Health and Care Bill

Written evidence submitted by the National Pharmacy Association (NPA) (HCB46)

The Public Bill Committee

Health and Care Bill

About the NPA

1. The NPA is the body that represents independent community pharmacies in the UK.  We count amongst our members independent regional chains through to single-handed independent pharmacies.

2. This spread of members, our UK-wide geographical coverage, and our remit for NHS and non-NHS affairs means that we are uniquely representative of the independent community pharmacy sector.

3. In addition to being a representative voice, we provide members with a range of professional services to help them maintain and improve the health and wellbeing of the communities they serve.

4. We welcome the opportunity to give evidence for any sessions of the committee. To arrange this, please contact Helga Mangion, Policy Manager at


5. The COVID-19 pandemic has highlighted the UK’s local NHS community pharmacies, which have become the visible face of the NHS on our high streets. They have been on the front line of the battle against coronavirus since day one, staying open and serving their patients when most healthcare providers closed their doors and suspended face to face services to the public. Now is the time to recognise the potential of community pharmacies to help get the nation through this crisis and to deliver better health outcomes in every community.

6. COVID-19 has highlighted the strain on the health service and the limitations of a GP-focused model. The challenge of attracting enough doctors into general practice means service delivery is at breaking point in some areas.

7. The government’s reforms of NHS England represent an opportunity to integrate community pharmacy and enhance its role within the NHS to help tackle both the short- and long-term challenges. Maximising the impact of community pharmacies will depend on strong representation from community pharmacy in the integrated care systems of the future.

8. The local community pharmacy network, with highly trained healthcare professionals at over 11,000 locations reaching into every part of the country, is an under-utilised resource within our NHS. The 5-year community pharmacy contract introduced in 2019 was intended to introduce new clinical services into community pharmacy. Work is underway to roll-out a number of these new services such as the Hypertension case-finding service. The community pharmacy network can do so much more, using the full skills and knowledge of the pharmacist, to tackle public health problems and take pressure off other parts of the health system – but it has to be empowered and funded to do so.

9. Patients also want to get more from their pharmacies: 77% of the public value the face-to-face relationship with their pharmacist and 71% believe pharmacies should expand their offering. (NPA Survey June 2020)

The reforms of the NHS

10. The COVID-19 pandemic has shone a light on the value of working collaboratively across systems at a local level. The NPA welcomes any attempts to improve integration of health and care services, recognising that community pharmacy can deliver more as an integral part of the system rather than being seen as an adjunct to the "main action".

11. The level of community pharmacy representation within current structures is sub-optimal. The development of Integrated Care Systems gives us a new opportunity to ensure community pharmacy is appropriately represented at all levels. For the public to get the maximum benefit from community pharmacy, the sector needs to be embedded in decision making and strategy. In particular, community pharmacy representatives should be at the tables where service pathways are designed and implemented, and monitoring of progress takes place.

12. Wherever community pharmacists sit within local structures, they should be properly supported to fulfil their role.

13. Another significant objective of the Bill is to achieve seamless and secure flow of data across Integrated Care Systems. The NPA wants all pharmacies to be plugged into local health care records in order to provide the best integrated care, improve patient safety and facilitate referrals.

Questions about the Bill

14. We pose the following questions in relation to the Bill:

a. How can community pharmacy be consistently included as a provider partner across the 42 Integrated Care System structures?

b. How can broader primary care providers be heard with parity to the large NHS Trusts so that the out of hospital and preventative agendas are successfully delivered?

c. How will the move to local system delegated national contracts from NHS England regional structures be made seamless, effective and consistently supported across the 42 Integrated Care Systems?

d. How can community pharmacy be supported with appropriate transformation funding investment to enable our 11,000+ contracted providers to engage with local structures, especially at neighbourhood Primary Care Network (PCN) level?

