffield Trust identified pharmacist prescribing being at the centre of many of the future clinical services that the NHS could commission from community pharmacies. It also featured within many of the priority service developments we identified and lobbied for after the publication of the Vision.

Ahead of the 2024 General Election, the Labour Party Manifesto included a commitment to create a Community Pharmacist Prescribing Service, granting more pharmacists independent prescribing rights where clinically appropriate. And in 2025, the new Government’s 10 Year Health Plan for England: fit for the future also highlighted the future role community pharmacy could play in the management of long-term conditions, utilising the skills of pharmacist prescribers.

Following that, the NHS Medium Term Planning Framework 2026–2029 set out a commitment to introduce prescribing-based services into community pharmacies during 2026/27. This is part of a wider need for Integrated Care Boards (ICBs) to support primary care access with an increasing role for community pharmacy.

The NHS England workforce survey 2025 indicates that there is a ratio of one community pharmacist prescriber to 5 pharmacy premises, with data from the historic surveys showing year on year growth in the number of pharmacist prescribers working in community pharmacies in England. Additionally, from September 2026, newly qualified pharmacists entered the General Pharmaceutical Council (GPhC) register as prescribers.

Introducing prescribing into the CPCF is therefore key to unlocking the potential these opportunities present.

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CPE’s view on the addition of prescribing to the CPCF

In principle, we are very 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 Labour Party manifesto commitment.

Please also read about our concerns regarding the specific fees payable related to the provision of prescribing services in the Funding and claiming payment section of this webpage.

The introduction of prescribing into the CPCF requires several legislative and contractual changes, and the publication of a range of guidance to support pharmacy owners and pharmacist prescribers*, including:

• changes to the Terms of Service within the National Health Service (Pharmaceutical and Local Pharmaceutical Services) Regulations (see details in a section below);
• additions and changes to the Drug Tariff (see further information in the Funding and claiming payment section below);
• revised Pharmacy First and PCS service specifications;
• amendments to the Secretary of State Directions relating to Advanced services;
• the publication of the Prescribing Specification;
• the publication of the five new Pharmacy First prescribing clinical pathways and associated guidance, prescribing guidance related to the existing seven Pharmacy First clinical pathways and prescribing within the PCS;
• the publication of guidance on Prescription Management; and
• guidance on clinical governance requirements related to prescribing activities set out in a Professional Assurance Framework and Commissioning guidance for ICBs.

Some of that documentation has already been published and links to the documents can be found below.

Links to documents can also be found on the NHSBSA website.

DHSC and NHS England are working on finalising the outstanding documentation and those will be published as soon as possible.

* The introduction of prescribing within the CPCF only covers pharmacist prescribers. It does not allow other non-pharmacist prescribers to prescribe within the CPCF.

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Revised Pharmacy First and PCS service specs

With prescribing being added to Pharmacy First and the Pharmacy Contraception Service, the service specifications for both of the services need updating. NHS England and DHSC are currently working with us to update those service specifications.

These updates will identify which requirements apply to all pharmacies providing the services and which requirements are specific to consultations using PGDs or prescribing by pharmacist prescribers.

The updated Pharmacy First service specification will also include a number of wider amendments and clarifications intended to support consistent service delivery, governance and assurance arrangements. These include enhanced guidance on urgent medicines supplies.

Pharmacy owners should review the updated specifications when published and consider whether any updates are required to local SOPs, governance arrangements and operational processes ahead of implementation of the revised service requirements

The service spec requirements still apply to prescribing consultations

The provisions set out in the two service specifications still apply to pharmacist prescribers providing the services.

For example, all consultations must be verbal (face-to-face or remote) and must be provided at or from the pharmacy premises. ‘From the pharmacy premises’ is referring to remote consultations with a patient, meaning the pharmacist prescriber undertaking the remote consultation must be at the pharmacy premises, which must be the same premises that is linked to the NHSBSA Prescribing Cost Centre.

Once a pharmacy starts to provide prescribing services within the CPCF, the NHS-authorised prescribers in that pharmacy 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 (pharmacists who are not prescribers or pharmacist prescribers who have not been onboarded and authorised to prescribe by the NHS) can continue to provide those services using the PGDs.

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Secretary of State Directions

The Secretary of State Directions related to the provision of Advanced services within the CPCF provide the legal basis for the commissioning of those services and they need to be amended to reflect the addition of prescribing to the CPCF.

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Prescribing Specification

A separate NHS Community Pharmacy Prescribing Specification has also been drafted and published in draft form on the NHSBSA website; this document sets out the requirements that will apply to the provision of NHS prescribing services within the CPCF.

