Expert guide to setting up and running a NHS distance selling pharmacy (guest blog)

 

Purchasing an existing pharmacy remains an expensive option for many people wanting to own a pharmacy business. Despite pressures on pharmacy, goodwill values remain high and bank loans can prove challenging to obtain. Internet Pharmacies or ‘Distance Selling Pharmacies’ could provide another option to those wishing to own their own pharmacy business or an existing group wishing to make use of a Hub and Spoke/Central Dispensing model.

To set up a new traditional style NHS brick-and-mortar pharmacy, you need to prove that there is a pharmaceutical need (contact us if you want more advice on this). New contracts under pharmaceutical need are becoming increasingly difficult to obtain. Distance selling pharmacies however, remain exempt from any kind of needs assessment.

The aim of this guide is to give you some knowledge of the steps involved in the application process, what kind of things to keep in mind – such as premises, what entity to apply under and other organisations that will need to be involved (such as the Local Council and General Pharmaceutical Council – GPhC). The guide also touches on setting up your pharmacy once you have approval and some of the business models that have been tried.

As always, if you have any questions just get in touch!

Who is Making the Application?

There are a number of entities that can be granted an NHS licence. These include a pharmacist sole trader, a partnership of pharmacists and a ‘body corporate’ (e.g. Limited Company or Limited Liability Partnership- LLP).

Body Corporate

You can decide whichever works for you but we would always recommend the Limited Company or LLP route. If you plan to sell the contract or pharmacy at a later stage it may also be worthwhile applying with a fresh company that has no other assets/trading.

When applying as a Body Corporate, you will also need to nominate a Superintendent. If you have not used the word ‘Chemist’ or similar in either the company name or trading name, the superintendent does not have to be a director. The superintendent should be familiar with GPhC standards (http://bit.ly/1T6wM0J)

Where are you going to trade?

You do not have to have a lease/freehold in place before the application. We recommend finding an industrial park with a variety of units available. However, there is no hard and fast rule on what type of premises you must have. Just bear the following in mind:

  • Distance selling pharmacy premises must be approved by the GPhC before any trading can commence.
  • The site will need approval from the council – be sure to specify that you will NOT be a retail premises
  • The site should not be next door or in the vicinity of any other Primary Care setting (GP Surgery, another pharmacy). There are exceptions to the rule but such an application will need additional explanation and assurances

Who do I Apply to?

This used to be one of the most challenging steps in the process as NHS Primary Care Teams (PCTs) became NHS Area Teams and Clinical Commissioning Groups (CCGs). Now you can normally find the right person to contact through the NHS England website http://bit.ly/1OjVgfw

Ensure you have a name, email address and contact number. You will need to liaise with this person regularly to find out what stage your application has reached. If you are not chasing, expect your application to be sitting in a pile of mounting paperwork on someone’s desk!

How do I Apply?

Initial Application

Remember, you are not applying to fulfil a pharmaceutical need. Your application must show how you will provide and fulfil all essential services nationally. Your application must also give sufficient assurance that no-one will receive any face to face essential service on or near the premises.

We now advise submitting a set of Standard Operating Procedures (SOPs) along with the application. Both the application and the SOPs must describe how you will provide NHS Pharmacy Essential Services to anyone in the country without face to face interaction at or near the pharmacy premises.

You can view a sample set of SOPs HERE or by entering http://bit.ly/1smypLu into any browser.

Fitness to Practice

All applicants will need to provide assurance that they are fit to provide a pharmaceutical service. This includes completing a questionnaire and providing suitable referees. In the case of Body Corporates (Ltd Companies and LLP’s), all directors will need to complete a form. Additional assurances are required from any directors that are also pharmacists.

Objections

It is quite normal to receive objections from interested parties. Objections are normally raised by the Local Pharmaceutical Committee and local pharmacy providers. These will be relayed to you by NHS England and you will be given a short period of time to respond. It is important that objections are responded to robustly. Make sure that all points raised in the objections are responded to individually.

Appeal

If your application is rejected, you will be given the opportunity to appeal to the Secretary of State. Appeals must relate to the procedure followed by NHS England and NOT changes to or the perceived strength of your application.

Application Accepted! What next?

Thirty days for appeal

In the first instant, any interested parties will be given thirty days to appeal the decision to the Secretary of State. In our experience this is very rare and only attempted if there is a suggestion of malpractice by the NHS body during the application process.

Notifying NHS England

You will then be given six months within which you must be ready to trade. At least two weeks before this date you must provide NHS England with a variety of information such as trading name, opening times, superintendent details, web address and other particulars.

GPhC Registration

Before you can open you must be given approval for opening by the GPhC. You can get more details on this process by visiting http://bit.ly/1Zw5SOe

Fill out the form and send it to the GPhC electronically where possible. We recommend contacting the GPhC at the earliest opportunity. Find out who the inspector is for your area. Get in touch with the inspector and arrange a date for any inspections and final registration dates

Be sure to have a full set of Standard Operating Procedures, a CD Cabinet, a fridge and a working tap/sink BEFORE any inspection is arranged

Remember – GPhC Registration MUST be completed before you can trade.

Notifying the Council

Before you can open, you must have approval from the council. In fact, the GPhC application also asks for evidence that the council has granted permission for you to open a Distance Selling Pharmacy on the premises.

When you first mention ‘pharmacy’ to the council, they will automatically assume you are talking about a retail premises. It is important to ensure they understand the type of business and activities that will be taking place from the premises.

Setting up

There are still a number of steps to consider to get yourself up and running. Some of these include (in no particular order and not exhaustive):

  • Fit out of the premises
  • Accountant/Legal
  • Wholesaler accounts
  • Prescription Medication Record (PMR) System and Hardware
  • Broadband – can be arranged by the PMR supplier
  • Telephone/Fax
  • Waste collection
    • T28 waste exemption
    • Yellow bins
  • Security
    • CCTV
    • Alarms
    • Shutters
  • Software and Hardware
    • CRM Software
    • Office Software (Google Apps, Office 365)
    • Email and other messaging
    • NHS Mail
  • Website
    • Web presence (including NHS Choices)
    • Web services
    • Messaging System
  • Insurance
  • Pharmacy Fridge and record
  • CD Cabinet
  • Utilities
  • Marketing
  • Signage
  • PGD’s and other services
  • Care home services
  • Kettle
    • Coffee, black, no sugar 😉

We can provide help and guidance on any of the above – apart from the kettle, you’re on your own there!

Running the Business

Getting NHS Prescriptions into a newly opened Internet Pharmacy can be extremely challenging. Strategies that people have tried in the past include:

  • Advertising at various surgeries
  • Setting up collection points
  • Postal and web marketing campaigns in various localities
  • Winning care home and nursing home contracts
  • Setting up a hub-and-spoke centralised dispensing unit

You should start thinking about this stage before the application is made. We always recommend having a range of revenue streams including revenue that does not rely on the NHS. Examples of non-NHS revenue may include:

  • Local Authority based Services
  • Wholesaling
  • Private Medical Services
  • Cosmetic Services
  • Alternative Therapy Clinics

Our team has experienced specialists in many of these fields. Contact us if you need any help.

Get Expert Help

Whatever you decide to do, it is always worth considering advice from someone who has done it before and knows the pitfalls that you can come across.

With a wealth of expertise and experience, we are always here to help and guide you along the way – just get in touch

Written

Asim Mirza

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