Opposing applications & appeals

Representations are submissions made to the ICB during the notification period for a pharmacy application — before the ICB has made its decision. An appeal is made after the ICB has decided, to NHS Resolution's Primary Care Appeals service. The two processes are sequential: you must make correct representations at the ICB stage to preserve your right of appeal if the decision goes against you. TI Pharmacy Consultancy manages both processes.

The notification period for representations is typically 45 days from the date of PCSE notification. This deadline is absolute — it cannot be extended. In practice, preparing thorough regulatory-focused representations takes time, so you should contact TI Pharmacy Consultancy as soon as possible after receiving a notification — ideally within the first few days.

Yes. Both new pharmacy contract applications and significant change relocation applications are subject to the notification and representation process. Existing contractors whose business may be affected by either type of application can make representations to the ICB.

If you failed to make representations within the notification period, you generally lose the right to attend any oral hearing and your right of appeal. In limited circumstances it may be possible to make late representations with ICB agreement, but this cannot be relied upon. Contact TI Pharmacy Consultancy immediately if you have missed or are close to missing a deadline — early advice gives the best chance of preserving your position.

Yes. TI Pharmacy Consultancy advises on objections and appeals in both England and Wales. The Welsh process differs from the English framework — applications in Wales are determined by local health boards and the appeals route differs from NHS Resolution. We advise on the correct process for your jurisdiction.