Regs reminder (#14): Consultation rooms and remote consultations
Ahead of the 2021/22 contract monitoring process, community pharmacy contractors are reminded of recent changes to the pharmacy Terms of Service. This article is the final part of a series of reminders.
On 20th October 2020 new NHS regulations were laid to introduce changes to the Terms of Service for pharmacy contractors. PSNC issued a series of 14 Regs explainer articles in November 2020 to help contractors and their teams to understand the new requirements.
Whilst deadlines for compliance with the changes have now passed, the end of 2020 was a particularly busy time for pharmacies, so contractors are advised to review our reminders in preparation for completing the 2021/22 Community Pharmacy Assurance Framework (CPAF) survey, which will include questions on some aspects of the new Terms of Service.
What is required?
As a result of the Healthy Living Pharmacy Level 1 (HLP) criteria becoming Terms of Service requirements, almost all pharmacies need to have a consultation room which are detailed in the NHSE&I regulations guidance.
The requirement for the consultation room is based on the existing requirement for a consultation room which is included in the service specifications of most of the Advanced services; most pharmacies already comply with these requirements.
The requirements for the consultation room are that it is:
- clearly designated as a room for confidential conversations, for example a sign is attached to the door to the room saying Consultation room;
- distinct from the general public areas of the pharmacy premises; and
- a room where both the person receiving the service and the person providing it can be seated together and communicate confidentially.
If the pharmacy was included in a pharmaceutical list on 1st January 2021, but no Advanced services were provided at or from the pharmacy during the 12 months ending 31st December 2020, the contractor has until 1st April 2023 to install a consultation room within their pharmacy.
Contractors who open new pharmacy premises must have a consultation room from the first day they open for business.
Where a contractor believes that their pharmacy is too small for a consultation room, they need to complete and submit a request to their NHS England and NHS Improvement (NHSE&I) regional team (NHSE&I have published a form on which to make this request).
NHSE&I will consider the information provided by the contractor and where it is of the opinion that the pharmacy is too small for a consultation room, it will confirm this with the contractor. The contractor must then ensure that they put arrangements in place at the pharmacy which enable staff and patients to communicate confidentially by telephone or another live audio link and a live video link.
Where NHSE&I are of the opinion that the pharmacy is not too small for a consultation room, the contractor will be advised of this and they will need to install a consultation room.
Distance Selling Pharmacies (DSPs)
DSPs must ensure that there are arrangements in place at the pharmacy which enable staff and patients to communicate confidentially by telephone or another live audio link and a live video link.
DSPs can choose to install a consultation room at their pharmacy to allow the provision of Enhanced and Advanced services on the premises, but this is not a requirement of the Terms of Service.