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What ICBs look for in a pharmacy application

Understanding how integrated care boards assess NHS pharmacy applications — the evidence, criteria and factors that matter most.

⚠ Important notice The information on this page is intended for general awareness only. It does not constitute professional advice and should not be acted upon without first consulting a qualified pharmacy applications consultant. Regulations change — always seek specialist guidance before taking any action. Contact TI Pharmacy Consultancy for advice specific to your situation.
In summary: Integrated care boards (ICBs) in England assess pharmacy applications against the criteria set out in the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013. The decision turns on whether the proposed pharmacy would meet a current need, a future need, provide improvements in access or deliver unforeseen benefits — and whether the evidence submitted demonstrates this convincingly. Understanding what ICBs are looking for is essential to preparing a successful application.

The regulatory framework

ICBs do not have a free discretion to grant or refuse pharmacy applications. They must apply the criteria set out in the Regulations and reach a decision that is supported by the evidence. The NHS Pharmacy Manual, published by NHS England, provides guidance to ICBs on how to process and assess applications. A decision that departs from the regulatory criteria without good reason can be challenged on appeal.

The ICB assesses the application through its pharmaceutical services regulations committee (or equivalent body). The committee considers the application, any representations received, and all supporting evidence before reaching a determination.

The four application grounds

A new pharmacy contract application must succeed on one of four grounds. The applicant chooses the most appropriate ground at the outset — and the ICB's assessment is focused on whether that ground is made out.

1. Current need

The most straightforward ground — the local population currently has an unmet need for pharmaceutical services that the proposed pharmacy would meet. The ICB looks for clear evidence of unmet demand: gaps in the pharmaceutical needs assessment, data on existing pharmacy capacity, distance from existing providers, population density and health deprivation indicators. The PNA is the starting point but is not the only evidence the ICB considers.

2. Future need

The proposed pharmacy would be needed in the near future, typically because of planned housing or population growth. The ICB looks for credible evidence of the anticipated development — planning consents, housing numbers, timescales — and an assessment of the pharmaceutical needs the new population will generate. Future need applications require forward-looking evidence that the development will materialise within a reasonable timeframe.

3. Improvements or better access

The proposed pharmacy would not necessarily meet an unmet need but would provide improved access to pharmaceutical services for the local population — for example, through extended hours, better location relative to where people live or work, or improved accessibility for people with disabilities. The ICB assesses whether the improvement in access is genuine and material, and not merely marginal.

4. Unforeseen benefits

The proposed pharmacy would provide benefits to the local population that were not anticipated when the PNA was prepared. This is one of the more technically complex grounds — the applicant must demonstrate both that the benefit was not foreseen and that it is a genuine benefit that the population needs. TI Pharmacy Consultancy advises on whether an unforeseen benefits argument is available in a specific case.

What the ICB looks at in detail

Beyond the application ground itself, the ICB's committee examines a number of specific factors when assessing an application:

  • The pharmaceutical needs assessment for the area and how the proposed pharmacy addresses any identified gaps
  • The location of existing pharmacies and their capacity to meet current demand
  • The proposed opening hours and whether they improve access compared to existing provision
  • Population data — size, demographics, health deprivation indices
  • Representations from existing contractors, GPs and other interested parties
  • The fitness of the applicant to be included in the pharmaceutical list
  • In controlled localities — the impact on dispensing doctor arrangements

The quality of the evidence matters

ICBs assess the evidence submitted. An application that makes broad assertions without supporting data — "there is a need for a pharmacy in this area" — is far less likely to succeed than one that presents specific, quantified evidence tied to the regulatory criteria. The covering letter and evidence bundle are as important as the application form itself.

TI Pharmacy Consultancy prepares applications with the ICB’s assessment criteria in mind from the outset — presenting evidence in the form and at the level of detail that committees expect to see.

Want to know how your application would be assessed?

Contact TI Pharmacy Consultancy for a free initial assessment of your proposed application. We will review the evidence available and give you an honest view of how the ICB is likely to approach it.

Free initial discussion

Frequently asked questions

The PNA is an important part of the evidence base but it is not determinative on its own. ICBs must also consider representations from interested parties, the specific evidence submitted by the applicant and any other relevant factors. An application can succeed even where the PNA does not explicitly identify a need, if the applicant can demonstrate unforeseen benefits or improvements in access. TI Pharmacy Consultancy advises on how to structure the evidence to address the ICB's assessment criteria.

The position on post-submission evidence varies. In general, the strongest applications are complete and well-evidenced at the point of submission. However, where an ICB requests further information, the applicant has the opportunity to respond. At an oral hearing, oral evidence and supplementary submissions can also be made. TI Pharmacy Consultancy manages this process and advises on what additional evidence to submit at each stage.

Yes. ICBs may take into account representations from GPs, other health professionals and community representatives, particularly where an application would affect existing healthcare provision. In controlled localities, the views of dispensing doctors are specifically relevant. TI Pharmacy Consultancy advises on how to address potential concerns from healthcare providers when preparing an application.

Current need means the population currently has an unmet need for pharmaceutical services that the proposed pharmacy would meet. Future need means the proposed pharmacy would be needed in the near future — for example, because of planned housing development. Future need applications require credible evidence of the anticipated population growth and the pharmaceutical needs that will arise. TI Pharmacy Consultancy advises on which ground is most appropriate for a specific application.

Location is critical. The ICB will assess whether the proposed site is accessible to the population it would serve, how it relates to existing pharmacies, GPs and other healthcare facilities, and whether its location genuinely addresses a gap in provision. A pharmacy that is close to an existing pharmacy serving the same population is unlikely to succeed on current need grounds unless there is clear evidence of unmet demand. TI Pharmacy Consultancy reviews proposed sites before any application is submitted.