Maintaining access to pharmacy services – opening hours and temporary closures
The COVID-19 pandemic is unprecedented and exceptional measures may be required to ensure patient and public safety, as well as the safety and welfare of the pharmacy team.
The workload and other pressures on community pharmacy during the second phase of the outbreak are likely to remain high, with staff illness and absence continuing, additional services such as the pharmacy delivery service to shielded patients to provide, other deliveries to vulnerable patients and those isolating continuing to be necessary; and the continuing need to manage the ongoing new ways of working such as working behind screens, social distancing for staff, patients and customers and the use of PPE for patient interactions, as necessary. Please see the business continuity and PPE, staff safety and security pages on the PSNC COVID hub.
For pharmacy staff to stay well and not be fatigued, contractors may need to consider steps to temporarily shorten the working day or have periods of time for staff to recover and catch up with any backlog of work. The same steps may be needed for a period of time, even if the pharmacy team is not reduced in numbers.
Various dispensations and options for closed door working and the flexible provision of hours or services are in place in accordance with the emergency provisions of the NHS (Pharmaceutical and Local Pharmaceutical Service) Regulations 2013. NHS England and NHS Improvement (NHSE&I) may also require community pharmacies to open as it has done for recent Bank Holidays.
Flexible opening provisions
Flexible opening already authorised by NHSE&I
NHSE&I have agreed that contractors may make use of opening hours flexibility, as set out in the Community Pharmacy SOP.
NHSE&I has agreed some flexibility in the hours that pharmacies need to open to the public, specifically:
- If under significant pressure, at the discretion of the responsible pharmacist, pharmacies may close their doors to the public for up to 2.5 hours a day, including lunch.
- All pharmacies will be expected, to be open to the public between 10am and 12 noon and 2pm and 4pm (on every day they have contracted opening hours) and any working behind closed doors should be outside of these hours.
- Similarly, 100 hours pharmacies should be open from 10am-12pm and 2pm-6pm (if these are contracted hours) and any working behind closed doors should be outside of these hours.
- A sign on the door must give information about how to contact the pharmacy if urgent help is needed (NHSE&I has provided a poster, available from the NHS resources folder in the PHE Campaign Resources Centre).
No notification to NHSE&I is required for opening hours flexibility (closed-door working), which is not a temporary closure, and contractors must update their NHS 111 Directory of Services (DoS) entry and NHS website pharmacy profile as appropriate.
Flexible temporary opening hours that may be requested from NHSE&I during an emergency
The flexible provision of pharmacy services may assist contractors as the outbreak continues, if opening hours at one or more pharmacies need to be adjusted to match the staff and resources available. This provision permits contractors to manage the pharmacies across their own network, if NHSE&I agrees with the contractor’s proposal.
Contractors must apply to NHSE&I for the temporary flexible provision of pharmacy services – for temporary changes to the days or times the pharmacy will be open, or a temporary closure of the pharmacy – and to do so, should give:
- 24-hours’ notice of the proposed change or closure to NHSE&I; and
- the reasons for the request.
NHSE&I will only agree with a contractor’s request if it consider the reasons are adequate.
Having given 24-hours’ notice, the contractor does not need NHSE&I’s permission in advance of the change, or closure, so, if NHSE&I does not object to the request, it can be implemented. If, subsequently, NHSE&I does not approve the request, the pharmacy must go back to its original opening hours.
If NHSE&I grant the request, the contractor may revert to the original hours by giving NHSE&I 24-hours’ notice.
NHSE&I has indicated in the SOP that temporary closures may be granted for:
- closure of a pharmacy in an area where there is minimal demand due to the Government’s social distancing policy (e.g. shopping malls);
And may grant such closures for:
- pharmacies co-located with GP practice hot sites, dealing with COVID-19 patients, where patient access to the pharmacy is affected.
Flexible temporary closures that may be requested from NHSE&I during an emergency
New options for temporary closure and relocations are now available under emergency provisions in the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013. PSNC has brought together guidance and resources on how contractors can apply or notify the authorities if they need to close for any of these reasons – see Temporary closures during the COVID-19 outbreak.
NHSE&I has stated that for temporary closures (not closed-door working), for instance where not enough staff are available to work, NHSE&I must be informed immediately. The pharmacy NHS 111 DoS profile must be updated, as must the NHS website.
NHSE&I is encouraging cooperation between community pharmacies and GP practices in primary care networks, to deliver the best care, and protect and maximise the capabilities of staff across practices and pharmacies.
NHSE&I also encourages local pharmacies to work to maintain continuity of services in the event of temporary closures through ‘buddy’ arrangements, stating:
Particular thought should be given to patients receiving services such as supervised consumption or monitored dosage systems. Consideration can be given to providing daily doses rather than supervised consumption on an individual patient risk assessed basis.
This guidance is included in the Community Pharmacy SOP.
Immediate temporary closures due to illness or other reasonable cause
A contractor may also close a pharmacy on a temporary basis if prevented from opening by reason of illness or other reasonable cause – for example, staff illness and absence or for the decontamination of the pharmacy.
NHSE&I has indicated that contractors closing temporarily for this reason must:
- inform NHSE&I of the temporary closure (and any arrangements for continuity of service with other contractors/pharmacies);
- update the pharmacy NHS 111 DoS profile; and
- update the NHS website.
NHSE&I is encouraging cooperation between community pharmacies and GP practices in primary care networks, to deliver the best care, and protect and maximise the capabilities of staff.
