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R2 Arrangements

In Release 2 of the Electronic Prescription Service, dispensing contractors will have access to a part of the NHS CRS known as the Personal Demographics Service. Therefore, dispensing contractors and their staff will be required to adopt the same ‘single card’ access model as all other staff accessing parts of the NHS CRS.

Click on the link below to download the CFH/PSNC Guidance for Contractors on the Release 2 smartcard model and the migration of smartcards for Release 1 to Release 2: 

 Release 2 Guidance Leaflet

During the initial implementation of EPS Release 2 further work will be undertaken to determine the impact of these arrangements on business processes and workload.

These arrangements do not change the existing legal and professional responsibility for dispensing.

A summary of the key points can be found on this section of the website:

Registration for an NHS CRS Smartcard

As with Release 1 smartcards, NHS CRS Smartcard registration will be undertaken by local Registration Authorities (RA). PCTs have responsibility for establishing their own Registration Authority service – this may be within a primary care trust, as part of a shared local health community service or a wider shared service.

The Registration Authority will ensure that, where needed, all the appropriate identity checks are performed, and that the terms and conditions of NHS CRS Smartcard use (known as the RA01 form) are understood and acknowledged with the applicant’s signature.

Pharmacists who have an EPS Release 1 card (known as the EPS01 card), will only have to sign the terms and conditions for the NHS CRS Smartcard. Identity checks would have been conducted when they were first registered for the EPS01 card. All Pharmacy staff registering for an NHS CRS Smartcard for the first time will have to go through the full registration process which includes identity checks that satisfy government standard ‘e-GIF Level 3’. This means providing at least three forms of ID (photo and non-photo), including proof of address and attending a face-to-face meeting with the PCT Registration Authority.

Contact your local PCT Registration Authority or LPC to find out what arrangements are in place locally for this meeting, for example Registration Authority visits to pharmacies or pharmacy specific sessions at the PCT. 

As part of the registration process, a 'sponsor' must grant approval of appropriate Role Based Access Control (RBAC) codes so that staff have appropriate access to the NHS CRS and EPS based on their job role and, if necessary, area of work. Sponsors are identified by the PCT Registration Authority. Registration Authority Managers have been advised to consult with local pharmacy representatives to propose individuals who could act as sponsors, for example PCT pharmacy advisors, pharmacy managers etc. A key consideration is the accessibility of sponsors to ensure there are not delays in the Smartcard registration process.

Smartcard Model for Release 2

The Smartcard model for dispensing contractors and their staff operating EPS Release 2 systems is:

1. One NHS CRS Smartcard per authorised user of the service.

2. To use an EPS Release 2 compliant system, all cardholders will sign the RA01 terms and conditions (this means no Smartcard sharing and no sharing of access sessions with the NHS CRS).

3. EPS Release 2 pharmacy staff will need an appropriate user role profile (URP) registered with the NHS CRS User Directory before they can use any EPS Release 2 compliant dispensing system. 4

4. The NHS Registration Authority policies and procedures will ensure that pharmacy staff are issued with Smartcards and registered with the user role profile to meet the e-GIF Level 3 Government Standard.

5. All users who need access to the system such as pharmacists, pre-registration pharmacists, counter assistants, and dispensing technicians will need to be registered with an appropriate access profile as defined by the local Registration Authority.

6. Pharmacy staff will be allocated access rights dependent on their roles within the pharmacy as deemed appropriate by the sponsor.

7. All pharmacy staff will be registered with an organisation identifier that represents the NACS code of the pharmacy site where they operate the service on a regular basis.

8. The NHS Registration Authority within a primary care trust (PCT) can only add, modify, or delete a user role profile for an organisation associated with that PCT.

9. The only permitted exception to this model is the case of community pharmacists/dispensing technician locums who may need to legitimately work within many community pharmacies at short notice. In such cases, they will also have a user role profile registered against a generic organisation NACS code for a “locum pharmacy”. In such cases, a warning will be displayed to the user when they log on to a local pharmacy system.

10. All locum pharmacist/dispensing technicians will be registered with a locum user role profile. All pharmacist/ dispensing technicians with a locum user role profile will be able to work with any EPS Release 2 compliant system connected to the service.

11. The NHS Registration Authority within any PCT will be able to create a user role for a “locum” pharmacist/ dispensing technician.

12. If a user does not have a user profile for the site they are in or the locum pharmacy profile they will not be able to use the service.

