Contract changes: DSP regulatory FAQs

On Monday 31st March 2025, the details of the contractual settlement for 2025/26 were announced, which included changes to regulations around Distance Selling Premises (DSP) Pharmacies.

This news story addresses key DSP regulatory related questions that have been raised since the announcement of the settlement.

Is Community Pharmacy England supportive of remote provision of NHS Pharmaceutical Services? 

Yes. Community Pharmacy England supports the provision of NHS pharmaceutical services remotely, where this can be carried out safely and within the conditions described in the service specification and the Secretary of State’s directions.  

What change is coming in for the provision of services by Distance Selling Premises (DSP) pharmacies?  

DSPs will no longer be able to deliver in-person Directed Services (Advanced, National Enhanced, and Enhanced Services) onsite (i.e. no longer provide services onsite, face-to-face with the patient).  

Where a service specification allows, DSPs will continue to be able to provide… 

• remote consultations (from the distance selling premises) or  

• off-site provision of a service (face-to-face)(i.e. not on the distance selling premises),  

… will still be possible for DSPs (and for all pharmacies).  

What will this change mean for the provision of services onsite at Distance Selling Premises? 

This change will mean that DSPs may only provide Advanced, National Enhanced and Enhanced Services remotely from their pharmacy premises. They must already only provide Essential services remotely from their pharmacy premises. 

When will this change happen/come into force? 

This change is likely to be in October 2025, after the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013 (PLPS Regulations) have been amended.  

Why is this change being introduced? 

In simple terms, Distance Selling Premises (DSP) pharmacies will have to do what their name implies, to provide NHS pharmaceutical services remotely (at a distance) and not face-to-face with patients at, or in the vicinity of, the pharmacy premises.  

The intention of the PLPS regulations was for DSPs to be remote providers of pharmaceutical services, and, on this basis, they are allowed to establish or open (subject to application) without reference to local Pharmaceutical Needs Assessments (PNA). The expectation was that DSPs would provide NHS pharmaceutical services nationally. Not that they would deliver clinical services locally or on the High Street.  

Currently, the PLPS Regulations allow DSPs to provide Advanced, National Enhanced and Enhanced Services (Directed Services) to patients present onsite, at the pharmacy premises. However, this was introduced when such services were a small part of the NHS community pharmacy offering. This has since changed and has meant that increasingly, with the provision of such services, DSPs can establish and provide such services locally, undermining the integrity of the market entry controls in the PLPS (which broadly only permit new pharmacies if local patient needs – set out in the local PNA – require one). 

The first formal recognition of this issue – concern with DSPs providing Directed Service onsite, face-to face with patients – was when the Pharmacy First Service was introduced, and DSPs were only allowed to provide Pharmacy First clinical pathways (the new part of the service) remotely. 

How much notice of this change are DSPs being given? 

DSP pharmacy owners are being given 6 months’ notice of this change. 

Will this stop ‘local’ or ‘pseudo’ DSPs? 

No. This change will not stop the establishment of ‘local’ or ‘pseudo’ DSPs (for more information about these, visit the CCA website), but it should stop their provision of Directed Services in a way that undermines the market entry controls in the PLPS Regulations. 

Will DSPs be able to continue to provide the COVID-19 Vaccination Service? 

The COVID-19 Vaccination Service is a National Enhanced Service that may only be provided by NHS pharmacies from designated premises approved by NHS England. The designated premises may be premises other than the pharmacy premises. If the provision of the service is offsite, i.e. not at the DSP pharmacy premises, our understanding is that DSPs will continue to be able to provide the service after the change to the PLPS Regulations in October 2025. 

Will DSPs be able to provide the Flu Vaccination Service? 

The Flu Vaccination Service is an Advanced Service. The service specification states that ‘Vaccinations under this advanced service will usually be carried out on the pharmacy premises, but they can also be undertaken in other suitable locations, such as in the Patient’s home, a long-stay care home, a long-stay residential facility or community venues (e.g. community centres).’  

DSPs will not be able to provide Flu vaccinations at the DSP pharmacy premises.  

The service specification is reviewed annually and will be revised to reflect the changes to DSP provision of Directed Services, which will be introduced in the PLPS Regulations. If DSPs retain the option to provide flu vaccinations offsite, this is likely to be a way that does not undermine market entry controls. This could mean, for example, that off-site provision is only at designated and approved premises.