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Pharmaceutical Services Negotiating Committee

Sorting & Submission

NHS Prescription Services are writing individually to contractors to alert them that their accounts will be priced using the CIP system and to request changes to the way that prescriptions are bundled for submission. Approximately 84% of pharmacy contractors have now received letters. Once all contractors are required to sort their prescriptions differently, the FP34C Submission document will be updated to also state the new sorting requirements

Prescriptions endorsed with a broken bulk claim, and prescriptions for calendar pack items where the quantity dispensed differs from the pack size (or sub-pack size), cannot be priced automatically via the system. This information must be inputted manually by an NHS Prescription Services operator. Therefore, to ensure accurate payment, NHS Prescription Services have requested contractors being priced using CIP to separate out these prescriptions when bundling their prescriptions for submission. Particular care should be taken when dispensing weekly prescriptions, where there is an increased likelihood that the prescribed quantity differs from the pack size or sub-pack size.

Worked Example:

Zestril 10mg tablets are supplied in a calendar pack of 28 tablets which contains 2 sub-packs of 14 tablets:

 

Prescribed Quantity Dispensed Quantity  Separate Out?   Reason  
 14  14  No Payment will be based on 14 tablets.
 10  14  No NHS Prescription Services will automatically apply the calendar pack rules and payment will be based on 14 tablets.
 10  10  Yes If the prescription is not sorted there is a risk of overpayment as NHS Prescription Services would automatically apply the calendar pack rules and reimburse the contractor for 14 tablets. If the prescription is sorted, the endorsement indicating that 10 tablets have been dispensed will be identified and payment will be based on 10 tablets.
 20  20  Yes If the prescription is not sorted there is a risk of underpayment as NHS Prescription Services would automatically apply the calendar pack rules and reimburse the contractor for 14 tablets. If the prescription is sorted, the endorsement indicating that 20 tablets have been dispensed will be identified and payment will be based on 20 tablets.

 

In the Department of Health consultation on the ‘Simplification of the Reimbursement and Remuneration rules’, the Department proposed removing the calendar pack rules and replacing them with a more general rounding rule. A proposal was also made to remove individual claims for broken bulk on readily available items and replace this with a monthly allowance to compensate contractors for residual stock. PSNC is still in discussion with the Department of Health on both of these proposals. The issues involved are complex and PSNC is working to ensure that any changes made do not disadvantage contractors.

Annual adjustments are made to the national contract funding arrangements using an agreed formula which takes into consideration increased regulatory burdens. Regulatory burdens are assessed on a retrospective basis.

PSNC is working to ensure that the additional workload associated with changes in the sorting requirements is fully quantified so that additional costs are recognised in the funding arrangements. The PPD are still evaluating whether it will be possible to simplify the submission process to remove the need for prescriptions to be sorted in prescriber order. PSNC is pushing NHS Prescription Services to remove this mandatory requirement to give pharmacy contractors flexibility in how prescriptions are filed in the pharmacy before submission. They have also started giving consideration to alternative options for sorting calendar pack and broken bulk prescriptions to reduce the burden on contractors and PPD staff.


Calendar Pack List

Click on the links below to download a list of commonly dispensed calendar packs:

List of Commonly Dispensed Calendar Packs* (PDF File)

List of Commonly Dispensed Calendar Packs* (MS Excel)

*this list is correct as of December 2007

Alternatively, search for a particular product in the online PSNC Special Container & Calendar Pack List. A hard copy of this list can be found in the PSNC Dispensing Resources Booklet 2007/08 which was sent to all pharmacies in May 2007. Additional copies are available on request for a small charge (£6).


Sorting Tips

Whilst contractors can easily identify that a prescription has a broken bulk claim (there will be a ‘BB’ endorsement), it is more difficult to assess whether the product being dispensed is a calendar pack and therefore to know whether the quantity dispensed is different from the nearest pack/subpack quantity. To improve the efficiency of sorting, one option would be for staff labelling prescriptions to include a marker on the prescription to indicate that the prescription must be sorted separately.

For example, staff could make a cross or use a highlighter in the endorsement column. Most pharmacy systems indicate on the screen whether a product being dispensed is a calendar pack.

Feedback from pharmacy contractors suggests that it is far more efficient to mark prescriptions for segregation during the labelling process or at the point of dispensing rather than reviewing all prescriptions at the end of the month to consider whether individual prescriptions need to be segregated.