13. In Release 2 of the Electronic Prescription Service, dispensing contractors will have access to a part of the NHS Care Records Service known as the Personal Demographics Service. If a user attempts to access a record in the PDS that has previously been flagged as sensitive, an alert will be generated by the service. These will be sent to the appropriate authority within the PCT for investigation.

Cancelling a Smartcard

If a Smartcard is no longer required, for example a member of the dispensing staff has left,  the pharmacist or pharmacy manager should advise the local Registration Authority prior to a user leaving an organisation. The Registration Authority will then need to follow the appropriate access removal process.

Leavers with no intention of returning to an organisation in the near future, where a Smartcard is required to access NHS CRS compliant applications, for example users having a change of career or those retiring, should have their Smartcard and its certificates revoked using an RA03 form.

Alerts

Dispensing contractors have a duty of care to keep information they access on the NHS CRS safe, secure and confidential. They are bound by the terms and conditions as set out in the RA01 form and should be aware of Confidentiality: NHS Code of Practice and the Care Record Guarantee, which is the commitment made to patients by the NHS about how information held on the NHS CRS will be governed.

A record will be kept of everyone who looks at information the NHS CRS holds about a patient. Patients can ask to have a list of everyone who has looked at their records and when they did so. Strict and robust safeguards are in place to protect the security and confidentiality of every patient’s health record, including the demographics information stored in the Personal Demographics Service (PDS). If a user attempts to access a record which has previously been marked sensitive, an alert will be generated by the service. Notification of the alert will be sent to the appropriate authority within the PCT for investigation.

Migration of Pharmacists with Release 1 Cards to NHS CRS Cards

EPS01 cards that are used for EPS Release 1 will not operate in an EPS Release 2 system. This means that all sites currently using EPS Release 1 will need to ensure staff migrate to the NHS CRS Smartcard and sign the RA01 terms and conditions. This migration will take place as part of the EPS Release 2 implementation activities.

A number of factors will need to be considered when deciding the specific action required. These include:

• Planned go live dates
• Circumstances of the individual pharmacist; In particular, do they work at one site or a range of sites
• Ensuring business continuity of EPS Release 1 functionality throughout the nationwide transition to EPS Release 2.

If by upgrading pharmacist EPS01 cards to NHS CRS Smartcards, a pharmacy is left without an individual with an EPS01 card to operate the Release 1 system, the Registration Authority can consider the following options:

Option 1: Issue the pharmacy with an EPS01 ‘premises card’ to ensure continuity of EPS Release 1 functionality until the pharmacy upgrades to an EPS Release 2 dispensing system. This card will be retained in the pharmacy. There is no requirement for a face to face meeting for a ‘premises card’ to be issued. They can be posted or delivered to the pharmacy with a letter of receipt (EPS01 form). The Passcode will be sent separately. If a receipt is not confirmed within a specified period, the card will be cancelled.

Option 2: Issue an EPS01 card to one or more staff within the pharmacy with an EPS Release 1 dispensing system. If this is decided locally between the pharmacy and the PCT, as an alternative to the ‘premises card’, the EPS01 cards can be upgraded remotely to NHS CRS Smartcards when the site enables EPS Release 2.

A number of factors will need to considered before determining the most appropriate option. These include:

• Speed of obtaining the card particularly if a face to face interview is required. This would be required for option 2
• Staff that will require a card for Release 2. With option 2 the staff will complete and sign an RA01 terms and conditions form for their EPS01 card to become their NHS CRS smartcard when the site implements Release 2.

The National Registration Authority has advised PCTs that they should start issuing ‘premises cards’ as soon as possible to ensure business continuity of access to EPS Release 1 systems throughout the nationwide transition to EPS Release 2. Guidance on local arrangements and the timing of issuing cards will be communicated locally by PCT Registration Authorities.

Importance of Adopting National Guidance on R1 to R2 Transition Model

PSNC strongly recommends that PCT RA's adopt the National guidance as outlined above. We are aware some PCT's have considered alternatives including putting R1 (EPS01) and R2 (RA01) roles on the same smartcard. The risks of not adopting the national guidance include: 

• There is a high percentage of Locum Pharmacists moving between pharmacy sites. Any differences in registration and access process between PCT areas may cause confusion and access problems.
• Registering pharmacists with the EPS01 (Rel 1) and RA01 (Rel 2) RBAC job roles on the same smartcard, contravenes the smartcard terms and conditions pharmacists have agreed to. It is not possible to adhere to two sets of conditions using the same card.
• Any action to be taken when a user breaches security may be unenforceable if the terms and conditions of access are not clear.

