Brexit: NHS England issues additional guidance for primary care contractors

Brexit: NHS England issues additional guidance for primary care contractors

April 10, 2019

NHS England has today (10th April) published a letter to support primary care contractors in preparing for the possibility of a no-deal Brexit.

The letter is intended to be a companion to the Department of Health and Social Care’s (DHSC) Operational Readiness Guidance issued in December 2018. Written by EU Exit Strategic Commander Professor Keith Willett and Director of Primary Care Commissioning Dr David Geddes, this advice has been compiled for all primary care contractors.

You can view the letter here, but we have summarised the information relevant to community pharmacy teams below.

Medicine supply issues

Community pharmacy contractors do not need to change their behaviour in terms of ordering stocks or engaging with suppliers, as this work has been undertaken nationally. They are advised not to stockpile medicines, medical devices or clinical consumables, and to reassure patients that they do not need to stockpile either.

For some products from the EU, such as medical devices and clinical consumables, contractors are advised to plan for lead times of around three days or longer.

Public Health England (PHE) and DHSC are working closely with vaccine suppliers (such as those manufacturing vaccines for the adult influenza vaccination programme) to ensure there are sufficient stockpiles of vaccines in the event of supply disruption in the UK.

Information for pharmacy teams to share with patients concerned about this can be found here.

Raising concerns

DHSC already works very closely with manufacturers and wholesalers to manage supply disruption which may or may not be related to Brexit.

In the first instance, contractors are advised to resolve issues through the usual channels: report medicine supply issues to PSNC and notify your local NHS England team if you experience significant service delivery problems. Community pharmacy teams already work hard to source medicines for patients and, where a medicine is not available, are advised to liaise with the prescriber to consider a suitable alternative.

PSNC’s Community Pharmacy Brexit Forum, along with pharmacy and LPC reports, the NHS Commercial Medicines Unit and patient groups, are helping to inform DHSC’s work and these ‘business as usual’ arrangements will be supplemented by data gathered by the Regional Medicines EU Exit Panels.

Serious Shortage Protocols

The letter also provides some clarification on when Serious Shortage Protocols (SSPs):

  • May be used when other measures have been exhausted or are likely to be ineffective;
  • Enable community pharmacists to supply in line with a protocol for a specific medicine, without going back to the prescriber to get the prescription changed;
  • Only introduced if the clinicians advising Ministers think it is appropriate, and after discussion with the manufacturer and/or marketing authorisation holder;
  • Community pharmacists could supply either an alternative quantity, strength, pharmaceutical form or medicine as described in the protocol;
  • Each protocol would clear set out what action can be taken, under what circumstance, for which patients, and during what time period; and
  • Pharmacists will still need to use their professional judgement on whether to make a supply under the protocol.

Data processing

The transfer of personal data outside of the UK should not be affected by a no-deal scenario, but contractors are advised to review their use of any systems which hold data abroad. Contractors may have already undertaken this process as part of their work towards complying with the General Data Protection Regulation (GDPR) and the Data Security and Protection (IG) Toolkit.

Further guidance on this is available in PSNC Briefing 005/19: Key actions for pharmacy contractors to prepare for a no-deal exit from the EU.


Contractors are reminded to make any staff who are EU citizens aware of the EU Settlement Scheme.


For the latest EU exit updates and guidance, please visit our Brexit hub.

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