PSNC wrote to pharmacy system suppliers to inform them of this issue in May 2007. Some suppliers have indicated that they would like to print an endorsement on prescription forms, for internal pharmacy use, to support the efficient sorting of prescriptions. The recommended endorsement for system suppliers to use is 'CPack' to indicate that the quantity dispensed differs from the nearest pack or subpack for items packaged in calendar packs.


Not Dispensed (ND) Endorsement

Where a pharmacist does not dispense an item on a prescription, it is recommended that pharmacy staff either score through the prescribed item on the prescription or alternatively endorse the initials ‘ND’ beside the prescribed item in the prescriber’s area on the prescription form. ‘ND’ endorsements in the endorsement column may not be picked up, resulting in an incorrect payment to the pharmacy contractor. There is no requirement to sort ‘not dispensed’ prescriptions differently for submission to NHS Prescription Services.


Out of Pocket Expenses

Out of Pocket Expenses (OOP) can be claimed in exceptional circumstances on all medicines except products in Category A or M of Part VIII of the Drug Tariff. Out of Pocket Expenses can also be claimed on appliances in Part IXB and IXC of the Drug Tariff but cannot be claimed on items listed in Part IXA or IXR.

For contractors having their prescriptions processed via the CIP system, payment for out of pocket expenses will be based on the declaration on the FP34C Submission Document. Therefore to ensure correct payment, it is essential that this declaration is completed accurately and clearly. Contractors should also continue to endorse individual prescriptions when making an OOP expense claim so that investigations can be carried out by NHS Prescription Services should the need arise. Such prescriptions should be clearly marked with an indication that out of pocket expenses are being claimed (the recommended endorsement is ‘XP’) along with information on the amount being claimed and the reason for the claim (e.g. "postage & packing"). Documentary evidence of the claim should not be sent to NHS Prescription Services, however PSNC recommends that evidence to support the claim, for example the receipt or invoice, is stored in the pharmacy in case of query or investigation.


Repeat Dispensing Batch Issues: EMIS Printing Problem

NHS Prescription Services have alerted us to a problem with the way that certain repeat dispensing prescriptions are being generated. Information obtained to date suggests this problem is limited to certain versions of the EMIS prescribing system. In some cases where there are 4 items listed on the repeat authorising (RA) form, the 4 items are being printed over 2 batch issue (RD) forms, for example, details of the prescribed product may appear on the first batch issue but the quantity to be prescribed and the directions for use on the second batch issue.

Although this is legally acceptable, prescription forms are priced by NHS Prescription Services individually so if all of the information required for payment is not on an individual form, there is a risk of incorrect payment or the form being returned to the pharmacy for clarification. The intelligent character recognition software used by CIP would not be able to collect information about a certain prescribed item from 2 different forms in calculating payment. Therefore it is essential that any contractors affected by this problem, ensure that all of the necessary information for payment is contained on the one form. For example, in this scenario, the pharmacist could use the 'PC' endorsement to endorse the quantity on the form containing details of the prescribed product, scoring a line through the directions and quantity printed on the second form.

Both NHS Prescription Services and PSNC have contacted EMIS to ask them to amend their system to resolve this problem.


Prescription Handling Tips

Avoid sticking a label on the prescription during the dispensing process. The residual glue can jam the high speed scanners.

Avoid using any pins, clips or staples on your prescriptions as these have to be removed and can delay processing.

Avoid enclosing invoices or photocopies of invoices with your prescriptions. These will not be used in the pricing process. Where NHS Prescription Services require information on the price of products dispensed, this should be endorsed on the left hand side of the prescription form.

Take care when stamping and endorsing prescriptions, ensuring that pharmacy stamps do not obliterate the age / date of birth box on the front of the prescription form. This makes it difficult for both the intelligent character recognition software and prescription processing staff to determine whether a prescription is exempt from the prescription charge on the grounds of age and could lead to inappropriate switching of prescriptions for patients exempt on age related grounds.

Endorse your prescriptions clearly and only with the minimum amount of information required for your prescriptions to be priced. Printed endorsements that are faint or out of line with the prescribed product information increase the risk of prescriptions being referred back for clarification. A guide to endorsing is available on both the NHS Prescription Services' and PSNC websites.

Follow instructions from NHS Prescription Services on the way prescriptions should be bundled for submission. Note that the FP34C Submission Document has not yet been updated with information on the additional sorting requirements for broken bulk and certain calendar pack prescriptions – this information is being communicated separately by NHS Prescription Services to individual contractors. The FP34C Form will be updated later in the year when all contractors’ prescriptions are priced under the CIP system.

