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Contract Monitoring

For the first 6 month 'implementation phase' of the contract there was no monitoring of the contract services conducted; PCTs have had the responsibility for monitoring the successful implementation of Essential and Advanced services since 1st October 2005.

Arrangements for monitoring of Enhanced services may be set out in local contracts or Service Level Agreements, and might be carried out at the same time as monitoring the Essential services.

PCTs can choose to monitor the contract in a way that meets their local approach to such matters. They are advised to discuss and agree the approach to be taken with the Local Pharmaceutical Committee (LPC), in order to ensure that maximum contractor 'buy in' can be achieved.

In most circumstances monitoring will involve an annual visit to the pharmacy premises. The use of a self-assessment questionnaire (see below) may precede the monitoring visit; these questionnaires can be a helpful tool for contractors to assess their readiness and to highlight areas of service provision which may require additional attention.

Pharmacy contractors have the right to request the attendance of an LPC member at any monitoring visits conducted by the PCT.

PCTs must ensure they only monitor the requirements of the contract, i.e. those set out in the Regulations and the Secretary of State Directions, and not any additional matters outside of this scope.

PSNC Contract Workbook

Pharmacy contractors should ensure they prepare for the monitoring of the contract. The PSNC New Contract Workbook can be used to prepare for PCT monitoring.

It has been designed to allow pharmacy contractors to record compliance with the obligations under the Pharmacy Contract and can help in the collation of the necessary information for PCT monitoring visits. Within the workbook, there are sections to record information that may be requested during monitoring visits – these sections have been prepared to coincide with the details set out in the monitoring toolkit that has been prepared for PCTs by NHS Primary Care Contracting, so should ensure that pharmacy contractors can prepare for monitoring visits with the knowledge of the type of information that may be requested.

PSNC recommends that PCTs use the NHS Primary Care Contracting (PCC) contract monitoring toolkit as the basis for their monitoring of the contract (see below for further details).

The PSNC Contract Workbook 2009-10 was posted to all pharmacy contractors in mid June 2009, which includes the appendices and reference material.

 Additional copies can be obtained by:

• Downloading the publication for free from the online publications database on the PSNC Website
• Hardcopies can also be purchased from PSNC. If you would like to purchase additional copies of the PSNC Workbook 2009-2010 please send your name and address together with cheque for payment of £10 (the price includes p&p) to PSNC Publications, 59 Buckingham Street, Aylesbury, Bucks. HP20 2PJ.

PCC Contractor Monitoring Toolkit - the community pharmacy assurance framework (CPAF)

As part of the support to the NHS on the implementation of the community pharmacy contract, the NHS Primary Care Contracting Team was asked to co-ordinate and support the work of Strategic Health Authorities (SHAs) and PCTs in developing a toolkit for assessing compliance and quality under the new contract arrangements.

Although PCTs are free to design and implement their own framework for this purpose, SHAs felt that it would be helpful to have a nationally designed and agreed framework with a core set of indicators and quality markers for assessing implementation, rather than PCTs ‘reinventing the wheel'.

A nationally developed standard framework would also ensure that contractor organisations, audit and other support organisations could also be consulted on the drafting of the document.

The final toolkit was published in September 2005 as the Community Pharmacy Assurance Framework (CPAF) and it has been used successfully by many PCTs. An updated version of the toolkit has been produced by NHS Primary Care Contracting, working with PSNC and is available on the Primary Care Contracting website.

The CPAF has been used as the base for the NHS Wales monitoring toolkit for Local Health Boards (LHBs). Further advice on the monitoring of the contract in Wales can be found here.

In areas where the CPAF is used, PCTs, LPCs and pharmacy contractors can be assured that the contents have been agreed nationally and fulfil the requirements of monitoring whilst ensuring only those items required under the contractual framework are covered.

In some areas PCTs may have adopted their own monitoring toolkits prepared from scratch or by amendment of the national toolkit. In these areas, questions are being asked about whether a particular request by the PCT must be complied with, where this differs from those in the national toolkit.