i. We note that significant additional funding has been applied to the General Practice side of the PCN construct to enable their leadership/involvement, yet beyond use of the Pharmacy Quality Scheme (PQS) for specific seasonal flu campaign purposes, no national funding has been made to community pharmacy. It is evident that some forward thinking local systems have already made local investment but the majority have not to date, citing that community pharmacy is a national contract so should be funded nationally.

e. How will public health commissioning fit in the new Integrated Care System decision making processes and how will community pharmacy be involved?

f. How will community pharmacy be enabled to join local healthcare record systems, thereby allowing full participation in clinical multi-disciplinary teams and the effective delivery of the additional national contract clinical services, such as the Discharge Medicines Service and Hypertension case-finding service?

Additional points and concerns

15. The Bill does not ensure that community pharmacy will have appropriate representation within Integrated Care Systems. The Bill does not even make any reference to community pharmacy. Wider primary care providers, including community pharmacy, must be involved in decision-making local structures beyond just general practice.

16. Community pharmacy has the size and scope of service to be recognised as a major part of primary care, with 11,000+ pharmacy practices, a large workforce of healthcare professionals and a range of clinical services available to patients and the public. Furthermore, community pharmacists are the most accessible healthcare professionals based at the heart of communities across the country, particularly in deprived neighbourhoods. However, the sector is still an underutilised NHS asset. Community pharmacy will have a big footprint across Integrated Care Systems, with averages of 260 pharmacies and 2,600 community pharmacy personnel per ICS. It could be strongly argued that a sector of this size and significance should be mandated to have appropriate representation at all levels of an Integrated Care System, in particular where the decisions are taken about care delivery design and funding of services.

17. NPA responded to a number of consultations on ICS structures, where we reiterated the importance of having the community pharmacist voice heard at all appropriate levels within the new NHS structures.

18. Community pharmacists and their pharmacies are regulated by the General Pharmaceutical Council ( GPhC ) in England, Scotland and Wales. In Northern Ireland, this regulation falls under the jurisdiction of the Pharmaceutical Society of Northern Ireland (PSNI).

In all four countries of the United Kingdom, the pharmacy regulators ( GPhC & PSNI) also inspect the pharmacy premises.

19. The NPA believes that as a large healthcare profession, the G P hC and the PSNI should remain as the regulators of pharmacists and pharmacy technicians. Pharmacy , is practised across a broad range of settings. Hence, any decisions pertaining to any setting, including community pharmacy, would require a full understanding and involvement from the relevant sphere of practice.

20. The NPA recognises that proposals pertaining to procurement and competition rules, may not necessarily be applicable to community pharmaceutical services commissioned nationally by NHS England. However, the NPA would like to outline a few areas of concern in relation to the provision of services by community pharmacies outside the nationally agreed framework.

21. Community pharmacies are commissioned to provide both NHS and public health services. Through integration with local health services, community pharmacies are positioned to play a broader role in supporting community health, including being commissioned locally to provide public health services. These public health services tend to be identified through local Pharmaceutical Needs Assessments, which are commissioned on a population health basis.

22. The NPA strongly supports proposals to ensure that there is sufficient transparency about the decisions that are taken (such as the obligation to publish the intention to award a contract). Commissioners will not always be aware of the potential that some providers have to deliver a service in a way that is beneficial for patients, the NHS and the taxpayer. Whilst giving commissioners more freedom to avoid bureaucratic procurement processes, these changes should not preclude new providers from the opportunity to deliver NHS services.


23. The NPA is seeking the following from the reforms set out in the Health and Care Bill:

a. To ensure that community pharmacy is appropriately represented across the new NHS structures.

b. The sector needs to be embedded in decision making and strategy.

c. Community pharmacists should be at the tables where service pathways are designed and implemented, and monitoring of progress takes place.

d. Wherever community pharmacists sit within local structures, they should be properly supported to fulfil their role.

e. The NPA wants all pharmacies to be plugged into local health care records in order to provide the best integrated care, improve patient safety and facilitate referrals.

September 2021


Prepared 15th September 2021