PQS: Preparing to declare – additional FAQs

PQS: Preparing to declare – additional FAQs

January 27, 2021

As the declaration window for the Pharmacy Quality Scheme (PQS) 2020/21 Part 2 approaches, PSNC has received several related questions to the announced flexible timing agreed with NHS England and NHS Improvement (NHSE&I) and the Department of Health and Social Care (DHSC).

PSNC has confirmed some additional questions and answers with NHSE&I that will assist contractors in preparing to make their declarations.


Background and general

Q. Will all elements of PQS be extended until 30th June 2021?
No. The PQS Part 2 2020/21 declaration will still take place as planned in February 2021 however, contractors will have until 30th June 2021 to complete any elements of the scheme in Domain 1 – Infection Prevention & Control and Antimicrobial Stewardship, Domain 2 – Prevention and Domain 3 – Risk management they have declared as having met and collate the evidence to demonstrate that they are compliant with the requirements

Domain 4 – Primary Care Network (PCN) – Prevention aimed to reduce the risk of harm resulting from contracting the influenza virus for all patients aged 65 and over and as a result, to reduce pressure on the NHS during winter. The domain incentivised collaboration of community pharmacy and general practice (through the PQS and the Impact and Investment Fund (IIF) respectively), to work together to increase the number of eligible people vaccinated.

The domain required engagement with the Pharmacy PCN Lead to confirm involvement in increasing the uptake of flu vaccines in the over 65s. Leads could then confirm to the PCN how community pharmacies in the PCN would collaborate to increase vaccine uptake during the data capture period between 1st September 2020 to 31st January 2021. Engagement with the PCN needed to occur within the data capture period to be considered as collaboration towards a shared target. Therefore, this domain cannot be extended beyond this point, as activity should have already largely finished.

Only contractors that engaged with the Pharmacy PCN Lead to confirm they would be involved in increasing the uptake of flu vaccination to patients aged 65 by provision of vaccinations and where subsequently the Pharmacy PCN Lead engaged with the PCN Clinical Director or appointed representative to share these plans, can seek to declare against this domain.

Domain 5 – Primary Care Network – Business continuity requires participation in a contractor discussion and for the Lead to collate the information to share with all contractors within the PCN, the PCN, the Local Pharmaceutical Committee (LPC) and NHS England and NHS Improvement (NHSE&I).

Where this activity has not yet commenced or has started, but not concluded, NHSE&I have agreed that 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 domain 4 and domain 5, if activity has already occurred, PSNC guidance to contractors does indicate 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 will assume the contractor does not want to be involved in these domains. The activity therefore would proceed without the contractors that have not responded.

Q. On the day of declaration are all pharmacy staff required to have completed the appropriate e-learning for a domain, or is this deadline now extended to 30th June 2021?
Contractors wanting to declare against a domain that has any training requirements will still need to make their PQS Part 2 2020/21 declaration as planned in February 2021. However, contractors will have until 30th June 2021 to ensure their teams have completed the activity and collated the evidence to demonstrate that they are compliant with the required levels of training associated with the domains they declare for.

Q. How will this extension work for new starters?
Guidance regarding new starters, or those recently returning to work in the pharmacy is already specified in the PQS guidance. While the guidance is for an action plan to be in place and training to have been completed within 30 days of declaration, the same flexibility for training (i.e. extension to 30th June 2021 to collate the evidence) will apply to the requirements. New starters joining after the point of declaration would not be included in the staffing contingent at the declaration and for whom evidence may be required for any Post Payment Verification (PPV).

Q. Is it possible to complete the PQS declaration as a bulk submission for multiple pharmacies?
No. PQS declarations must be submitted as an individual pharmacy submission. There is no facility to submit a bulk declaration on behalf of multiple pharmacies.


Primary Care Network (PCN) Domains

Q. Can the contractor discussion required to fulfil part of Domain 5 – Business Continuity Planning be carried out via email or WhatsApp?
No. This domain requires a discussion that is facilitated. The need 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. Given that funding is attached to the domain and that this is a key criterion within the domain, the discussion does need to occur between contractors. 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 closure. No other option other than a discussion between contractors in the PCN area and the Lead will be considered by NHSE&I. This discussion can occur virtually using a meetings platform such as Zoom or MS Teams etc.

Q. To satisfy the requirement of participation in contractor discussion, can the pharmacy call or email the Pharmacy PCN Lead to discuss their high level Business Continuity Plan on a 1-2-1 basis prior to declaration if the PCN lead has not arranged a PCN wide discussion?
Where this activity has not yet commenced or has started, but not concluded, NHSE&I have agreed that 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.

A 1-2-1 discussion with the Pharmacy PCN Lead would only be appropriate if a contractor could not make the planned event and they were following up promptly after the event, but before the point at which the Lead is making their declaration.

Where activity has been completed by the Lead and shared with the PCN, the LPC, NHSE&I and contractors in the PCN, any contractors who did not participate or follow up before this, 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 requirement of the domain, any 1-2-1 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.

Q. Our Pharmacy PCN Lead has resigned or left the role; are we still allowed to make declarations against the PQS PCN domains?
Where a Pharmacy PCN Lead resigns or leaves the role, but the required activities had been completed before they resigned or left the role, the contractor will still be able to make their declaration as the PCN Lead.

Contractors aligned to the PCN are also able to declare against the PCN domains where they were involved and contributed to the PCN domains and have met the requirements of the domains.

Q. Where a Pharmacy PCN Lead has not managed to get meetings in place with contractors before the end of the declaration period, how will this impact contractors aligned to that PCN?
If the activities required by the domain do not occur, then contractors aligned with that PCN cannot declare against that domain. The contractors who elected their Pharmacy PCN Lead need to hold them to account to undertake the activity and support meeting the requirements of the domain(s).

If there are problems with the ways of working in the PCN or a lack of activity by a Lead, the assistance of the LPC could be sought. The two PCN domains require collaboration with the Pharmacy PCN Lead, between contractors aligned with the PCN and with the PCN. This collaboration therefore requires active management within the group of contractors. This potentially has implications moving forwards as NHSE&I have been clear in their commitment to developing integrated community-based health care via PCNs.

Q. Can Pharmacy PCN leads still be recruited to assist with completion of PQS PCN activity by 30th June 2021?
Pharmacy PCN Leads can continue to be recruited where gaps occur, however domain 4 activity can only occur until 31st of January 2021. Domain 5 activity would need to have been substantively undertaken, including the contractor meeting, to meet the requirements of the domain before the end of the declaration period. The collation of information and preparation of the required report can occur up to 30th June 2021.

Q. If a PCN Clinical Director or their agreed lead does not engage with the Pharmacy PCN Lead, does this mean that contractors aligned to the PCN cannot declare against that domain?
No. If a lead other than the PCN Clinical Director has been assigned to work with community pharmacy and that individual is not engaging with the Pharmacy PCN Lead, then in the first instance, and with LPC support, the Clinical Director’s support should be sought.

If the PCN Clinical Director is not engaging with the Pharmacy PCN Lead and the Lead has made best endeavours to make contact and progress the requirements of the PQS domains with the Clinical Director, as long as all other aspects of the domain have been undertaken, a claim for the domain could be made by the lead and any participating contractors. The Lead would need to retain evidence to demonstrate the attempts they made to make contact and engage with the Clinical Director (e.g. email trails).

Read further Frequently Asked Questions (FAQs) on the Part 2 Pharmacy Quality Scheme (PQS) 2020/21.



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