NHS Community Pharmacy Prescribing Specification

This is a final draft of the guidance. The guidance is currently working its way through the NHS England publication authorisation process and once that is completed, the final version of the guidance will be published on the NHS England website.

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Pharmacy First prescribing clinical pathways

NHS England is finalising work on the five new prescribing clinical pathways which will be added to Pharmacy First:

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

*Provision of these consultations will count towards the monthly Pharmacy First clinical pathways minimum activity requirement to receive the payment of either £1000 or £500.

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Prescribing guidance for Pharmacy First and PCS consultations

NHS England is developing guidance for pharmacist prescribers in relation to prescribing within the existing seven Pharmacy First clinical pathways and the PCS.

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Prescription Management guidance

NHS England has produced guidance to support pharmacist prescribers with prescription management.

Prescription management allows NHS onboarded pharmacist prescribers working in a pharmacy authorised to provide NHS prescribing services to issue new prescriptions that support safe and timely access to medicines when an NHS prescription is presented for dispensing at the pharmacy and cannot be supplied as written.

The addition of prescription management arrangements to the CPCF is an enabling change for pharmacist prescribers, but it is not a mandatory requirement.

Where it is used by pharmacist prescribers, they will need to make contemporaneous records of the consultation with the patient in the pharmacy’s clinical system used for prescribing consultation records and they will need to send a summary of the consultation and outcome via NHS.net Connect (formerly NHSmail) to the patient’s general practice. The original prescription item will also need to be marked as ‘Not dispensed’ in the PMR system.

No payment will be made under the CPCF for any prescription management activity undertaken.

Download the NHS England Prescription Management guidance

This is a final draft of the guidance. The guidance is currently working its way through the NHS England publication authorisation process and once that is completed, the final version of the guidance will be published on the NHS England website.

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Professional Assurance Framework

NHS England published the professional assurance framework in July 2026. It 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.

The framework sets out the governance, workforce, training, digital and clinical assurance arrangements that must be in place before prescribing activity can commence, helping pharmacies and ICBs demonstrate readiness and maintain safe, effective and high-quality patient care.

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.

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Commissioning guidance for prescribing-based services

NHS England also published guidance for ICBs in July 2026. This guidance applies when ICBs 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 are considering providing an NHS commissioned prescribing service from their pharmacy. 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.

There are also some important subsidiary documents and templates that pharmacy owners considering providing an NHS commissioned prescribing service should read, including:

Incident recording guidance for NHS prescribing-based services in community pharmacy

Prescribing service risk assessment template

Alongside the publication of the two documents, NHS England also wrote to ICBs setting out their expectations of ICBs in relation to establishing safe, effective and sustainable prescribing-based national services within community pharmacy. This includes 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 work with the ICBs on a Prescribing Development Programme to support locally commissioned, neighbourhood-based care models for community pharmacy.

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Risk assessment

NHS England’s Commissioning guidance for community pharmacy prescribing-based services says ICBs should require a pharmacy owner to complete a risk assessment specific to the prescribing-based service and implement controls to mitigate any identified risks. This should require the pharmacy owner to, as a minimum:

• Identify and mitigate the risks associated with provision of the prescribing-based service which may include, but are not limited to, clinical, digital, and operational risks.
• Consider how prescribing and dispensing by the same healthcare professional, when this is necessary in the best interests of the patient, will be managed to maintain patient safety.
• Have safeguards in place for managing high-risk patients, complex clinical presentations and vulnerable individuals and minors.
• Evaluate how the integration of prescribing and dispensing functions may impact clinical objectivity or patient choice due to commercial incentives and conflicts of interest.
• Ensure plans are in place to support continuity of service delivery if the regular pharmacist prescriber is absent or the service cannot be provided.
• Develop standard operating procedures to support the safe and consistent delivery of services.

NHS England has a risk assessment template that pharmacy owners can use.

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CPE’s view on the Professional Assurance Framework and ICB commissioning guidance

NHS England sought our views on the draft versions of the two documents during the 2026/27 negotiations. The Committee carefully reviewed them and concluded that the requirements in the documents did represent best practice, much of which 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 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.

Please also read about our concerns regarding the specific fees payable related to the provision of prescribing services in the Funding and claiming payment section of this webpage.

Ahead of a pharmacy owner signing-up to provide prescribing services within the CPCF  there is a significant amount of preparatory work which needs to be undertaken.

At the point of completing the sign-up form (see further information on the sign-up process below), the pharmacy owner will be declaring that they have completed the required preparatory work, reviewed the supporting documents and will deliver the service in accordance with their requirements.

