Retention of Pharmacy Records
Published on: 15th August 2017 | Updated on: 17th November 2025
The Importance of Accurate Record Keeping for Payment
Accurate record-keeping is essential in the provision of Advanced Services to verify what was provided and, therefore, that the claims made for service provision were appropriate; as well as for the provision of safe clinical care.
The records needed to support claims for payment must be…
- complete and include all the relevant information listed and
- kept for at least the minimum period
… stated in the service specification, service Directions, or service Determination.
The information may have to be kept for longer if requested by NHSBSA (on behalf of the commissioner), for example, if post-payment verification work is ongoing or anticipated.
The records of commissioned services enable a pharmacy owner to demonstrate or verify that the delivery of the service has been made to eligible patients in accordance with the service specification and confirm the commissioner’s associated payments have been properly made. Without such records, if a pharmacy owner is asked to verify service delivery, they will not be able to do so, at least not in a manner required by the service specification, service Directions, or service Determination, and the payments for such delivery are likely to be recovered as an ‘overpayment’.
The pharmacy owner, as the data controller, must determine any additional retention periods, beyond those required by the service specification, service Directions, or service Determination.
Pharmacy owners must provide relevant records to the NHSBSA Provider Assurance Team if requested to do so to verify delivery of the service.
The drop down menus below details the current record retention periods for Advanced and National Enhanced Services
| Service | Minimum record retention period | Reason for record retention |
| Adult Flu Vaccination Service |
3 years for reimbursement purposes. Clinical records are to be retained for 8 years for adults aged 18 years and over. Where the vaccination was administered to a pregnant woman, retain until child’s 25th birthday.
|
Legal requirement – see service specification/direction on the service page for more information. |
| Appliance Use Reviews |
12 months for reimbursement purposes. Clinical records are to be retained for 8 years for adults aged 18 years and over. Where the vaccination was administered to a pregnant woman, retain until child’s 25th birthday. (As per the NHS Records Management Code of Practice) |
Terms of Service requirement – see service page for more information. |
| Childhood Flu Vaccination Service |
3 years for reimbursement purposes. Clinical records are to be retained until the patient’s 25th birthday or 26th birthday if the patient was 17 years when the service was administered. |
Legal requirement – see service specification/direction on the service page for more information. |
| Hypertension Case-Finding Service |
3 years for reimbursement purposes. Clinical records are to be retained for 8 years for adults aged 18 years and over. Where the vaccination was administered to a pregnant woman, retain until child’s 25th birthday. (As per the NHS Records Management Code of Practice)
|
Legal requirement – see service specification/direction on the service page for more information. |
| Lateral Flow Device Service |
3 years for reimbursement purposes. Clinical records are to be retained for 8 years for adults aged 18 years and over. Where the vaccination was administered to a pregnant woman, retain until child’s 25th birthday. (As per the NHS Records Management Code of Practice) |
Legal requirement – see service specification/direction on the service page for more information. |
| New Medicine Service |
3 years for reimbursement purposes. Clinical records are to be retained for 8 years for adults aged 18 years and over. Where the vaccination was administered to a pregnant woman, retain until child’s 25th birthday. (As per the NHS Records Management Code of Practice) |
Legal requirement – see service specification/direction on the service page for more information. |
| Pharmacy Contraception Service |
3 years for reimbursement purposes. Clinical records are to be retained for 8 years. Where the record relates to a child, then retain until 25th birthday, or 26th if the patient was 17 years old when treatment ended. |
Legal requirement – see service specification/direction on the service page for more information. |
| Pharmacy First |
3 years for reimbursement purposes. Where treatment was provided to a pregnant woman, retain until child’s 25th birthday. Where the record relates to a child, then retain until 25th birthday, or 26th if the patient was 17 years old when treatment ended. |
Legal requirement – see service specification/direction on the service page for more information. |
| Smoking Cessation Service |
