PQS Declaration and the PCN Business Continuity Domain

PQS Declaration and the PCN Business Continuity Domain

February 11, 2021

PSNC is continuing to receive some queries regarding interpretation of the requirements to meet Domain 5, the Primary Care Network (PCN) Business continuity element of the Pharmacy Quality Scheme (PQS) 2020/21 Part 2.

PSNC previously published a series of additional FAQs to assist contractors with these queries on interpretation in response to the announced flexible timing agreed with NHS England and NHS Improvement (NHSE&I) and the Department of Health and Social Care (DHSC).

Guidance, including PSNC Briefings for contractors and for Pharmacy PCN Leads issued in October 2020, clearly highlighted in relation to Domain 5 that participation in a facilitated discussion between pharmacy contractors chaired by the Pharmacy PCN Lead was a key requirement.

The guidance explained that the contractor discussion was to be a meeting of contractors aligned to the PCN. The purpose of the meeting was to understand the high-level business continuity plans (BCP) of participating contractors and that would not be possible via an email or contractor survey alone.

An email chain or WhatsApp exchange does not constitute a discussion for the purposes of this domain, nor does it allow for the intention, which is to share, learn and therefore develop a collated document that further supports BCPs more fully and considers how best to support local requirements in the event of a temporary pharmacy or general practice closure, to be achieved. NHSE&I are clear that only a discussion in a meeting of contractors and the Lead will be considered to meet the requirements. This meeting can occur virtually by teleconference or using Zoom, Microsoft Teams or other similar systems.

As a result of the flexible timing announced, NHSE&I have confirmed that where the activity required to meet the criteria of the Business Continuity domain has not yet commenced or has started, but not concluded, the collation of the evidence to demonstrate that contractors and Leads are compliant with the requirements can be extended until 30th June 2021 provided the contractor discussion has been undertaken before the end of the declaration period. The contractors participating in this work must confirm that they will actively participate in any additional work required to meet the requirements of the domain after their declaration has been made. The Pharmacy PCN Lead’s PQS declaration will include the ODS codes of the participating contractors; this cannot be amended once it has been submitted.

For both of the PCN Domains, our guidance to contractors and PCN Leads was that where the Pharmacy PCN Lead has made reasonable attempts to contact contractors three times, by two different methods, and the contractor has either not responded or not returned the requested information, then the Pharmacy PCN Lead can assume the contractor does not want to be involved in these domains. In those circumstances, the activity would therefore proceed without the contractors that have not responded.

A one-to-one discussion with the Pharmacy PCN Lead would only be appropriate if a contractor could not make the planned meeting and they were following up promptly after the event.

Where activity has been completed by the Lead and shared with the PCN, the LPC, NHSE&I and contractors aligned to the PCN, any contractors who did not participate or follow up before this point will not be able to declare as having met the domain. It is the responsibility of the contractor who was unable to attend the planned event to follow up with the Lead promptly after the planned event.

In line with the requirements of the domain, any one-to-one follow up with the Pharmacy PCN Lead by a contractor who missed the planned event must be as a verbal discussion; it cannot be an email exchange.

Where a contractor discussion as not yet occurred within a PCN group, there is still time to conduct this before the PQS Part 2 declaration closes on 1st March 2021. If a Lead has not met the full requirements of the domain, in line with the guidance and subject to the flexible timing arrangements detailed above, the Lead and the contractors aligned to that PCN, cannot declare that they have met the criteria for the domain.

Read the additional FAQs

Read the full PQS Part 2 requirements

Read the completing your declaration guidance


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