This section of the webpage sets out preparatory work we have identified that pharmacy owners will need to undertake, but there may be other actions required, including to comply with any internal business rules or, for example, the stipulations of the pharmacy owner’s indemnity insurance provider.

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Initial prerequisites

The starting point for a pharmacy owner considering providing prescribing within the CPCF is to ensure they meet the following prerequisites:

• Be satisfactorily complying with their obligations under Schedule 4 of the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013 (Terms of Service of NHS pharmacists) in respect of the provision of Essential services and an acceptable system of clinical governance.
• The pharmacy is not subject to any investigation, restriction, suspension or enforcement action by the GPhC, the ICB or other related NHS body, or any other regulatory authority that could affect its ability to provide the service.
• Already providing Pharmacy First and/or the PCS at the pharmacy.
• Have sufficient access to a pharmacist prescriber, registered with the GPhC, with the appropriate register annotation and with no relevant restrictions imposed in relation to Fitness to Practise proceedings.
• Understand and expect to be able to meet the minimum prescribing service level to the public during the week/year (a minimum of 24 hours per week during the pharmacy’s opening hours for at least 45 weeks in each financial year).

If all of the above pre-requisites are met, the pharmacy owner then needs to review the following documents, to ensure they fully understand the requirements and expectations related to providing prescribing within the CPCF and can comply with them:

• Revised Pharmacy First service specification (if the pharmacy is providing that service).
• Revised PCS service specification (if the pharmacy is providing that service).
• NHS England Prescribing Specification.
• The five new Pharmacy First prescribing clinical pathways and associated clinical guidance (if the pharmacy is providing that service).
• Prescribing guidance for Pharmacy First and PCS consultations.
• NHS England guidance on Prescription Management.
• NHS England Professional assurance framework for delivering NHS community pharmacy clinical services.
• NHS England Commissioning guidance for community pharmacy prescribing-based services.
• NHS England’s employer checklist.
• Changes to the Terms of Service within the National Health Service (Pharmaceutical and Local Pharmaceutical Services) Regulations.
• Additions and changes to the Drug Tariff.
• Amendments to the Secretary of State Directions relating to Advanced services.

Further information and links to these documents (where published) can be found in the Service specifications and other documentation section of this webpage.

Those documents contain a long list of requirements that the pharmacy owner and/or pharmacist prescriber need to comply with. We advise pharmacy owners to work through the documents with their pharmacist prescriber(s) to assess compliance with the requirements and to create an action plan for the areas where work is still required to achieve compliance.

Specific tasks that pharmacy owners will need to undertake include:

• Procuring an IT system in which clinical records of prescribing consultations will be recorded.
• Procuring an EPS prescribing system.
• In relation to both those IT systems, pharmacy owners need to comply with NHS Digital clinical safety standards, including the two clinical risk management standards: DCB0129 and DCB0160. Read more about these requirements in the Digital clinical safety standards section of the Commissioning guidance for community pharmacy prescribing-based services.
• Once a pharmacist prescriber has been authorised by the ICB, working with the local Registration Authority to ensure the prescriber has an NHS care identity with an appropriate authenticator (CIS2 authentication and AAL3) and the required access rights to undertake prescribing to ensure that the correct role-based access control (RBAC) is in place for the use of EPS. Read this NHS England guidance first: Independent prescribing pharmacist authentication guidance for NHS prescribing-based services in community pharmacy.
• Putting in place appropriate indemnity arrangements for the provision of prescribing services.
• Updating business continuity and escalation plans.
• Supporting pharmacist prescribers to access communities of practice and/or peer networks where they exist for pharmacists providing prescribing services.
• Ensuring that pharmacist prescribers complete a declaration of fitness for purpose, including their prescribing scope of practice, and submit this to the pharmacy owner for retention in their files. The declaration should be updated annually or more frequently if their prescribing scope changes or if the pharmacist is no longer involved in prescribing.

Some of the requirements that may need more significant effort to achieve compliance, and which pharmacy owners may want to prioritise tackling include:

• Developing or updating an existing standard operating procedure (SOP) which covers prescribing provision. The SOP must include the process for escalation of clinical and non-clinical issues identified, record keeping, equipment maintenance and validation, and staff training. Additionally, it must include the process for dispensing of a prescription from the premises at which the prescription was generated and evidence of a risk assessment taking into account prescribing and dispensing by the same pharmacist to maintain patient safety.
• Undertaking a risk assessment for the addition of prescribing to the CPCF services at the pharmacy. NHS England has a risk assessment template that pharmacy owners can use.
• Ensuring pharmacist prescribers have a clear development plan to upskill themselves to provide any element of the five prescribing Pharmacy First clinical pathways and/or the Pharmacy Contraception Service that they are not yet competent to provide.
• Ensuring pharmacist prescribers have regular access to a named clinical supervisor or prescribing mentor and time allocated regularly to complete a review of prescribing practice (prescribing appraisal) between the prescriber and their clinical supervisor. NHS England Supervision guidance for primary care network multidisciplinary teams can be used by pharmacy owners as a guide to implementing clinical supervision for pharmacist prescribers.

