DRAFT

Document Status:DRAFT
Developed By:
Date of Policy / 16/02/11
Next Review Date / TBC
Sponsor / Catherine Dampney
Approved By / On
Version / Date / Comments / By Whom
1.0 / 16/02/11 / First Draft / Chris Phillips
1.1 / 29/11/12 / Minor revisions / Chris Phillips

Contents

1Purpose...... 4

2Scope...... 4

3Background...... 4

4Nomination Procedure...... 5

Capturing and Setting the Nomination...... 6

Changing the nomination...... 8

Cancelling the nomination...... 8

Using the nomination...... 8

Inducements...... 9

5Patient Suitability...... 9

6Complaints...... 9

7Nomination Monitoring and Review...... 10

8Policy Review…………………………………………………………………10

Appendix A – Template SOP, Prescribing Only Surgery..…………………….11

Appendix B – Template SOP, Dispensing Surgery…………………………….15

Appendix C – Template SOP, Community Pharmacy…………………………19

Appendix D – Nomination Request Form……………………………………….23

1

ELECTRONIC PRESCRIPTION SERVICE RELEASE 2

PROJECT MANAGEMENT AND GOVERNANCE STRUCTURE

1Purpose

1.1This policy describes how Xxxxxxxxx and its GP, pharmacy and dispensing appliance contractors will implement and manage nominations for the Electronic Prescription Service Release 2 (EPS 2). The overall aim of the policy is to ensure that the maximum benefit for patients and contractors is achieved by EPS 2.

1.2The policy will ensure that:

  • patients are given the appropriate information in order that they can make informed decisions
  • GP practices manage patient wishes regarding nominations and EPS 2 appropriately
  • dispensing contractors manage patient wishes regarding nominations and EPS 2 appropriately

1.3The policy will also seek to ensure that no patient or contractor is disadvantaged by the implementation of EPS 2 in the Xxxxxxxxx area.

2Scope

2.1This policy covers nominations in EPS 2. It includes guidance on managing nominations for both GP practices and dispensing contractors. It also covers Xxxxxxxxx’s approach to monitoring nominations. It does not apply to EPS release 1.

2.2This policy impacts on GP surgery staff, community pharmacy staff, dispensing appliance contractor staff and PCT staff involved in managing nomination related complaints and nomination monitoring.

3Background

3.1EPS 2 builds on release 1 of the service. EPS 2 allows prescriptions to be generated, transmitted and received electronically. This will have benefits for patients, prescribers and dispensers.

3.2The NHS (Primary Medical Services) (Miscellaneous Amendments) Regulations 2005 and the NHS (Pharmaceutical Services) Regulations 2005 make provision for the introduction of nomination.

3.3The NHS (Primary Medical Services) (Miscellaneous Amendments) Regulations 2005 state that:

  • a prescriber may only order drugs, medicines or appliances by an electronic prescription if they have a contract with a PCT which is specified by the Secretary of State as one which can authorise its contractors to use EPS 2
  • an electronic prescription can only be used if the patient has nominated a dispenser, confirmed that he intends to use that dispenser and consents to the use of an electronic prescription “on the particular occasion”
  • a GP surgery that operates the EPS 2 will, when requested by a patient, enter in that patient’s NHS care record a nominated dispenser or change the dispenser or add a further dispenser (but not to exceed the maximum allowed) as chosen by that patient

3.4The Primary Medical Services (Electronic Prescription Service Authorisation) Directions 2012 lists those PCTs permitted to authorise prescribing contractors to use EPS 2. It also obliges the PCT to monitor dispenser nominations in order to identify unusual or unexpected distribution of nominations.

3.5Dispensing contractors will have to set nominations where requested to by patients,even if it involves nominating a contractor other than themselves. However, dispensing contractors may offer EPS 2 as soon as they have a software system that has been granted full roll out approval by Connecting for Health.

3.6To make use of the EPS 2patients must nominate a dispensing contractor to which they would like electronic prescriptions sent.

3.7The appropriate use of nomination will be underpinned by four principles.

Principle 1. Patients must be provided with sufficient information about the EPS 2 before nomination is captured.

