FAQs on the conditions applying to Independent prescribing within the CPCF
Community Pharmacy England Briefing 020/26 explains the amendments recently made to the Terms of Service for NHS pharmacy owners, including the new conditions related to independent prescribing within the CPCF.
These changes to the Terms of Service apply from 1st October 2026. However, prescribing within the CPCF will not be implemented in individual pharmacies until various processes have been completed and the ICB has authorised individual pharmacies.
There are many requirements that will apply to pharmacy owners that wish a pharmacist prescriber they employ or engage to prescribe within the CPCF from their pharmacy, and you can read more about them on our Prescribing within the CPCF webpage.
Frequently asked questions (FAQs)
Community Pharmacy England has been compiling answers to queries about the conditions related to independent prescribing since the announcement of the regulation amendments. The following are some of the most commonly asked.
Q. Why have these 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.
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:
- As part of a directed service (currently either Pharmacy First or the Pharmacy Contraception Service) and only as permitted by that service; or
- 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 did these Terms of Service come into force?
On 1st October 2026.
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.
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.
The CPE and BMA have jointly issued the following guidance which indicates that the choice of who dispensed their prescription remains with the patient: BMA-and-PSNC-statement-on-prescription-direction-2018-reissue.pdf 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 information page 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 contractors’ Terms of Service on 1 October 2026.
NHS England has updated the EPS nomination: standards that must be followed, which recommends that an electronic or written record of the patient’s consent is kept in case of future queries.
Q. May a pharmacy signpost a patient to another pharmacy because that pharmacy offers independent prescribing as part of a directed service?
Yes.
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.
Q. Must a pharmacist prescriber be present at the pharmacy premises when issuing prescriptions as part of a directed service?
Yes. Pharmacy First and Pharmacy Contraception Service 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.
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:
(a) clinically appropriate and in the best interests of the patient for whom the medicine 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.
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 records.
As stated already, there are many requirements that will apply to pharmacy owners that wish a pharmacist prescriber they employ or engage to prescribe within the CPCF from their pharmacy, and you can read more about them on our Prescribing within the CPCF webpage.
