Opposing a new pharmacy application or relocation
When a new pharmacy application or relocation is notified in your area, your business may be at risk. The regulatory process allows affected contractors to make representations — but only within a strict timeframe and in the correct format. TI Pharmacy Consultancy manages this on your behalf.
What we do
- Urgent review of the notified application and initial assessment of the threat to your business
- Advising on your grounds for objection under the Regulations
- Preparing representations to the ICB within the notification period
- Responding to the applicant's counter-representations
- Attending ICB meetings and oral hearings on your behalf
- Preparing and submitting an appeal to NHS Resolution if the application is granted
How it works
Urgent review
We review the application immediately and assess its likely impact on your business.
Representations
We prepare detailed, regulation-focused representations for submission to the ICB.
Counter-representations
We respond to any representations made by the applicant.
Hearing attendance
We attend any oral hearing and present your case to the decision-making committee.
Appeal if necessary
If the application is granted, we advise on and prepare an appeal to NHS Resolution.
Deadlines for initial representations are typically 45 days from notification — contact us immediately.
Frequently asked questions
The notification period for representations is typically 45 days from the date of notification by PCSE. This deadline is strict — it cannot be extended. Failing to submit representations within this period means you lose the right to attend any oral hearing and your right of appeal against a favourable determination. Contact TI Pharmacy Consultancy immediately if you have received a notification.
Representations against a pharmacy application must be grounded in the regulatory criteria — they must address why the application does not satisfy the relevant market entry ground, or why granting it would not be in the interests of the local population. Personal objections or general commercial concerns are not sufficient. TI Pharmacy Consultancy prepares regulatory-focused representations that address the correct legal criteria.
Yes. Both new pharmacy applications and significant change relocation applications are subject to a notification and representation period. Existing contractors in the affected area can make representations against either type of application.
The ICB considers all representations alongside the application. In many cases, an oral hearing is convened at which all parties — the applicant and those who made representations — can present their case. TI Pharmacy Consultancy attends oral hearings and presents your case to the committee.
If the ICB grants an application you have opposed, you generally have 30 days to appeal to NHS Resolution's Primary Care Appeals service. Having made correct and timely representations at the ICB stage is a prerequisite for appealing. TI Pharmacy Consultancy manages the appeal process if required.
Ready to start?
Contact us for a free initial assessment. We will review your situation and give you an honest view of your options and the likely chances of success — before you commit to anything.
Get in touch