Principle 2. Dispensing contractors must not offer any type of inducement to encourage patients to nominate them.

Principle 3. Dispensing contractors will need to capture, record and act on patient’s nomination request in a timely manner.

Principle 4. Prescribers and dispensing contractors must establish Standard Operating Procedures (SOPs) for nomination.

4Nomination Procedure

4.1In accordance with principle 4 above contractors must establish a SOP for dealing with nomination.SOPs will ensure that nomination is communicated consistently to patients and is captured in an auditable way. Members of staff at prescribing and dispensing contractors can set and amend nominations, provided they have an individually registered Smartcard with a User Role Profile that allows access to the Personal Demographic Service (PDS). Template standard operating procedures for prescribing only practices, dispensing practices and community pharmaciesare included in appendices A, B and C.

4.2A variety of signs are available from connecting for health that a contractor may use to indicate that they are able to offer EPS 2 ( This will help patients to identify EPS 2 participating contractors.

4.3Patients will also be able to find EPS 2 compliant dispensing contractors by searching on the NHS choices website (

Capturing and Setting the Nomination

4.4In accordance with key principle 1 patients must be provided with sufficient information to support their choice. Principle 1 describes the information to be given to the patient, namely that:

  • the EPS 2 involves the electronic transmission of prescriptions safely and securely.
  • any dispensing contractor operating EPS 2 can be nominated
  • patients are not restricted to nominating a dispensing contractor located close to their GP practice
  • where patients use their nominated dispensing contractor their prescription willbe sent automatically to that dispensing contractor
  • if the patient chooses not to use their nominated dispenser for a particularprescription, they must make that clear at the time of requesting theprescription
  • patients can change their nominated dispensing contractor at their GP practice or any dispensing contractor atany time. This includes when they are part way through a repeat dispensing cycle,any prescriptions which have not been downloaded before the changeof contractor will be accessed by the new nominated dispensing contractor
  • where a patient has nominated a dispensing contractor, the dispensingcontractor will usually be able to access the electronic prescription in advanceof the patient arriving – allowing them to prepare the prescription in advance
  • if the patient goes to a dispensing contractor other than the one they havenominated, there may be delays before the dispensary is able to access theprescription
  • patients do not have to receive their prescriptions via the Electronic PrescriptionService, however, if it is not used, services associated with it (such asnomination) cannot be used.

The NHS Connecting for Health leaflet ‘Explaining the Electronic PrescriptionService – Information for Patients and Carers in England’ contains all this information and is available to order from This leaflet can be used as a “script” or prompt to ensure that staff fully explain EPS 2 nomination to patients.

4.5The information given to patients to support their decision regarding nomination must be delivered in an impartial manner. Patients must be allowed to make their own decisions about who (if anybody) they nominate.

4.6It is expected that nominations will be mainly captured through face to face meetings; however it is up to contractors to decide how nominations will be captured.

4.7Nominations must be captured in an auditable way so that, if challenged, processes are in place to back up information following a patient complaint, or from an audit perspective.Dispensing practices, community pharmacies and dispensing appliance contractors should ask patients to sign a nomination request form (appendix D). It would be good practice for prescribing only surgeries to ask patients to sign a nomination consent form.

4.8The process for setting the nomination is the same for both prescribers and dispensers. Search the patient’s PDS record using the NHS number. If the NHS number is not available perform a “simple trace” using the patient’s name, registered address, date of birth and gender. The PDS record should then be updated with the nominated dispenser. Any nomination requests (including changes and cancellations) must be acted on within one working day of the patient request.

4.9A patient may nominate up to one of each type of dispensers;a community pharmacy, a dispensing appliance contractor and a dispensing practice if they wish.If they wish to do this the steps in 4.3 above will need to be repeated. Only the dispensing doctor can set the dispensing doctor nomination.Patients may not nominate more than one contractor of the same type.

4.10Dispensing contractors may not assume that patients making use of a prescription collection service will nominate them for EPS 2. Explicit consent and nomination will need to be obtained for EPS 2.

4.11Similarly dispensing GP sites must also offer the patient a choice of dispensing services so the patient can make their own decision to nominate the practice dispensary, a local pharmacy,anappliance contractor or all three.

