EPS & the NHS Re-organisation
PCTs currently undertake a range of tasks that support pharmacies in accessing and using national NHS IT applications. On the 1st April 2013, responsibility for supporting pharmacies in using these services will transfer to the NHS Commissioning Board (CB).
The following is a high level summary of expected changes; some details are still to be confirmed but as more information becomes available it will be posted online. Information on local arrangements such as any changes in the arrangements for obtaining smartcards will be available from LPCs. Across the country, PCTs are at different stages in their transition planning; in some areas, future arrangements are already confirmed, in others, this is still under discussion.
Summary of NHS IT Future Operating Model
The recently published NHS Commissioning Board (NHS CB) document – Securing excellence in IT Services: Operating model for community pharmacies, appliance contractors, dental practices and community optometry – sets out future NHS organisational responsibilities in relation to IT.
Where there is a national policy directive for contractors to provide a service, for example the Electronic Prescription Service and NHSmail, the NHS Commissioning Board, through its regional/area teams may either provide support functions itself or make arrangements for commissioning support units (CSUs) or any other IT provider to deliver them. Where PCTs have been supporting pharmacy access to an application on a discretionary basis, for example the Summary Care Record, the NHS Commissioning Board, through its regional/area teams will manage the legacy arrangements from PCTs through the transition but on-going support will be subject to review going forward.
GP IT services will be managed by clinical commissioning groups (CCGs) on behalf of the NHS CB. A CCG may choose to provide support functions to GP practices itself or make arrangements to commission support from CSUs or another IT provider – whilst it is possible that in some areas, the NHS CB and CCGs will commission the same CSU to provide EPS support for pharmacies and GPs respectively, this may not always be the case.
Most of Connecting for Health including the EPS Team will be transferred into the ‘Health and Social Care Information Centre’ (HSCIC) from 1st April.
Future EPS Support Arrangements
Authorisation of GPs to deploy EPS Release 2: Currently, only PCTs that have been authorised through Secretary of State Directions can direct their GPs to start issuing electronic NHS prescriptions. From April 1st 2013, the EPS Authorisation Directions will no longer apply; GP practices anywhere in England will be able to decide when they go-live without requiring prior authorisation. To ensure that adequate notice of GP go-live dates is available to pharmacies, it is anticipated that the following technical controls will be put in place:
The local NHS lead on the project (e.g. from the CCG or NHS CB) will enter a date in the “Local Business Go-Live Planned Date” field in the national EPS tracking database, as PCTs should do now.GP practices will be encouraged to provide more that 8-weeks’ notice and will not be able to issue electronic prescriptions unless a minimum of 8 weeks’ notice has been provided through this processIf a GP practice does not enable EPS R2 within 2 weeks of their planned date, they will need to pass through the process again, giving fresh notice of intent to deploy.This process will apply for all EPS R2 deployments planned from 1st April 2013.
Information from the tracking database is currently used to populate the EPS deployment map and a weekly update of which GPs are live or have placed an order for an EPS Release 2 system. Both resources will continue to be available online at: www.cfh.nhs.uk/eps/maps. In some areas PCTs currently provide pharmacies with information on local deployment planning; whilst this will continue in many areas, to support local communication, Connecting for Health will shortly begin sending a weekly email service to LPCs with tailored information from the tracking database on which pharmacies in a locality are expected to be affected by planned GP deployments.
Arrangements for distribution of smartcards: The NHS CB through its regional/area teams will be responsible for the issue of smartcards. Given the business and patient safety critical nature of smartcards, an RA needs to be in reasonable proximity to the pharmacies that it supports and have opening hours that properly reflect the realities of pharmacy practice.
A significant challenge to date has been inconsistency in local RA policies and in some areas, poor adherence to national guidance, for example refusal to issue the locum user role profile (FFFFF) where pharmacists have a legitimate need for it. As the NHS Commissioning Board will ultimately be responsible for the provision of RA support, it is anticipated that there will be improved consistency in the application of RA policy.
Following a change in policy to permit non-NHS organisations to host Registration Authorities (RA) for the issue of smartcards, information and guidance is expected to be issued in February by NHS Connecting for Health (CFH) to invite organisations to apply to become a pilot RA. Pharmacy companies, pharmacy system suppliers or pharmacy organisations could potentially become a pilot RA, however it will only be possible to assess whether this is a viable option once the criteria in respect of governance, operation and audit is published. A requirement that has already been confirmed is that the organisation must have access to the NHS network (N3).
Detailed background information on smartcards can be found online at www.psnc.org.uk/smartcards.
Arrangements for distribution of tokens: The NHS CB through its regional/area teams will be responsible for issue of tokens.
Arrangements for supervision of nomination functionality: The EPS Authorisation Directions currently place an obligation on PCTs to proactively monitor the service and where they identify any unusual or unexpected distribution of nominations, consider whether further investigation or action is appropriate. From April 1st 2013, the EPS Authorisation Directions will no longer apply and proactive monitoring of the service will cease, however the NHS CB will continue to have a duty to act on complaints about abuse of the service where the GP or pharmacy Terms of Service may have been breached. CfH will be continuing to provide the NHS with both summary and detailed reports about nominations to support the investigation of complaints.
Authoring payment of the On-going EPS Allowance: It is anticipated that the NHS CB through its regional/area teams will be responsible for authorisation of the EPS On-going Allowance (Drug Tariff Part VIA 4.10) (to be confirmed). NHS Prescription Services will continue to process payment of the on-going EPS allowance.
Support with co-ordinating resolution of local issues arising in use of the service: For technical problems using the EPS service, system suppliers are currently and should continue to be a contractor’s first point of contact. PCTs currently play a role in resolving operational issues that can’t be resolved directly between GPs and pharmacists, for example if inappropriate information is being included in electronic prescriptions for printing on the right hand side of dispensing tokens. Going forward, there may be a variety of organisations involved in supporting resolution of problems; this could include relevant leads at CSUs, CCGs or LATs.
General Support for Deployment: In some areas, PCTs have supported deployment by organising beneficial local awareness raising events or facilitating bringing together GPs and pharmacies to discuss business change. In many areas, this type of support will continue to be available, but in other areas, it may not. Support is available if LPCs want to independently organise events to provide support for contractors.
Posted 21 February 2013