Once the initial prerequisites are met, the pharmacy owner also needs to plan how they will ensure ongoing compliance with all the requirements related to prescribing within the CPCF. That will include:

• Processes to ensure that prescribing pharmacists only undertake prescribing activity within their scope of practice and competency, as set out in the Royal College of Pharmacy Competency Framework for all Prescribers.
• Maintaining documentary evidence that pharmacist prescribers are competent and remain up to date with regards to the specific skills and knowledge that are appropriate to their role, and to the aspects of the services they are providing.
• Ensuring a process is in place to systematically review the quality, safety and effectiveness of prescribing through regular audit, such as, quality improvement audits and prescribing audits.
• Recording any events that meet the national definition of a patient safety incident via the learn from patient safety events (LFPSE) service. The prompt code ‘COIN1’ should be used when recording incidents relating to NHS-commissioned prescribing services. Further guidance on this topic can be found in this NHS England document: Incident recording guidance for NHS prescribing-based services in community pharmacy.

Finally, the pharmacy owner needs to ensure they will be ready to provide prescribing services at or from the pharmacy from the date of approval by their ICB.

The sign-up and authorisation process (onboarding) includes two aspects of approval by the ICB:

1. for the individual pharmacy premises; and
2. for the prescribers who will prescribe from those premises.

NHS England has published a slide set with further information on the onboarding process:

NHS England onboarding process slideset

Pharmacy owners must complete the Prescribing Consultation Claims Declaration Form, which can be found on the NHSBSA website, to formally request authority to provide prescribing within the CPCF from their pharmacy premises.

The completed form must be emailed to prescribingconsultationclaims@nhsbsa.nhs.uk.

Pharmacy owners must complete this form for each pharmacy premises they wish to sign-up.

Submission of this form does not itself confer approval to provide prescribing at the pharmacy; approval is subject to confirmation by the pharmacy’s ICB.

We advise pharmacy owners to read all the documents detailed in the Service specifications and other documentation section of this webpage before completing the declaration.

Only pharmacist prescribers that have been approved by the ICB in accordance with its onboarding process will be authorised to undertake NHS prescribing services. This includes where the pharmacist prescriber works across more than one pharmacy, e.g. as a locum.

The form requests information on the pharmacist prescriber or prescribers who will be providing NHS prescribing consultations once the pharmacist/pharmacists and the pharmacy are authorised by the ICB.

It also includes a declaration that seeks confirmation from the pharmacy owner that certain pre-requisites to providing prescribing at the pharmacy are complete or true, such as the pharmacy owner having reviewed specified supporting documents related to the provision of prescribing within the CPCF (see further guidance on this in the Preparations before completing the sign-up process section above).

The completed form will be shared with the pharmacy’s ICB and they will then consider the information provided in it and will make a decision on authorisation of the pharmacy to provide NHS prescribing services. The information supplied on the form will also allow the ICB to confirm whether each prescriber listed meets the applicable onboarding and governance requirements.

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Future changes in circumstances

If in the future there is a change in the circumstances related to the provision of prescribing services, the pharmacy owner must notify the ICB within five working days of becoming aware of any change, including where a notified pharmacist prescriber ceases to work at the pharmacy, is no longer available to provide prescribing consultations or no longer meets the applicable onboarding requirements.

Where a pharmacy owner wishes to add an additional pharmacist prescriber following initial onboarding of the pharmacy, they must notify the ICB and obtain their approval before that pharmacist undertakes NHS prescribing consultations.

The Drug Tariff requirements also require pharmacy owners to provide, within five working days of a request, any further information reasonably requested by the ICB for assurance, governance or service monitoring purposes.

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Change of pharmacy ownership

Where there is a change of pharmacy ownership that results in a new ODS code, the new pharmacy owner must complete the full onboarding requirements for NHS prescribing services. Once those are completed, they will be eligible for a Setup payment and subsequent Monthly Infrastructure Payments.

Where the pharmacy’s ODS code does not change, the new pharmacy owner must confirm to the ICB that the information previously supplied remains accurate. In this scenario, no further Setup payment will be payable.

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A key element of the governance for prescribing within the CPCF is amendments to the Terms of Service within The National Health Service (Pharmaceutical and Local Pharmaceutical Services) Regulations.