Use the most recently received bar-coded label when submitting prescriptions to NHS Prescription Services.

Despatch your prescriptions by the 5th of the month.


NHS Prescription Services Address Labels

Each month, NHS Prescription Services post pharmacies a bar-coded label to use when submitting prescriptions for payment. The bar-code contains the details of the pharmacy and the submission month. To ensure correct payment, it is essential that pharmacies use the most recent label that they have received when submitting prescriptions. When a prescription bundle reaches NHS Prescription Services, the bar-code on the label is scanned to log the bundle into the system. Prescriptions are priced based on the reimbursement prices and rules in effect for the month held on the bar-code. Any stocks of old NHS Prescription Services address labels and old FP34C forms should be destroyed. Submission of the incorrect FP34C form or use of an old address label could delay payment or lead to incorrect payment.


Frequently Asked Questions

Where I have sorted broken bulk and certain calendar pack prescriptions separately for submission to NHS Prescription Services, do I need to file these in prescriber order?

No, there is no need to sort the broken bulk and calendar pack prescriptions in prescriber order. The segregated broken bulk and calendar pack prescriptions must be sorted into charge paid and exempt and included at the top of the charge paid or exempt bundles as appropriate. There is no need to separate out the segregated broken bulk prescriptions from the calendar pack prescriptions.

When sorting my prescriptions into prescriber order for submission to NHS Prescription Services, I know I have to submit the forms in prescriber order but do I need to put an elastic band around each individual prescriber’s prescriptions?

No, prescriptions should be submitted in prescriber order but contractors should not wrap an elastic band around each individual prescriber’s prescriptions in the bundle. If this is done, each band has to be removed by NHS Prescription Services staff causing delays in processing.

Do I have to sort my prescriptions as requested by NHS Prescription Services?

Yes, Part I Clause 5 of the Drug Tariff requires that ‘Contractors shall sort and despatch forms in such a manner as the PCT for England and LHB for Wales may direct’. In this instance, NHS Prescription Services is acting as an agent of the PCT so contractors are required to sort prescriptions as requested. Annual adjustments are made to the national contract funding arrangements using an agreed formula which takes into consideration increased regulatory burdens. Regulatory burdens are assessed on a retrospective basis. PSNC is working to ensure that the additional workload associated with changes in the sorting requirements is quantified so that additional costs are recognised in the funding arrangements. More detailed information on the formula for negotiating annual uplifts to the value of the contract can be found in the National Contract Funding section of the PSNC website.

If I do not sort my calendar pack prescriptions, where requested, could I be accused of committing fraud?

No. The only prescriptions that have to be sorted differently are prescriptions endorsed with a broken bulk claim and calendar pack prescriptions where the quantity prescribed differs from the complete pack or sub-pack quantity and the quantity prescribed has been dispensed.

If the contractor when sorting prescriptions uses the fact that failing to segregate certain calendar pack prescriptions will result in overpayment, and submits these in the normal bundles, then he could face allegations of fraud. Contractors are aware that the NHS Counter Fraud and Security Management Service carry out spot checks, and also have statistical and investigational tools which helps them target submitted prescriptions that deviate from normal patterns. Deliberate submission of prescriptions in a way that leads to over-payment is likely to be picked up and could result in allegations of fraud or professional misconduct.

However, genuine mistakes do occur and the NHS CFSMS would not allege fraud unless there were grounds for believing that the conduct was deliberate. As any investigation into alleged fraud would be distressing and possibly damaging to the pharmacy business, PSNC recommends that pharmacy contractors adopt rigorous procedures to ensure accurate sorting of prescriptions.

I’ve received a prescription for a product but the patient has requested less than the prescribed quantity. Do I need to sort this prescription differently for submission to NHS Prescription Services?

 No. The only prescriptions that have to be sorted differently are prescriptions endorsed with a broken bulk claim and calendar pack prescriptions where the quantity prescribed differs from the complete pack or sub-pack quantity and the quantity ordered has been dispensed.

In this scenario, to guard against any suggestion of fraud, the prescription should be clearly endorsed in the endorsement column to indicate the dispensed quantity. Although information in the endorsement column may not be picked up in the pricing process, NHS Prescription Services have not asked contractors to separate out prescriptions where the dispensed quantity is less than the prescribed quantity, other than for certain calendar packs prescriptions as explained above.

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