Introduction

Clinical pathways consultations

Pharmacy First clinical pathways consultations are a routine part of clinical practice in community pharmacies across England, with over 2.75 million delivered between April 2025 and January 2026 (Community Pharmacy Contractual Framework 2026/27).

In each consultation, pharmacists assess the patient, screen for red flags and risk of deterioration, decide on treatment and provide safety-netting advice.

The clinical role of community pharmacy continues to grow: from September 2026, all newly qualified pharmacists will join the General Pharmaceutical Council (GPhC) register as independent prescribers; and from autumn 2026, a national NHS prescribing offer will be introduced as an extension of Pharmacy First and the Pharmacy Contraception Service, building on the Community Pharmacy Independent Prescribing Pathfinder Programme.

Professional assurance

As clinical responsibility grows, so does the value of pharmacists examining their own practice.

The professional assurance framework for delivering NHS community pharmacy clinical services sets out the importance of clinical audit as a tool to support scope of practice and competence of pharmacists and pharmacy technicians.

Clinical audit is an established quality improvement method in which care is measured against explicit criteria, and improvements are identified and put into practice.

Combined with structured reflection and discussion with a peer, it allows pharmacists to see how consistently their consultations meet defined standards, and to act on what they find — the same cycle of reflection and improvement that underpins the GPhC’s standards for pharmacy professionals and revalidation.

The 2026/27 Pharmacy Quality Scheme (PQS) therefore includes a clinical audit and peer discussion, supporting safe, high-quality care as pharmacy services become more clinically complex.

Clinical audit in 2026/27

Pharmacy contractors participating in the 2026/27 PQS, and choosing to undertake Domain 2: Professional Practice, must complete this clinical audit focusing on the quality of clinical pathways consultations delivered under the NHS Pharmacy First service.

As stated in the PQS Drug Tariff update, “Contractors must complete a clinical audit… to develop an action plan for improving practice.”

A pharmacist must also complete a peer discussion of approximately 1 to 2 hours with a ‘buddy’ pharmacist, focused on reviewing the findings of the audit and the action plan.

Preparation for audit

2 resources may help pharmacists prepare for the audit:

CPPE

The Centre for Pharmacy Postgraduate Education (CPPE) Documenting in patient clinical records e-learning programme covers the legal and regulatory requirements for patient clinical records and the structure expected when writing in them.

NHS England

NHS England’s High quality patient records guidance sets out what a high-quality record contains, including the presenting complaint, what was found on assessment, the plan and any safety-netting advice given, and the value of making the record as close to the time of the consultation as possible.

It is written for general practice, so it is the principles rather than the system detail that apply here.

Scope of audit

This audit examines the content of the patient consultation record. It asks whether the record sets out:

• why the patient was eligible for the clinical pathway
• what was found on assessment
• why the treatment decision was reached
• what the patient was advised to do if their condition did not improve.

This audit spans all 7 clinical pathways, so that pharmacists can measure their own practice against defined standards and act on what they find.

Not all of the information recorded during a consultation is shared with the patient’s general practice. Annex B of the NHS Pharmacy First service specification sets out the dataset that must be recorded and shared, and is worth reading alongside this audit.

Considering the difference between what is recorded and what is transmitted forms part of the reflection this audit supports.

Aims

• To assess the quality and completeness of the clinical records made for Pharmacy First clinical pathways consultations.
• To identify which elements of the consultation record are recorded least consistently.
• To measure how often a consultation record states that a safeguarding concern was identified.
• To reflect on what the record review shows, and to test that reflection through a structured peer discussion with a buddy pharmacist.
• To agree at least one specific change or improvement to practice – or a way to strengthen what already works well – and put it into effect.

Audit timeframe

Pharmacy contractors can choose a time to start the clinical audit from when the audit is published.

Each consultation record on the data collection and analysis form can be completed either:

• prospectively (at or shortly after a Pharmacy First clinical pathways consultation)
• retrospectively, using the pharmacy’s clinical records of any clinical pathways consultation undertaken between 1 April 2026 and 31 March 2027

Pharmacy contractors should choose an audit timeframe in 2026/27 that achieves the minimum audit sample with sufficient time to complete the audit (including sharing their anonymised data with NHS England and incorporating any learnings from the audit into future practice), as well as completion of the peer discussion by 31 March 2027.