The amendments were laid before Parliament on 3rd September 2026 and they came into force on 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:

Conditions relating to independent prescribing 66A.—(1) It is a condition of the inclusion of each NHS pharmacist in a pharmaceutical list that the NHS pharmacist must not provide a drug or appliance that is ordered on a prescription form by a prescriber who is or who is employed or engaged by the NHS pharmacist, except as provided for by this regulation. (2) An NHS pharmacist may provide a drug or appliance that is ordered on a prescription form by a prescriber who is or who is employed or engaged by the NHS pharmacist where— (a) the drug or appliance is provided as part of a directed service; (b) the terms on which the arrangements are made for the provision of the directed service allow for the provision, by the NHS pharmacist, of a drug or appliance ordered on a prescription form by a prescriber who is or who is employed or engaged by the NHS pharmacist; and (c) any conditions that are part of those arrangements and that relate to the ordering on a prescription form of a drug or appliance by a prescriber who is or who is employed or engaged by the NHS pharmacist, or to the provision of a drug or appliance in accordance with a prescription of such a prescriber, are met. (3) An NHS pharmacist may, as part of an essential service, provide a drug or appliance that is ordered on a prescription form by a prescriber (P) who is or who is employed or engaged by the NHS pharmacist only if— (a) the NHS pharmacist is also the provider of a directed service as part of which P is entitled to order drugs or appliances on a prescription form; (b) the NHS pharmacist has in place standard operating procedures that relate to prescribing and dispensing drugs or appliances on the same pharmacy premises and to carrying out best interests assessments prior to prescribing at those premises; (c) the order by P replaces an order by a prescriber who is or who is employed or engaged by a provider of primary medical services and it replaces that order with the agreement of the provider of primary medical services (the agreement may relate to the replacement of a specific order or to replacement of a pre-arranged category of orders, where the specific order is within that category); (d) the order by P is on an electronic prescription form and is for a prescription only medicine, the ordering of which is not restricted under the Prescription of Drugs Regulations; and (e) before placing the order, P carries out a best interests assessment, and the placing of the order is in accordance with that best interests assessment. (4) For the purposes of paragraph (3), a best interests assessment is an assessment that an order for a drug 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 health service with regard to obtaining value for money for the health service; and (c) in all other respects professionally appropriate. (5) No pharmaceutical remuneration is payable in respect of the provision of a drug or appliance that is ordered on a prescription form by a prescriber who is or who is employed or engaged by the NHS pharmacist who claims the pharmaceutical remuneration, where such provision is, in the opinion of NHS England, otherwise than as provided for by this regulation.”.

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 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 part of the regulations is  describing Prescription management.

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:

1. clinically appropriate and in the best interests of the patient for whom the drug or appliance is ordered;
2. consistent with best practice within the NHS with regard to obtaining value for money for the NHS; and
3. 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).

You will find some FAQs related to the Terms of Service changes in the FAQs section of this webpage

Future IT support for community pharmacy prescribing and other clinical services

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 clinical services, which will fully support prescribing services and will include integration with other systems, such as APIs with MYS and GP Connect functionality.

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.

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Interim IT arrangements

Pharmacy owners will need the following IT functionality/systems to support their pharmacist prescribers in prescribing consultations:

1. A clinical system to record prescribing consultations.
2. Access to the patient’s clinical records, for example via GP Connect Access Record, National Care Record Service or a local Shared Care Record.
3. An EPS-approved prescribing system.
4. A way to send a secure post-consultation message to the patient’s general practice, in most cases using NHS.net Connect (formerly NHSmail).
5. Access to MYS to submit a manual payment claim for each prescribing consultation.

NHS England held a webinar on 1st October 2026 focused on the IT systems pharmacy owners will need to have in place to provide prescribing within the CPCF.

Watch the recording of the webinar and download the slides used (Futures platform)

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Clinical records system for prescribing consultations

The pharmacy owner’s existing clinical IT system modules used for Pharmacy First and PCS PGD consultation records cannot be used for prescribing consultations.

Consequently, a separate digital consultation record system or a separate module of an existing clinical services IT system that the pharmacy is already using will need to be used by the pharmacist prescriber to make their clinical records of prescribing consultations.

Pharmacy owners will need to procure this additional record system or module.

The digital consultation record system should enable:

• structured and secure capture of clinical data.
• appropriate role-based access controls.
• consistency in documentation for clinical safety and audit purposes.

When procuring digitals systems, pharmacy owners need to comply with NHS Digital clinical safety standards, including the two clinical risk management standards: DCB0129 and DCB0160. Read more about these requirements in the Digital clinical safety standards section of the Commissioning guidance for community pharmacy prescribing-based services.

