Introduction

From summer 2026, all pharmacists that have graduated from an MPharm Pharmacy course accredited against the 2021 General Pharmaceutical Council (GPhC) standards for the Initial Education and Training of pharmacists, qualify as independent prescribers. This enables pharmacists to use their prescribing capabilities in the expansion of clinical services within primary care. In addition, pharmacy technicians have been added to the list of healthcare professionals who can supply and/or administer medicines via a Patient Group Direction (PGD) following amendments to the Human Medicines Regulation 2012 in June 2024.

Both pharmacists and pharmacy technicians are regulated across England, Scotland and Wales by the GPhC, with a requirement to revalidate each year via completion of continuing professional development (CPD) entries, peer discussion and a reflective account. The GPhC maintains registers for pharmacists, pharmacy technicians and pharmacy premises to provide assurance to the public, that the individual pharmacist, pharmacy technician or premises meet the necessary requirements for registration.

The primary function of the GPhC is to protect the safety and wellbeing of patients and the public and uphold the standards across the pharmacy professions, under the Pharmacy Order 2010. As with other healthcare regulators, the remit is fitness to practise. The GPhC can investigate concerns about fitness to practise and issue relevant sanctions, where necessary, to protect patients and the public.

Fitness to practise refers to the standards set by the relevant healthcare professionals’ regulator, in this case the GPhC. The standards outline the minimum requirements for the professional group including competence, health and character. The GPhC states that “being fit to practise means a pharmacy professional has the skills, knowledge, health and character to do their job safely and effectively. They must also act professionally and meet the principles of good practice set out in our standards and guidance”.

For the NHS in England GPs, dentists and optometrists have additional professional governance arrangements in place through an NHS performers list. The purpose of the NHS performers list is to ensure primary care clinicians achieve fitness for purpose, i.e.  are qualified and competent to provide safe and effective care for the services they deliver.

Fitness for purpose refers to the professional’s ability to perform services in accordance with the requirements of the contract and in accordance with local standards and policies. Fitness for purpose therefore relates to the individual being able to demonstrate they are safe and can work independently within the relevant setting. A professional may be deemed fit to practise whilst simultaneously not being considered fit for purpose for the contract and/or setting in question.

There is no performers list for pharmacists and pharmacy technicians in England, working in any sector. This professional framework sets out guidance that is expected of pharmacists and pharmacy technicians to ensure they are fit for purpose to deliver clinical pharmacy services including the use of patient group directions and independent prescribing where applicable.

1. Scope of the framework

This framework outlines the best practice guidance for all pharmacists and pharmacy technicians involved in the delivery of NHS commissioned community pharmacy clinical services within the primary care setting in England. NHS commissioned community pharmacy clinical services include all advanced services within the Community Pharmacy Contractual Framework (CPCF), the Discharge Medicines Service (DMS) and enhanced services (nationally and locally commissioned).

This framework aims to close the gap on professional assurance linked to the quality of services provided by pharmacists and pharmacy technicians and outlines the responsibilities of the following:

• commissioners of NHS community pharmacy clinical services
• employers of pharmacists and pharmacy technicians delivering NHS community pharmacy clinical services
• pharmacists and pharmacy technicians delivering NHS community pharmacy clinical services (applies to both permanent and locum staff)

This framework relates to the delivery of NHS commissioned clinical pharmacy services that are primarily commissioned through Integrated Care Boards (ICBs). However, the principles set out within this framework may be equally applicable to the provision of clinical pharmacy services commissioned by other organisations, such as local authorities and private services.

1.1 What is professional assurance?

Professional assurance comprises the processes and systems that enable patients and the public to have confidence in the care they are receiving. This includes assuring that pharmacists and pharmacy technicians are consistently working to safe and effective standards, providing high quality care and demonstrating the required professional behaviours.

Professional assurance operates across many layers, including:

• commissioners
• the regulator
• professional leadership bodies
• employers
• individual professional (pharmacist or pharmacy technician)

The GPhC have published The layers that shape professional practice in pharmacy, which provides detailed examples of how the various layers interlink and can be used for further support.

2. Professional assurance responsibilities

2.1 The role of NHS commissioners

The role of NHS commissioners is to ensure that all NHS commissioned services provided to patients are safe, cost effective and provide equity of care. The specific role of ICBs within strategic commissioning is outlined within the NHS strategic commissioning framework.

NHS commissioners of clinical pharmacy services are expected to use this framework to support best practice as part of their wider responsibility for assuring delivery of clinical services. They should use it alongside relevant national policy and guidance, such as guidance for commissioning community pharmacy prescribing-based services.