4.12Both prescribers and dispensers have a duty to ensure that nomination is available to every patient regardless of age, disability, gender, race, sexual orientation, religion/ belief and vulnerable groups, and all attempts should be made to ensure openness and fairness towards all patients.

4.13Both prescribers and dispensers are advised to use professional judgement to determine whether it is appropriate for the patient’s nomination to be set, bearing in mind that there is no minimum age applicable to nomination.Nomination can be requested by a representative if they have the patient’s consent.

4.14Principle 3 states that “dispensing contractors will need to capture, record and act on patient’s nomination request in a timely manner”. This principle does allow for the collection of nominations up to four to six weeks prior to deploying an EPS 2 pharmacy system. If nominations are collected in advance then these must be re-confirmed once the system is in place. This principle also requires that nominations that are to be entered later rather than while the patient waits should be entered without delay. In any event all nomination requests should be entered on the PDS within one working day. The PCT will liaise with contractors regarding the collection of nominations in advance of surgeries “going live” with EPS 2 once the go live dates are known.

Changing the nomination

4.15The process for changing a nomination is the same as that for setting a nomination; replace the old information with the updated information. Any nominated prescriptions not yet retrieved by the originally nominated dispenser will be transferred to the new one.

4.16Patients with a repeatable prescription should be informed that the best time to change their nomination is soon after they have collected the last repeat. If they change the nomination before the end of the repeatable prescription it is possible that the next repeat will already have been retrieved by the original nomination in anticipation of the patient’s arrival.

4.17Any requests to change (or cancel) a nomination must be acted on within one working day.

4.18Dispensing doctor practices, pharmacies and dispensing appliance contractors should ask the patient to complete a nomination request form. It would be good practice for prescribing only surgeries to do the same.

Cancelling the nomination

4.19The process is similar to that involved in setting a nomination. The nomination information is removed from the patient’s PDS record.

4.20If a patient cancels their nomination part way through an electronic repeat prescription they will have to return to the GP to obtain a paper version.

Using the nomination

4.21Patients should be made aware that if they have nominated they must ensure that they go to their nominated dispenser to collect their prescription items

4.22A patient always has the option of not using their nominated dispenser for any particular prescription. A mechanism must be in place to ensure that a patient who has a nominated dispenser wishes to use the EPS on each occasion. A sign or poster could be displayed in the reception area or consultation room advising the patient that their prescription will automatically be sent to their nominated dispenser unless they specify otherwise. Where a patient phones a prescription request through to the prescriber then an explicit message to this effect will be needed.

4.23Prescribers will also need to consider how to decide which dispensing contractor an electronic prescription should go to if more than one is nominated. This includes dispensing doctors.

4.24Dispensing contractors will need a process for authenticating and identifying persons calling to collect electronic prescriptions. This will be similar to that used for persons calling for prescriptions the dispenser has collected from the surgery on the patient’s behalf.

4.25A patient or carer may check the identity of their nominated dispensing contractor at any point at any EPS 2 compliant site. If the patient enquires about which dispenser they have nominated, a dispenser must volunteer this information, even if this is not them.

Inducements

4.26Principle 2 says that “dispensing contractors must not offer any type of inducement to encourage patients to nominate them”. Dispensing contractors and their staff may not offer any gift or reward to encourage a patient to nominate them. This includes offering a share of dividends of profits, discounts and loyalty points. This principle is supported by the Pharmaceutical Services Regulations 2012. Offering any inducement would be a breach of the terms of service and may result in the PCT taking action.

4.27The NHS (Primary Medical Services) (Miscellaneous Amendments) Regulations 2005 prohibit prescribers from tryingto persuade a patient to nominate a particular dispensing contractor. Should a patient ask a prescriber to recommend a dispenser, then a list of dispensers offering EPS 2 in the area should be supplied.

5Patient Suitability

5.1Nomination is likely to be most suitable for patients who

  • receive regular repeat prescriptions
  • are already using Repeat Dispensing (RD)(batch issues)
  • tend to collect their prescriptions from the same place each time
  • currently use a prescription collection service

6Complaints

6.1All patient complaints will be dealt with in accordance with “The Local Authority Social Services and National Health Service Complaints (England) Regulations 2009”.