Any pharmacists working at the pharmacy who are not a prescriber (or are a pharmacist prescriber who has not been onboarded as a prescriber by the NHS) can continue to use the existing Pharmacy First and PCS clinical IT system modules for their PGD consultations.

Additionally, where pharmacist prescribers provide Pharmacy First minor illness (referral) consultations and urgent medicines supply consultations, they will continue to use the pharmacy’s existing Pharmacy First IT system to record those consultations, as they are not prescribing consultations.

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Access to clinical records

Pharmacist prescribers will also need to be able to access patient’s clinical records. This can be achieved in several ways, including via:

• GP Connect Access Record in systems that have that functionality, e.g. the four NHS-assured Pharmacy First IT systems and Cleo Solo.
• the National Care Record Service.
• access to a local Shared Care Record system.

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EPS-approved prescribing system

Originally, NHS England said the interim IT arrangements would involve using CLEO Solo as the prescribing system for community pharmacy-based prescribers currently approved for use by the NHS.

In early October 2026, NHS England subsequently told us that it will also be possible for other EPS IT systems to be used in pharmacies. They have a list of approved systems on their website:

NHS England’s list of approved prescribing systems

When procuring digitals systems, pharmacy owners need to comply with NHS Digital clinical safety standards, including the two clinical risk management standards: DCB0129 and DCB0160. Read more about these requirements in the Digital clinical safety standards section of the Commissioning guidance for community pharmacy prescribing-based services.

Alongside needing an EPS prescribing system, individual pharmacist prescribers will also need an NHS care identity with an appropriate authenticator (CIS2 authentication and AAL3) and the required access rights to undertake prescribing to ensure that the correct role-based access control (RBAC) is in place for the use of EPS. Read this NHS England guidance first: Independent prescribing pharmacist authentication guidance for NHS prescribing-based services in community pharmacy.

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Sending post consultation messages

As the pharmacy owner’s existing clinical IT system modules used for Pharmacy First and PCS PGD consultation records cannot be used for prescribing consultations, that means GP Connect Update Record functionality will not be available and updating the patient’s general practice will have to be via an alternative secure method.

In most cases, that will mean a post-consultation summary will need to be sent to the patient’s general practice via an NHS.net Connect email message. Subject to local discussions, the dedicated GP email for pharmacy communications could be used.

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Submitting manual payment claims on MYS

In the interim IT arrangements scenario, there will be no API in place between the clinical records system and MYS, so a manual claim for each consultation will need to be made in MYS.

This manual claim 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 details of any medication prescribed.

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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.

We are particularly concerned about the potential for increased patient safety risks through the need to use multiple IT systems when undertaking a prescribing consultation. A similar potential patient safety risk relates to the use of different clinical IT record systems for different parts of the same service (such as the different parts of the Pharmacy First service and also where pharmacist prescribers and non-prescribers are both providing clinical services in the same pharmacy).

The need for a manual MYS payment claim process for each consultation provided will also be time consuming when compared to the integrated IT systems pharmacy owners currently use to make clinical records and payment claims for Pharmacy First and the PCS. That is inefficient and adds costs to pharmacy operations.

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

Please also read about our concerns regarding the specific fees payable related to the provision of prescribing services in the Funding and claiming payment section of this webpage.

The payments for prescribing services within the CPCF are set out in a new part of the Drug Tariff: Part VIF.

View the initial Drug Tariff determination

There are three separate payments related to prescribing:

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Setup payment

A one-off setup payment of £500 will be payable when:

• a pharmacy owner has signed up to provide prescribing within Pharmacy First and/or the PCS by completing a declaration on the NHSBSA website (see the Pharmacy sign-up process section above for further information); and
• the relevant ICB has approved the pharmacy owner’s application, assigned an NHS cost centre to the pharmacy, confirmed a go-live date and approved the pharmacy owner to provide prescribing consultations.

The payment will be included in the first available NHSBSA payment run following the pharmacy owner’s go-live date.

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Monthly Infrastructure Payment

Additionally, there will be a Monthly Infrastructure Payment of £525 to support ongoing costs incurred by pharmacy owners, such as prescribing software, clinical supervision and other governance costs.

This will be payable to pharmacy owners:

• approved to provide prescribing consultations;
• who have an approved IT system capable of issuing EPS prescriptions; and
• who use an appropriate clinical records system for recording the details of consultations.

This payment is subject to having a pharmacist prescriber available at the pharmacy premises to provide NHS prescribing consultations for a minimum of 24 hours per week during the pharmacy’s opening hours.

