NHS updates EPS nomination standards
This follows renewed scrutiny of nomination practices and reinforces the principle that patients must be able to set or change their nomination freely, without pressure or unwanted intervention.
Nomination standards: Key points
The four overarching standards:
- Patients must choose their own nomination
- Patients must not be persuaded, and inducements cannot be offered
- Prescribers and dispensers will need to confirm, set, change, cancel and reconfirm a patient’s nomination in a timely manner
- Prescribers and dispensers must use clear processes for nomination
Other important key points:
- The nomination standards are clearly marked up as applying to technology providers and website managers where digital tools invite patients to make an EPS nomination-related choice.
- References to NHS App
- Clarification on the use of Patient Demographic Services nomination data (see just below).
NHS England clarifies how NHS nomination data can be used
NHS England clarifies the appropriate use of PDS nomination data within the guidance:
“NHS Patient Demographic Services holds the patient nomination and, in accordance with the Data Protection Act, access to the nomination-related data held within PDS must only be where a legal basis exists. For dispensers, that would be because a patient has presented and wishes to change their nomination, requires a consultation or where dispensing activity is required. There would be no legal basis to access PDS nomination data outside of this, and a previous nomination is no guarantee of future intent.”
NHS England writes to system suppliers
NHS England advised Community Pharmacy England that it has written to system suppliers to confirm this position and to request the removal of any functionality that does not comply.
NHS England’s approach with the updated standard and with the communications to IT suppliers is intended to:
- protect patient choice and privacy
- prevent unintended or inappropriate nomination changes
- ensure consistent behaviour across all pharmacy IT systems
- reduce queries to NHS England, GPhC and ICBs
- support public confidence in EPS and the NHS App, which enables change to nomination
This position also reduces the risk of “patient ping‑pong”, where nominations switch back and forth between pharmacies without the patient’s knowledge. The instruction also applies beyond EPS IT system suppliers to other types of pharmacy IT suppliers.
What does this mean for pharmacy teams?
Pharmacies can continue to set, change or remove a nomination, but only:
- when the patient (or their representative) requests it
- after providing clear information about EPS and nomination
- with an auditable record of who made the change (as captured in Smartcard logs)
Teams must not:
- routinely look up or monitor patient nomination status
- use tools that perform periodic, automated, or bulk PDS checks
- assume a patient wishes to stay with the pharmacy
- change nominations without explicit consent
Operational considerations
Some pharmacy teams may be used to system features that checked for nomination changes or restored previous nominations. NHS England has confirmed that these features should no longer operate, and suppliers are expected to disable them.
This may mean adjusting local processes – especially where teams previously relied on automated alerts to identify patients who had moved their nomination elsewhere.
Accidental nomination changes will still occur from time to time (for example, when a patient uses a different pharmacy during travel). Clear, consistent and ongoing explanations of how nomination works can help reduce confusion.
Our position
Community Pharmacy England supports patient choice and safe, transparent use of the Electronic Prescription Service (EPS).
The updated standards