2.2 The role of regulation

The role of regulation is to protect, promote and maintain the health, safety and well-being of patients and the public by setting regulatory standards and providing registration, inspection and enforcement functions. The GPhC provides these functions under the Pharmacy Order 2010 to ensure minimum standards of safe practice in pharmacy. They are the independent statutory regulator in Great Britain for pharmacists, pharmacy technicians and pharmacy premises. They set standards for both pharmacists and pharmacy technicians and pharmacy premises, and failure to comply with these standards may result in enforcement action including fitness to practise sanctions.

2.3 The role of pharmacy professional leadership bodies

Pharmacy professional leadership bodies play a vital role in shaping the future of the pharmacy profession by setting professional practice standards, guiding practice, and advocating for pharmacists and pharmacy technicians. This supports pharmacists and pharmacy technicians to comply with regulations, aiming for aspirational standards of excellence.

2.4 The role of community pharmacy employers and contractors

2.4.1 Guidance applicable to all pharmacists and pharmacy technicians

The employer of pharmacists and pharmacy technicians involved in the delivery of NHS community pharmacy clinical services should ensure that each individual:

• holds current registration on the appropriate GPhC register with no sanctions that affect their ability to deliver the service for which they have been employed. If an individual has any conditions imposed on their practice that may impact service delivery or patient safety, employers are recommended to seek appropriate advice to mitigate risk
• always operates within their individual competence and scope of practice when delivering NHS community pharmacy clinical services
• has evidence of an enhanced Disclosure and Barring Service (DBS) check to support the safe provision of clinical services, with a certificate issued within the last three years. The DBS check tool can be used to find out what type of check is appropriate for an employee.
• has completed the relevant employment checks and is suitably skilled and qualified for the role they are undertaking. This applies to both permanent and locum staff. Employers using locum staff should consider how to seek assurance that relevant employment checks have been completed
• holds appropriate professional indemnity arrangements for activity related to the relevant clinical pharmacy service, whether through employer cover, professional body membership, and/or individual arrangements, in line with the GPhC indemnity requirements, and that any exclusions to that cover have been considered
• has read and adheres to Standard Operating Procedures (SOPs), service specifications and service level agreements (SLAs) covering activities relevant to their role and scope of practice within the community pharmacy setting

Before practising under a PGD or similar authority to supply medicines, such as vaccine group direction (VGD), employers should ensure that pharmacists, pharmacy technicians and any other registered healthcare professionals authorised to work under PGDs or VGDs:

• have undertaken the necessary training and CPD
• have signed the appropriate documentation
• are using a copy of the most recent and in date final signed version
• have read and understand the context of the PGD or VGD and service specification
• understand their legal and professional responsibilities and liabilities before delivering services

 2.4.2 Additional guidance applicable to independent prescribing pharmacists

Employers must ensure that pharmacists involved in prescribing:

• are qualified as independent prescribers, as annotated on the GPhC registers.
• complete a declaration of fitness for purpose, including their prescribing scope of practice, and submit this to the employer for recording. This should be updated annually, or more frequently if their prescribing scope changes or if the pharmacist is no longer involved in prescribing.
• hold appropriate professional indemnity arrangements for prescribing activity, whether through employer cover, professional body membership, and/or individual arrangements, in line with the GPhC indemnity requirements, and that any exclusions to that cover have been considered.
• are listed in the NHS prescriber details dataset that provides information on prescribers, including prescriber code, name, type and details of the employing organisations. This dataset is published monthly by the NHS Business Services Authority (NHSBSA).

2.4.3 Additional guidance applicable to pharmacy technicians

Where a pharmacy technician is to deliver a clinical service using a PGD, the employer must have relevant standard operating procedures (SOPs) in place covering how the responsible pharmacist will oversee or authorise associated activities connected to the supply of medicines, such as labelling. The SOP should define the roles and responsibilities of both the responsible pharmacist and the pharmacy technician to meet legal requirements and enable the pharmacy technician to make autonomous supplies of medicine under the PGD.

