Contractors have expressed concerns that some pharmacies are signing up patients to EPS without consent. It is important to follow the key principles set below in order to set up patient nominations. Any breach of the legislation can lead to an investigation by NHS England. EPS tracker can now show the nominated destination of a specific prescription and where the nomination has been changed.
- No inducements can be offered for patients to nominate your pharmacy for EPS R2. This means that money, gifts, points and discounts (along with anything else that may be classed as an inducement) must not be offered or given. The LPC is aware that some contractors do currently offer inducements for signing up to Prescription Collection Services. This must not happen for EPS 2 nominations.
- Consent does not necessarily have to be in writing, however pharmacies must have ‘local accountable auditable processes’ for obtaining explicit consent. Consent cannot be assumed to have been given just because a patient is signed up to your PCS service (even if your PCS leaflets make reference to EPS). As part of this consent process there is a range of information that must be given to the patients.
- If a GP practice already has a textual record of which pharmacy a patient’s paper prescriptions are collected by, the practice cannot assume that the patient has consented to EPS nomination at that pharmacy. Of course if the pharmacy has already informed the patient adequately and gained their consent for EPS nomination, then the pharmacy would add the EPS nomination via the pharmacy system, and the EPS nomination will then be visible in the patient record at the practice when they go live with EPS and they will be able to send prescriptions electronically for that patient. Pharmacies should normally be discussing EPS with their PCS patients first and recording these nominations once they have the patient consent. However, of course it is patient choice and some patients may not choose to nominate for EPS.
- If a GP practice has only the textual record of pharmacy for their paper prescriptions (and there is no nomination in place) for a patient then the patient’s prescriptions would continue to be printed until either the practice or a pharmacy discuss EPS with the patient and they choose to nominate a pharmacy for EPS – only then can the nomination be added to enable the prescriptions to be sent electronically.
- Please refer to the link here about the HSCIC nomination guidance on EPS prescriptions.
- Please refer to the PSNC link available here on nomination guidance for EPS. Please refer to the link here for PSNC information tips on the nomination process and how to capture patient nomination information.
- Please refer to the link here for PSNC guidance on the direction of prescriptions.
If a patient is unhappy with their experience of nomination, they can complain to the pharmacy, dispensing appliance contractor (DAC) or GP practice. The patient can also complain to NHS England or their local NHS Clinical Commissioning Group (CCG) if your complaint cannot be resolved.