Frequently Asked Questions

1. How are levels of access determined?

Role Based Access Control is the key to the security of data held on the Spine. It controls what a user can do and what as a consequence they can see. Role Based Access Controls help to preserve patient safety and confidentiality.

A user's role relates to the job role they hold in an organisation, the area in which they perform their duties and their level of involvement in patient care. For example: A community pharmacist or dispenser who is migrating to the NHS CRS Smartcard may have the following user profiles assigned to their NHS CRS Smartcard. This would be done by the Sponsor completing the RA02 indicating what user profiles are required by the community pharmacist for example:

• R8003 Health Professional Access Role
• T2200 Prescribing and Pharmacy Area of Work

A Pre-Registration Pharmacist may be assigned the following profiles

• R8004 Healthcare Student Access Role
• T2200 Prescribing and Pharmacy Area of Work

The additional Activity B0572 Manage Pharmacy Activities may be required if the pre-registration pharmacist undertakes any of the following activities ‘Send prescription reimbursement claims to payment authority or update spine if linked to ETP. This will be determined locally as deemed appropriate by the Sponsor.

2. What arrangements are in place to provide access to EPS Release 2 for non locum pharmacists who practice across PCT boundaries?

Prior to working at a pharmacy based in another PCT the pharmacist must contact the relevant PCT’s Registration Authority to organise for the appropriate user profile to be added to their NHS CRS Smartcard. The pharmacist’s Sponsor should complete an RA02 form which is sent to RA Agent/Manager for the necessary amendments to be actioned. This can be done remotely i.e. the user does not have to be present.

If the pharmacist has the locum profile on their card, they are able to work at any EPS Release 2 enabled pharmacy in England and are not required to go through this process.

3. What is the purpose of each of the Registration Authority forms?

4. Where can I obtain a certain smartcard form?

All Smartcard forms can be obtained from the PCT Registration Authority. Please contact your sponsor or Registration Authority to obtain the form(s) you require.  

5. Who can sign the EPS01 (Premises) form?

There are two parts to the EPS01 (Premises) form.

Part A contains the conditions of the EPS01 Premises Card which must be read and understood by all users of the EPS01 Premises card.

Part B of the form should be signed by someone in the pharmacy who has been authorised to sign the form on behalf of the pharmacy owner. The EPS01 Premises Form Part B is also signed by the sponsor.

It is important to discuss with your PCT the local arrangements for issuing the card.

6. What arrangements are in place to provide temporary access to EPS Release 2?

Each PCT Registration Authority has processes in place to grant the temporary access to NHS CRS applications including EPS Release 2.

There is a Fallback Smartcard solution that ensures NHS CRS users have continued access to compliant applications in the event a user has lost or forgotten their Smartcard, or their Smartcard has been stolen or damaged.

Please note: Each PCT will have its own arrangements and you are advised to contact your PCT’s Registration Authority to find out what arrangements are in place for temporary access to EPS Release 2.

7. If the pharmacy ODS code changes, do I need to update my smartcard? (i.e. will the smartcard stop working at that premises)

Yes, All pharmacy staff will be registered linked to ODS codes of the pharmacy sites where they operate the service on a regular basis. The exception to this model is the case of community pharmacists/dispensing technician locums who may need to work within many community pharmacies at short notice. In such cases, they will also have a user role profile registered against a generic organisation ODS code for a “locum pharmacy” that allows them to operate the system from any pharmacy.

If the pharmacy ODS code changes all users need to have the new ODS code added to their profile. An RA02 form needs to be completed and sent to the RA Manager to be actioned. This can be done before the removal of the old ODS code to aide transition.

To minimise the disruption caused by changes in ODS codes, a new ODS code should only be requested when a change of ownership occurs and the contractor buys out a business on a non debts and liabilities basis (i.e. the outgoing contractor requires payment for all items dispensed up to the date of sale). More information on ODS codes is available by clicking on the link below:

Allocation of ODS Codes

8. I registered for my Release 1 (EPS01 terms) card at PCT A. I have recently moved and am seeking to upgrade to a Release 2 (RA01 terms) card at PCT B. Does the PCT need to undertake a full identity check?

No, as long as the pharmacist had their identity checked to eGIF 3 by PCT A, all that is required is for the pharmacist to complete the RA01 form, there is no need for another identity check.

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