6.2Should a contractor receive a complaint from a patient regarding nomination then, wherever possible, this should be investigated and resolved by the contractor at local level. Where a contractor receives a nomination related complaint from a patient that relates to another contractor then, with the patient’s consent, that complaint should be forwarded to the relevant contractor for investigation at local level.

6.3Where a patient does not wish to go directly to the relevant contractor, or a local resolution has not been possible, thecomplaint can be raised with Xxxxxxxxx’s Patient Advice and Liaison Service (PALS). PALS will then liaise with the organisation involved in order to attempt to resolve the complaint, liaising with the complainant to agree an appropriate approach.

6.4Complaints by one contractor regarding another contractor regarding nomination should be sent to the PCT ETP project manager.

6.5Where a contractor is found to be in breach of their terms of service in relation to nomination the PCT will take action as described in the appropriate regulations.

6.6The EPS 2 project group will monitor complaints with a view to identifying any trends.

7Nomination Monitoring and Review

7.1The PCT will monitor the nomination activity of prescribing and dispensing contractors. This will be in accordance with the requirements laid out in the “EPS Authorisation Directions 2008” as amended.

7.2Monitoring will be undertaken by the EPS 2 project group. The group will make use of nationally produced monitoring reports and any concerns or complaints raised by patients, dispensers or prescribers. The project group may also use EPACT data to monitor changes in dispensing activity.

7.3The project group will ensure that standard operating procedures are in place and will be monitoring:

  • complaints or suspicions around nomination recommendations, inducements, gifts, rewards, dividends as an inducement or in consideration of a named nomination;
  • trends in nominations.

7.4This policy will be reviewed in the light of experience, and any further guidance or legal changes, and as a matter of course, every 12 months.

  1. Policy Review

8.1 This policy will be reviewed in TBC 2012

Version:1.0

Date:16 February 2011

Author:Bryan Taylor, I.T. Primary Care Project Manager - Xxxxxxxxx

1

Appendix APrescribing Only Practices

<insert Practice name> SURGERYstandard operating procedure (SOP) for managing electronic prescription service 2 (EPS 2) nominations

1Objectives

1.1To ensure that patients are given sufficient information regarding EPS 2 nomination to properly inform their decision.

1.2To ensure that information regarding nomination is delivered in aconsistent and impartial manner in order that no patient or contractor is disadvantaged.

1.3To ensure that nominations are captured, recorded and changed appropriately, accurately and promptly.

2Scope

2.1This procedure covers the capture, recording and changing of EPS 2 nominations.

3Process

Capturing the nomination

3.1When a patient enquires about nominating a dispenser, they should be given the following information:

  • EPS 2 involves the electronic transmission of prescriptions safely and securely.
  • any dispensing contractor operating EPS 2 can be nominated (only eligible patients can nominate a Dispensing GP practice and only Dispensing GP practice staff can set nomination for that practice)
  • patients are not restricted to nominating a dispensing contractor located close to their GP practice
  • where patients use their nominated dispensing contractor their prescription will be sent automatically to that dispensing contractor
  • if the patient chooses not to use their nominated dispenser for a particular prescription, they must make that clear at the time of requesting the prescription
  • patients can change their nominated dispensing contractor at their GP practice or any dispensing contractor at any time. This includes when they are part way through a repeat dispensing cycle, any prescriptions which have not been downloaded before the change of contractor will be accessed by the new nominated contractor
  • where a patient has nominated a dispensing contractor, the dispensing contractor will usually be able to access the electronic prescription in advance of the patient arriving – allowing them to prepare the prescription in advance
  • if the patient attends a dispensing contractor other than the one they have nominated, there may be delays before the dispensary is able to access the prescription
  • patients do not have to receive their prescriptions via the Electronic Prescription Service, however, if it is not used, services associated with it (such as nomination) cannot be used.

3.2Patients should be offereda copy of the “Explaining the Electronic Prescription Service – Information for Patients and Carers in England” leaflet to reinforce the above messages.