Data must be collected for a minimum of 10 unique patients receiving Pharmacy First clinical pathways consultations undertaken between 1 April 2026 and 31 March 2027.

Audit sample

All patients referred to the pharmacy, or presenting to the pharmacy seeking advice, who pass the gateway point for any of the seven clinical pathways in Pharmacy First are included, whether the consultation was face-to-face or remote.

Consultations undertaken from 1 April 2026 onwards may be included in the audit retrospectively from the pharmacy’s clinical records.

1 audit is required for each pharmacy premises. More than 1 pharmacist may contribute consultation records to the audit sample, and the reflection and peer discussion may be completed jointly.

The audit sample is a minimum of 10 unique patients.

Audit standards

The audit has 2 standards. Both are assessed from Part A of the data collection and analysis form.

Standard 1 – Consultation record quality

Every patient consultation record contains the information which another healthcare professional would need to understand :

• why the patient was eligible for inclusion in the clinical pathway
• what was found on assessment of the patient
• why the treatment decision was reached
• what the patient was advised to do if their condition did not improve

Audit standard: 100% for each of the 7 record elements at data point A4.

Standard 2 – Safeguarding

The patient’s clinical record states where a safeguarding concern was identified during a Pharmacy First consultation.

This standard is reported as a rate rather than as a compliance target, because the proportion of patients presenting with safeguarding concerns is not known in advance (data point A3).

A record review can show how often a concern was recorded; it cannot show how often a concern was identified but not recorded.

Self-audit, reflection and peer discussion

Reviewing your own records and discussing them with a buddy pharmacist is the central purpose of this audit, rather than it being about fully meeting standards.

Part B of the form sets out the reflection prompts and the 4 stages of the peer discussion.

Part B is retained in the pharmacy and is not submitted to NHS England. It is your own reflection and the record of your peer discussion.

How to complete the audit

MYS allows you to start your data submission and then return to it later if necessary; for example, if you want to start adding data to MYS before the end of the audit period.

Where data collection has been started but not submitted, it will not be eligible for payment for the PQS.

When you successfully complete the data submission on MYS, you will receive a data collection submission confirmation email as evidence that the submission was successful.

Retain a copy of this email. You may need to provide this to NHS England to demonstrate that you successfully completed the data submission.

If you don’t receive the data submission confirmation email within an hour of submitting your declaration:

• check your junk email folder (the email will be from noreply@online1.snapsurveys.com)
• immediately send an email to the NHS Business Services Authority (NHSBSA) provider assurance team (pharmacysupport@nhsbsa.nhs.uk) to make them aware of the issue if you don’t find the email

This audit differs from previous years. To meet the PQS audit requirements you must complete the audit on a minimum of 10 unique patients receiving Pharmacy First clinical pathways consultations undertaken between 1 April 2026 and 31 March 2027, and submit that data on the MYS data collection tool.

There is no alternative route for pharmacies that review fewer than 10 unique patients.

The audit sample is defined by the date each consultation was undertaken, not by the date it was claimed for. A clinical pathways consultation undertaken on or before 31 March 2027 therefore counts towards the minimum of 10 unique patients even if the claim for it is submitted after that date, including through the late payment claims process.

If your pharmacy delivers fewer than 10 unique patients receiving clinical pathways consultations across 2026/27, you will not be able to meet the requirements of this audit and so will not be able to claim for Domain 2 – Professional Practice.

All data from the audit must be successfully submitted to the MYS data collection tool before 11.59pm on Wednesday 31 March 2027.

Key resources

Download the tool you’ll need to carry out and report on the audit.

The data collection and analysis form combines:

• the patient-by-patient record review
• the audit standards
• your reflection and peer discussion
• the questions that are submitted to NHS England

Download the data collection and analysis form via the NHS England website.

Publication reference: PRN02557_i