PCTs have a right to enter pharmacy premises and ask for access to documents which are necessary for audit or monitoring purposes. This power does not extend to requiring pharmacy contractors to copy and send to the PCT such documents, although many pharmacists are happy to do so (see below).

Monitoring the use of SOPS

One of the areas that gave rise to many questions was Standard Operating Procedures (SOPs). The Essential Service specifications require the pharmacy to have appropriate SOPs for dispensing, repeat dispensing and support for self-care.

Monitoring compliance requires only the determination of whether the pharmacy has an appropriate SOP. It does not require the PCT to carry out a detailed analysis of the content of the SOPs. Indeed, it would be unwise for a PCT to carry out any detailed examination, because it will be unable to determine what is appropriate for the individual pharmacy concerned, and any shortcomings not identified, or suggestions made which themselves cause problems in delivery of the services, could lead to the PCT itself being involved in litigation.

For this reason, the most appropriate way for a PCT to determine whether the pharmacy has an appropriate SOP is to ask to see it during a monitoring visit (but without reading it in detail), then to ask appropriate members of staff suitable questions about their procedures to establish the level of understanding and compliance with the SOP.

The above text on SOPs is taken from a joint statement issued by PSNC and NHS Primary Care Contracting.

Self-assessment & Pre-visit Questionaires

PSNC supports the use of contractor self-assessment as the first step of monitoring and a pre-visit questionnaire is included within the updated CPAF.

PCTs are likely to differ in the way that they use the monitoring toolkit, some may support self-assessment by pharmacy contractors; some may choose to undertake visits of just a few pharmacies; and others may wish to visit all pharmacies.

While there is no requirement under the Terms of Service to provide documents to the PCT in advance of a monitoring visit, PSNC does encourage pharmacy contractors to provide some information to PCTs on compliance with the contract, especially if this will avoid the need for a visit, or reduce the time needed for a visit. The pre-visit questionnaire published by NHS Primary Care Contracting was agreed by PSNC, so completing this (or locally developed equivalents containing no additional matters) would be appropriate.

PSNC set out in the 2007-8 Workbook the areas of the contract in which anonymised copies of documents might be filed, in anticipation of a monitoring visit.

Monitoring Visits

Within the pharmacist's terms of service, a pharmacist shall allow persons authorised in writing by the PCT to enter and inspect his pharmacy at any reasonable time for the purpose of ascertaining whether or not the pharmacist is complying with the requirements of their terms of service.

Within the PCC Community Pharmacy Assurance Framework, there are tips for PCTs conducting visits to pharmacies. Where the pharmacist requests it, the LPC can be present at the inspection.

Any visit should be planned carefully so as not to impact negatively on the day-to-day running of the pharmacy. Patients of pharmacies do not require appointments therefore any inspection teams should not necessarily expect to have the pharmacist devoted to them during any visit, nor should any inspection disrupt the concentration of pharmacy staff in the provision of care to patients.

Advice on visits to pharmacies by other external monitoring bodies can be found in the regulatory issues section of this site.

Compliance with contract requirements

The Department of Health, NHS Confederation and PSNC agreed, during the negotiations, that pharmacy contractors will be given a minimum three months written notice to remedy any non compliance before any formal action for non compliance should be taken.

The Department of Health has issued a statement to PCTs on non-compliance with the contract requirements and dispute resolution. Click on the link below to download the document.

DH Community Pharmacy non-compliance briefing (July 2006)

Frequently asked questions

What is the situation regarding the engagement of a locum pharmacist to attend a pharmacy during a PCT monitoring visit?
A. There is no requirement to engage a locum pharmacist, to free up the time of the pharmacist to spend with the PCT monitoring team. Similarly, there is no obligation on PCTs to fund the cost of a locum. As monitoring visits are usually arranged at mutually convenient times, the regular pharmacist can decide whether it would be appropriate to engage a locum.