This minimum weekly availability must be in place for at least 45 weeks in each financial year. The 45 week requirement is to take account of the periods of annual leave and sickness absence of the pharmacist prescriber.

The pharmacy owner must notify the ICB as soon as reasonably practicable of any material change that prevents this requirement from being met. Evidence of prescriber availability must be retained at the pharmacy for three years and made available on request for Post-Payment Verification (PPV) purposes.

The Monthly Infrastructure Payment will be included in the first available NHSBSA payment run after the end of the month to which it relates.

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Prescribing activity requirements

A pharmacy owner must evidence prescribing clinical activity within three months of onboarding to provide prescribing consultations.

That can be evidenced by at least one completed NHS prescribing consultation under the Pharmacy First Clinical Pathways or PCS, recorded and submitted via the MYS portal. The consultation does not need to result in a prescription.

Where a pharmacy owner does not meet that requirement, future Monthly Infrastructure Payments will be withheld until prescribing activity is evidenced.

If no prescribing activity is evidenced within six months of onboarding, the Setup payment and all Monthly Infrastructure Payments made to the pharmacy owner will be able to be reclaimed by NHS England.

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Consultation fees

Pharmacy owners will also receive the usual Pharmacy First or PCS fees related to the provision of each consultation.

No payment will be made under the CPCF for any prescription management activity undertaken.

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Submitting manual payment claims on MYS

As noted above in the IT section of this webpage, the interim IT arrangements require a manual payment claim to be made on MYS for each consultation.

This manual claim 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 details of any medication prescribed.

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CPE’s view on the funding

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.

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 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 operational, 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.

The refusal of DHSC and NHS England to agree to a fee being paid to reflect the work and clinical risk related to Prescription Management activity is also not acceptable. That activity, if undertaken by pharmacist prescribers, will take time and will necessitate clinical records to be made and post-consultation communications sent to the original prescriber, all of which add to costs, before the cost of procuring a clinical records system is considered. The pharmacist prescriber and pharmacy owner are also taking on increased clinical risks associated with prescribing, compared with the alternative option of referring the patient back to the original prescriber. We believe all of those additional costs should be funded by the NHS.

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.

Pharmacy owners, cognisant of the above information, must decide on an individual basis whether it makes commercial sense for their business to or whether they will instead prioritise the use of pharmacist prescriber’s 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.

NHS England has published a set of FAQs following their webinar held on 1st October 2026:

Download the NHS England FAQ document (Futures platform)

General

Q. When will prescribing be implemented into the CPCF?
Subject to the necessary preparatory work being completed by NHS England and DHSC, prescribing will be added to the CPCF in the autumn of 2026, most likely in October.

Q. Can an NHS-authorised pharmacist prescriber make Pharmacy First or PCS supplies using the services’ PGDs?
No. Once a pharmacy starts to provide prescribing services within the CPCF, the NHS-authorised prescribers in that pharmacy must prescribe medicines, where appropriate, when they provide Pharmacy First clinical pathways or PCS consultations; they cannot continue to supply medicines using the PGDs.

Q. In a pharmacy authorised to provide NHS prescribing services, can a pharmacist who is not a prescriber make Pharmacy First or PCS supplies using the services’ PGDs?
Yes. Any pharmacists working at the pharmacy who are not an NHS-authorised prescriber can continue to provide those services using the PGDs.

Q. In a pharmacy authorised to provide NHS prescribing services, can a pharmacist who is a prescriber, but who has not been onboarded by the NHS (i.e. is not an NHS-authorised prescriber), make Pharmacy First or PCS supplies using the services’ PGDs?
Yes. Any pharmacists working at the pharmacy who are pharmacist prescribers who have not been onboarded and authorised to prescribe by the NHS can continue to provide those services using the PGDs.

Q. May a pharmacy signpost a patient to another pharmacy because that pharmacy offers independent prescribing as part of a directed service?
Yes.

Q. Must a pharmacist prescriber be present at the pharmacy premises when issuing prescriptions as part of a directed service?
Yes. Pharmacy First and PCS consultations must be at or from the pharmacy premises, as appropriate, even if the patient is remote (i.e. even if the patient is not at the pharmacy), and the consultation is taking place via telephone or video consultation.

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Funding

Q. How is the EPS IT necessary for the introduction of prescribing 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.

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Changes to the Terms of Service

Q. When did the Terms of Service come into force?
On 1st October 2026.

Q. Why have these additions to the Terms of Service been introduced?
To support the introduction of pharmacist prescribing within the CPCF and to be part of the governance to support prescribing and dispensing from the same pharmacy.

