Business continuity plans required for temporary closures from 31st July – two new NHSE Approved Particulars
Pharmacy owners will be required to have a business continuity plan dealing with temporary closures from the end of this month, and Community Pharmacy England has issued guidance to help support this.
Following changes to the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013 that were imposed earlier this year, from 31st July 2023, it will become a Terms of Service requirement for each NHS community pharmacy owner to have a business continuity plan for a temporary suspension of service (closure) due to illness or other reason beyond their control, and to action this when necessary.
The Terms of Service requirements are broadly that your plan must include arrangements for:
- Notifying your Integrated Care Board (ICB) of a temporary suspension, and a likely temporary suspension (in accordance with the approved particulars from NHS England);
- Updating the NHS England Directory of Services (DoS);
- Reducing referrals under Directed services that relate to urgent care;
- Notifying your main local GPs and other local contractors of the temporary closure and its anticipated duration;
- Displaying relevant information for patients on the premises (in accordance with the approved particulars), or for DSPs displaying relevant information on their website; and
- Continuity of care, for example, of patients with booked appointments and those who have supervised administration of medicines.
We have put together a briefing and a template plan to help guide pharmacy owners through the process. This explains what is required in the plan, describes how and when to implement it, and outlines some additional considerations. This could be added as an annex to your pharmacy’s existing business continuity plan. A checklist has also been added, which may be used in the event of a temporary suspension.
Update (1st August) – NHS England has now published the approved particulars and these are available on the NHS England website:
- Approved Particulars for Displaying Notices Regarding a Temporary Suspension
- Approved Particulars for Notification of a Temporary Suspension or a Likely Temporary Suspension
NHS England is also still to publish guidance on the amendments to the Pharmaceutical Regulations that came into force on 25th May, which will include guidance on these requirements.
The late publication of NHS England’s advice and approved particulars means that pharmacy owners (contractors) will have difficulty implementing them before the 31st July start date. So, we have asked and expect NHS England and ICBs to take a pragmatic approach to any enforcement of these new requirements for at least the next 3 months. This is normal for any enforcement authority (or quasi enforcement authority) even where such guidance is published well in advance.