3 years for reimbursement purposes. Clinical records are to be retained for 8 years for adults aged 18 years and over. Where the vaccination was administered to a pregnant woman, retain until child’s 25th birthday. (As per the NHS Records Management Code of Practice) |
Legal requirement – see service specification/direction on the service page for more information. |
| Stoma Appliance Customisation |
12 months for reimbursement purposes. Clinical records are to be retained for 8 years for adults aged 18 years and over. Where the vaccination was administered to a pregnant woman, retain until child’s 25th birthday. (As per the NHS Records Management Code of Practice) |
Legal requirement – see service page for more information. |
| Service | Minimum record retention period | Reason for record retention |
| COVID-19 Vaccination Service | For adults aged 18 years and over – 8 years. Where the vaccination was administered to a pregnant woman, retain until child’s 25th birthday | Legal requirement – see service specification/direction on the service page for more information. |
| For a child – retain until the 25th birthday or 26th birthday if the patient was 17 years when treatment finished | ||
| RSV and Pertussis Vaccination Service | For adults aged 18 years and over – 8 years. Where the vaccination was administered to a pregnant woman, retain until child’s 25th birthday. | Legal requirement – see service specification/direction on the service page for more information. |
| For a child – retain until the 25th birthday or 26th birthday if the patient was 17 years when treatment finished. |
Where a service involves recording professional judgement, such as the Hypertension Case-Finding Service for under 40-year-olds, a comprehensive record of the relevant decision should be maintained and provided to the NHSBSA Provider Assurance Team, where requested, as evidence of the reason the service was provided.
Locally commissioned services may have different record retention period requirements; pharmacy owners are advised to check the specific service specifications for those services to ensure they comply with record retention requirements.
Where additional assurance is needed for Essential services, such as Discharge Medicines Service and Out of Pocket Expenses claims, evidence will need to be retained for provider assurance purposes.
Absence of stated retention period
Recent appeal cases have determined that, if no retention period is stated in the service specification, pharmacy owners must retain evidence until the commissioner has confirmed the pharmacy will not be part of any provider assurance activity.
Change of IT systems
Pharmacy owners are reminded that where the pharmacy changes its PMR or clinical IT system supplier, the electronic service records that had been within the old system must still be retained and accessible for the relevant retention periods. Additional guidance on system transfer can be found at cpe.org.uk/changingitsystems
Pre and post payment verification
The commissioner must ensure that where pharmacy owners make claims for payment, they meet all the specified requirements of the service.
NHS England works with the NHSBSA Provider Assurance Team to undertake post-payment verification (PPV) checks on claims made. The verification checks include comparing the information provided by pharmacy owners in their claims against datasets and evidence sources available to the NHSBSA Provider Assurance Team.
Paragraph 36 of the Pharmacy First Directions states:
Where claims are submitted and the data provided indicates the activity was not in accordance with the appropriate PGD or service specification, the payments may be withheld by the NHSBSA whilst the claims are reviewed. Payments will be authorised where the contractor provides sufficient evidence to demonstrate that the supply was in accordance with the appropriate PGD or service specification.
Pharmacy owners who have made claims for a service have a responsibility to be able to provide evidence to support the claims when requested by NHSBSA and/or the commissioner.
In cases where evidence is not available or does not demonstrate that the service activity was delivered, and claims cannot be verified, the pharmacy owner may be invited to accept that the pharmacy has been ‘overpaid’. If not, the case may be referred to the relevant ICB’s Pharmaceutical Services Regulations Committee (PSRC) or equivalent, for a decision on whether there has been an ‘overpayment’.
Where the PSRC decides that there has been an ‘overpayment’, subject to any appeal, this is recovered, usually as a deduction from future payments to the pharmacy. Pharmacy owners will be contacted by NHSBSA and notified of the overpayment recovery process.
Additional information
Some of this guidance provides information beyond the focus area of this document:
- Our page on Data handling, maintenance and disposal
- SPS pharmacy records guidance
- NHS Records Management Code of Practice for Health and Social Care provides advice on minimum retention periods across the NHS
For more information on this topic please email regulations.team@cpe.org.uk