2.4.4 General requirements for employers

Employers should ensure that:

• all records of checks completed to assess fitness for purpose (professional registration, professional indemnity, scope of practice declarations and authorisations) are kept for at least 5 years and available to commissioners on request. Employers should consider how this will apply to locum staff delivering NHS commissioned community pharmacy clinical services
• DBS certificates should be managed as per DBS guidance
• the Superintendent Pharmacist, where one is required, or pharmacy owner where one is not, is responsible for ensuring that only fully competent, qualified and trained healthcare professionals are authorised to use the most recently approved version of a PGD or VGD
• clinical risk assessments are conducted before any new clinical services are commenced, including when pharmacists and pharmacy technicians are expanding their scope of practice
• robust and appropriate induction support is provided for all pharmacists and pharmacy technicians new to the business or to delivering clinical services
• pharmacists and pharmacy technicians are not asked to expand their scope of practice (including prescribing) without appropriate development support and clinical risk-assessment
• prescribing pharmacists have regular access to a named clinical supervisor or prescribing mentor, for example, one supervision session per month
• time is allocated regularly, and at least annually, to complete a review of prescribing practice (prescribing appraisal) between the pharmacist prescriber and their clinical supervisor
• they support access to communities of practice and/or peer networks where they currently exist for pharmacists and pharmacy technicians delivering clinical services
• structured development plans are put in place for pharmacists new to prescribing, with reference to relevant professional curricula and frameworks, including mentorship and appropriate induction
• an appraisal is scheduled at least annually for all pharmacists and pharmacy technicians to discuss performance and development opportunities.  This could be recorded in line with the GPhC inspection decision making framework

2.5. The role of the individual pharmacist and pharmacy technician

Any pharmacists and pharmacy technicians involved in the delivery of NHS commissioned community pharmacy clinical services should ensure that they:

• maintain their registration with the GPhC and fulfil the GPhC revalidation requirements
• follow the GPhC standards for pharmacy professionals
• engage in regular CPD relevant to the clinical services they deliver
• engage in regular peer discussions, (at least annually, to support reflection, learning and clinical confidence
• inform their employer of any concerns which may impact their ability to work within the designated healthcare setting
• adopt the GPhC strategic approach to scope of practice which emphasises a pharmacist and pharmacy technician’s professional obligation to self-regulate
• ensure any entries to patient clinical records are accurate, clear, appropriate and timely
• ensure patient confidentiality is maintained when managing patient records, including secure storage, transportation and destruction, where appropriate         

2.5.1 Additional guidance applicable to independent prescribing pharmacists

Any pharmacists involved in the provision of prescribing within NHS commissioned community pharmacy clinical services should ensure that they:

• follow GPhC guidance for pharmacist prescribers and the GPhC advice for newly qualified prescribing pharmacists
• undertake CPD relevant to their prescribing role and the relevant commissioned prescribing-based service, which may include, therapeutic updates, structured practice-based discussions and peer discussion
• self-assess their prescribing competence annually to identify areas for development and ensure fitness for purpose – the Royal College of Pharmacy Prescribing Competency Framework can be used to support this
• put in place a robust development plan when considering expanding their prescribing scope of practice – the Royal College of Pharmacy Expanding Prescribing Scope of Practice can be used to support with this
• maintain a professional portfolio, in digital or paper format, as a basis for reviewing prescribing practice with clinical supervisors and supporting individual development. This is not a requirement mandated by the GPhC, though entries could be used to support GPhC revalidation
• use their professional portfolio to document professional development, which may include evidence of clinical decision making (including decisions not to prescribe), peer discussions, prescribing feedback, clinical observations, reflections, prescribing errors, clinical logs, audits and CPD
• complete a prescribing appraisal at least annually with their clinical supervisor, documenting areas for improvement within their professional portfolio and considering whether additional clinical supervision sessions are required if a change in the service is planned

Clinical supervision refers to regular support from a named senior or experienced clinician or practitioner to promote high clinical standards and develop professional expertise. Although not specific to the community pharmacy setting, NHS England has published Supervision guidance for primary care network multidisciplinary teams which can be used as guide to clinical supervision. Core supervision training is also available via e-Learning for Health.

2.5.2 Additional guidance applicable to pharmacy technicians

Any pharmacy technicians involved in the delivery of community pharmacy clinical services should ensure that they:

• have read and understood the appropriate service specifications and PGDs or VGDs, and have signed the associated authorisation sheets
• have completed any service specific training, as set out within the service specification
• have been declared competent to deliver each service by their employer, in line with the relevant service specification and associated clinical pathway     

Pharmacy technicians delivering PGDs or VGDs are encouraged to complete the e-Learning for Health patient group directions programme, CPPE Pharmacy technicians: using patient group directions in practice e-learning programme and review the dedicated CPPE PGD training guide and resources and Specialist Pharmacy Service resources.

3. Managing concerns

The GPhC remains the key point of contact for patients and the public for raising concerns regarding individual pharmacists and pharmacy technicians, and registered pharmacy premises.

Reports can be made online via the GPhC webpage. The GPhC, as the regulator, can restrict the practice of pharmacists and pharmacy technicians and issue appropriate enforcement action, which could include removal from the relevant register. Further information can be found on the GPhC webpage.

