What is market entry in NHS pharmacy?
An overview of the NHS pharmaceutical list and what it means to have an NHS pharmacy contract in England.
The pharmaceutical list
To provide NHS pharmaceutical services — dispensing prescriptions and being paid by the NHS for doing so — a pharmacy must be included in the pharmaceutical list for the area in which it operates. These lists are maintained by NHS England, with day-to-day administration managed by integrated care boards (ICBs). Being included in the pharmaceutical list is often referred to as having an NHS contract, although no formal contract document is signed.
Market entry
The term 'market entry' refers to the process of being entered in a pharmaceutical list for the first time, or of making changes to an existing entry — such as relocating to new premises. Market entry is tightly controlled under the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013, which set out the circumstances in which new applications can succeed.
Why new contracts are hard to obtain
The regulations require an applicant to demonstrate that granting a new contract would meet a need or provide benefits to the local population. A new pharmacy will not be approved simply because a pharmacist wants to open one. The application must show, objectively, that there is a current or future need, an improvement in access, or unforeseen benefits that existing pharmacies are not already providing.
Who regulates market entry?
Applications are submitted to Primary Care Support England (PCSE), which administers the process on behalf of NHS England. The decision itself is made by the relevant ICB or its pharmaceutical services regulations committee. Appeals against decisions go to NHS Resolution's Primary Care Appeals service.
Why professional advice matters
The regulations are complex and the consequences of a poorly prepared application are significant — both in terms of cost and time. Applications that fail because of procedural errors or insufficient evidence cannot always be corrected. Professional advice at the outset is one of the most cost-effective steps any prospective pharmacy operator can take.
Frequently asked questions
Being on the pharmaceutical list means your pharmacy is authorised to provide NHS pharmaceutical services — dispensing NHS prescriptions and being paid by the NHS for doing so. The list is maintained by NHS England, with day-to-day administration through integrated care boards (ICBs). Inclusion in the pharmaceutical list is what is commonly referred to as having an NHS contract.
No. Inclusion in the pharmaceutical list is tightly controlled under the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013. An applicant must demonstrate that a new pharmacy would meet a current or future need, improve access or provide benefits that existing pharmacies do not already provide. A new pharmacy cannot open and dispense NHS prescriptions simply because a pharmacist wishes to open one.
A pharmaceutical needs assessment (PNA) is a document published by health and wellbeing boards that maps current pharmacy provision and identifies gaps in services. ICBs use PNAs as a key part of the evidence base when assessing new pharmacy applications. If the PNA for your area identifies a need, your application has a stronger prospect of success. If it does not, you will need to demonstrate unforeseen benefits or another approved basis for approval.
Essential services are the core pharmaceutical services that all NHS pharmacies must provide — dispensing, disposal of medicines, public health and others. Advanced services are services pharmacies can opt into if they meet the requirements, such as the Pharmacy First service. Directed services are locally commissioned by ICBs under Regulation 23. Market entry is a prerequisite for providing any of these services under an NHS contract.
The first step is an honest assessment of whether the proposed site has a realistic prospect of success — which depends on the local PNA, existing pharmacy provision and the application route available. TI Pharmacy Consultancy provides a free initial assessment of your proposed site before you commit to making an application.
Need professional advice?
The information above is for general awareness only. For advice specific to your situation, contact TI Pharmacy Consultancy for a free initial discussion.
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