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Dispensing prescriptions that have been prescribed at the same pharmacy

Q. When may a pharmacy owner who employs or engages a pharmacist prescriber dispense NHS prescriptions issued by that prescriber?
If their prescription is issued either:

1. As part of a directed service (currently either Pharmacy First or the Pharmacy Contraception Service) and only as permitted by that service; or
2. If it replaces a prescription issued by a prescriber at a general practice, where the pharmacist prescriber’s replacement prescription is issued with the agreement* of the prescriber/GP practice. This activity is described as ‘prescription management’ by NHS England.

*Agreement may relate to the replacement of a specific prescription, or it could, for example, be a general agreement for the replacement of a certain category of prescriptions in specified circumstances. NHS England has developed guidance on prescription management to provide further information on this activity.

Q. When may I start dispensing prescriptions issued by a prescriber I employ or engage, where those prescriptions are issued as part of Pharmacy First or the Pharmacy Contraception Service?
The start date has not yet been determined.

Q. Is the prescription issued as part of the Advanced Service?
Yes, except where a new prescription is issued under Prescription Management.

Q. Is the prescription dispensed as part of the Advanced Service?
No, it is dispensed as part of the Essential Services Dispensing service.

Q. May a patient choose which pharmacy to dispense their prescription if the prescription is issued as part of a directed service?
Yes. Patient choice remains important for prescriptions issued by pharmacist prescribers.

CPE and the BMA have jointly issued the following guidance which indicates that the choice of who dispenses their prescription remains with the patient: BMA and CPE statement on prescription direction (2018) and Prescription direction to certain pharmacies. NHS England also provide materials for pharmacies to use to inform patients of patient choice of pharmacy; see our webpage on Prescription Direction.

Q. If the patient’s EPS nomination is for Pharmacy A and they decide to have the prescription (issued as part of a directed service at Pharmacy B) dispensed at Pharmacy B, does the EPS nomination automatically change to Pharmacy B?
No. The prescription issued as part of the directed service may be dispensed at Pharmacy B without the patient’s EPS nomination being changed. The patient could also choose to have the prescription dispensed at Pharmacy A.

A patient’s explicit consent must be obtained before a nominated pharmacy is added to or changed in the patient’s NHS Personal Demographics Service (PDS) record. This became part of pharmacy owners’ Terms of Service on 1st October 2026.

NHS England has issued updated guidance: EPS nomination: standards that must be followed; this recommends that an electronic or written record of the patient’s consent is kept in case of future queries.

Q. If a pharmacy owner employs a pharmacist prescriber part time and the prescriber is employed by a local GP practice part time, may the pharmacy dispense the prescriptions the pharmacy prescriber issues from the GP practice
Yes. The pharmacist prescriber is not employed or engaged by the pharmacy owner when working for the GP practice.

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Prescription Management

Q. May any pharmacist prescriber employed or engaged by a pharmacy owner replace general practice prescriptions with the general practice prescriber’s agreement?
No. Only pharmacist prescribers employed or engaged by a pharmacy owner providing independent prescribing as part of a directed service may do so.

Q. What does the general practice prescriber’s agreement mean in this context?
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. NHS England has developed guidance on prescription management to provide further information on this activity.

Q. What is the ‘best interests assessment’?
A ‘best interests assessment’ is an assessment that a medicine is:

1. clinically appropriate and in the best interests of the patient for whom the medicine is ordered;
2. consistent with best practice within the NHS with regard to obtaining value for money for the NHS; and
3. in all other respects professionally appropriate.

Q. Who carries out a ‘best interests assessment’ and when?
The pharmacist prescriber employed or engaged by the pharmacy owner carries out a ‘best interests assessment’ before issuing the replacement prescription, and must issue the replacement prescription in accordance with that assessment.

Q. What is the pharmacy owner’s responsibility for ‘best interest assessments’ as set out in these Terms of Service changes?
The pharmacy owner must have an SOP for prescribing and dispensing at the same pharmacy, and for carrying out a ‘best interests assessment’.

Q. Is there a record keeping requirement in these Terms of Service changes for ‘best interests assessments’?
No, but it is implicit that any independent prescriber choosing to make these interventions must be able to justify them and should therefore keep appropriate clinical records.

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DSPs

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 Prescription Management would also apply to DSP pharmacies with a pharmacist prescriber who is also providing independent prescribing as part of a directed service.

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.

At Community Pharmacy England, we are always keen to hear from pharmacy owners and their teams about how the provision of national pharmacy services is going, be that niggles with the way services are commissioned, a success story you want to share or something else.

Please click on the link below to share a success story where you have helped achieve a good outcome for a patient following a consultation for a national pharmacy service or to provide feedback on one of the services.

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