The GPhC have published acceptance criteria for how concerns will be assessed and whether the concern will be referred for investigation.

Community pharmacy employers and commissioning bodies can access NHS Resolution Practitioner Performance Advice to receive independent, impartial advice regarding the management of performance concerns.

3.1 Employer responsibilities

If an employer has a concern about the performance of a pharmacist or pharmacy technician, they should consider using the support mechanisms in place locally. Depending on the nature of the concerns, this could include:

• Human Resources (HR) advice and relevant procedures for managing performance issues
• Occupational Health
• wellbeing support
• 1:1 support

Employers and line managers should be aware that many factors may contribute towards performance issues, and the wellbeing of the individual should be considered throughout any performance management process, with appropriate wellbeing support offered.

Employers should follow the principles set out within the NHS Just and learning culture charter  when managing concerns or when things go wrong, to support a consistent approach to incidents and errors.

Employers should consider proportionate remediation plans. These may include temporarily limiting an individual’s clinical activities within the organisation for a defined period, subject to regular review to support a safe return to practice, and in line with local HR processes.

If performance issues cannot be managed locally, or where this is not feasible or appropriate, employers should refer into the clinical leadership team within their ICB commissioning team, to seek advice on the next steps. NHS regional professional standards teams can also offer informal support and remediation for complex cases.

Where an employer believes that a prescribing pharmacist poses a significant risk of harm to patients or the public, they should consider requesting that their ICB remove or suspend the individual from the NHS prescriber details dataset, managed by NHSBSA.

Employers can also seek support from relevant indemnifiers, representative bodies or other relevant support organisations, including legal support.

Where an employer of a foundation trainee pharmacist raises a serious concern with the GPhC about the trainee, they should also notify the Statutory Education Body with responsibility for the Foundation Trainee Pharmacist Programme.

Where an employer of a pre-registration pharmacy technician raises a serious concern with the GPhC about the pre-registration pharmacy technician, they should notify the commissioning organisation responsible for that trainee’s post.

3.2 Support for pharmacists and pharmacy technicians

Pharmacists and pharmacy technicians can seek support from relevant union bodies, their professional leadership body, employer provision, e.g. third party arrangements or in-house where available or other relevant support organisations ( for example, Pharmacist Support).

3.3 NHS Resolution support

NHS resolution provides impartial advice to healthcare organisations to effectively manage and resolve concerns raised by doctors, dentists and pharmacists. They also provide resources to support employers and individuals with early resolution of concerns.

They can offer interventions including clinical performance assessment, behavioural assessment and action planning as means of supporting performance management processes and remediation and aiding the identification of concerns.

They have produced a principles and framework for healthcare organisations managing performance concerns that promotes fairness and proportionality in decision making.

They issue Healthcare Professional Alert Notices (HPANs) to inform NHS bodies and others if a healthcare professional poses significant harm to patients, public or staff. You can check if an individual is subject to a HPAN by using the NHS Resolution Performer and Healthcare Professional Check.

NHS organisations and other bodies providing services to the NHS that wish to request a HPAN should notify NHS Resolution at nhsr.hpan@nhs.net using the downloadable HPAN request form. Requests must be made by an Executive Board member or their authorised deputy.

4. Resources

4.1 Employer checklist for pharmacists and pharmacy technicians

* For a newly qualified pharmacist or pharmacy technician, one reference should be provided by their foundation training supervisor, Designated Pharmacist Prescriber (DPP) or Designated Medical Prescriber (DMP) supervisor.

Where a community pharmacist has not worked for some time, or has worked as a sole pharmacist or in a family business where an independent reference is not available or could present a conflict of interest, the employer may conduct a risk assessment and consider an initial period of employment, for example, three months,  as part of their employment terms. At the end of this period, the employer can reassess and decide on continued employment as appropriate. This process could be documented as an audit trail.

4.2 CPPE training resources

Risk assessment and patient safety

• Risk management guide
• Patient safety toolkit e-learning

Self-assessment, reflection and declarations of scope of practice

• Extending the scope of your prescribing practice programme
• Reflection e-lecture
• Reflective practice online workshop

Practising under a PGD and service specific training

• PGDs (Patient Group Directions): training guide and resources
• Pharmacy technicians: using patient group directions in practice e-learning
• PGDs: Empowering pharmacy technicians to provide services workshop
• Providing NHS and public health pharmacy services

Clinical assessment of patients

• Consultation skills: face-to-face and remote learning gateway
• Clinical history-taking: what a good consultation looks like e-learning
• Prescribing learning gateway
• Assess the patient: Prescribing

Record keeping requirements

• Documenting in patient clinical records e-learning

Publication reference: PRN02466