Temporary relocation during an emergency
If a contractor needs to move the provision of pharmacy services from the existing pharmacy premises to new pharmacy premises, this is an excepted application, so involves a more detailed application form (regulation 29(1) of the NHS Regulations). NHSE&I may grant such an application for a period of time no longer than the emergency, which currently declared until 1st September 2020. A reason for such an application might be, for example, co-location with a GP hot site treating COVID-19 patients, such that patients of the pharmacy are no longer able to access the pharmacy safely.
Maintaining pharmacy services during the outbreak (the emergency regulations)
Ensuring the continued provision of services in an area where there is a flexible temporary opening or closure during an emergency a closure
If one or more contractor closes pharmacies temporarily in an area, there is the potential for patients and the public to lose reasonable access to a pharmacy. Therefore, it is suggested that contractors liaise with NHSE&I well in advance of seeking temporary flexible opening hours and temporary closures where reduced hours or closures could affect the overall provision of medicines and pharmacy services to patients and the public – i.e. that contractors give more than the 24 hours’ minimum notice where possible. This is to ensure that closures by a number of contractors do not result in all the pharmacies in one area closing at the same time. LPCs should also be able to assist in discussions with NHSE&I.
See PSNC information on Maintaining pharmacy services during the outbreak.
NHSE&I may also require community pharmacies to open
NHSE&I may also require community pharmacies to open as it has done for recent Bank Holidays. Existing contractor intentions to open recorded on the DoS and NHSE&I directed opening will be sufficient to provide sufficient pharmacy services for patients on that day. See PSNC information on the National Health Service (Amendments Relating to the Provision of Primary Care Services During a Pandemic etc.) Regulations 2020.
Emergency regs on flexible provision of services
The Pharmaceutical Services (Advanced and Enhanced Services and Emergency Declaration) Directions 2020 declared an emergency requiring the flexible provision of pharmaceutical services with effect from 27th March 2020. Direction 2 states that until 1st September 2020 NHS England must exercise its functions, or consider exercising its functions, under NHS regulations relating to: relocation of premises, and temporary flexible provision of hours and/or closures for community pharmacy contractors, appliance contractors and LPS pharmacies.
The emergency provisions of regulation 61 also mean that NHSE&I may allow a dispensing doctor practice to dispense medicines temporarily to normally ineligible patients if required to maintain adequate provision of pharmaceutical services in the area.
Primary Care Commissioning (PCC) has issued a helpful briefing on the flexible provision of pharmaceutical services during the current pandemic.
Checklist for emergency closures
If you need to close your community pharmacy because of the ongoing COVID-19 pandemic, it is important that you do as much as you can before you leave the premises, where it is safe to do so. The pharmacy may be run by locums or other staff who are unfamiliar with your processes and procedures, or the pharmacy may be closed. It’s important that you do what you can, where it is safe to do so, to make sure everything is in place to ensure patients are able to access their prescriptions, and that your business can resume easily and effectively. You should not put yourself, your staff, or your patients at any unnecessary risk. For more information, please see our emergency closure checklist prepared with NHSE&I.
Amended models of care during the pandemic (hot sites)
In most circumstances, the NHS is seeking to provide treatment required by COVID-19 infected patients remotely or in their home. In exceptional circumstances, infected patients may need a face-to-face consultation and Clinical Commissioning Groups (CCGs) and general practices have been asked to put in place local arrangements to allow this to happen, while also ensuring appropriate separation of these patients from others, particularly the extremely vulnerable group.
In some areas, ‘hot sites’ are being set up at general practices, out-of-hours hubs or other locations, which may deal solely with COVID-19 patients (sometimes described as red sites) or may deal with all patients, but with clear segregation between the two cohorts (sometimes described as red and amber sites).
Where this is happening at GP practices and other sites which have a co-located community pharmacy, there could be a profound impact on the normal patient flows and subsequent use of the pharmacy during the period of the pandemic. The following document provides guidance for contractors and LPCs to consider when having local discussions:
Capacity changes and operational status reporting
NHSE&I will be using the DoS to monitor capacity changes within primary care. Contractors are therefore requested to continue to update their capacity status on their DoS profile. Please also remember to inform your local NHSE&I team of unavoidable closures and update the NHS website for patients and the public.
Pinnacle Health, now operating as part of the EMIS group, has been working closely with PSNC to develop a reporting template allowing pharmacies to record their operational status. This will allow pharmacies to record the level at which they are operating against a Red, Amber, Green traffic light system and provide feedback to LPC leads and Head Offices about the challenges they are facing. For sites recording an Amber status, the template allows a pharmacy to record and feedback details of their operational challenges and also provide information on planned closures, in line with the COVID-19 SOP.
For pharmacies faced with no alternative other than to close, i.e. recording a RED status, the template supports recording of actions taken in line with the requirements of Annex 14 of the NHSE&I pharmacy manual, and details of the closure itself. All information recorded and saved for a RED status will prepopulate a form that can be printed when data is saved. The form can be sent to the regional NHSE&I office to inform them of the closure.
Bank Holiday Openings
25th May Bank Holiday: NHSE&I confirmed that there would be no blanket requirement for all community pharmacies to open on the Spring Bank Holiday (25th May 2020).
Early May Bank Holiday (8th May): NHSE&I required community pharmacies in England to open between 2pm and 5pm on Friday 8th May 2020 (the Early May Bank Holiday). Contractors needed to submit their claim for the £250 per hour payment between the 25th May 2020 and 22nd June 2020, with payment due on 1st July. This payment will not appear on the FP34 Schedule of Payment but the NHS Business Services Authority (NHSBSA) will provide confirmation of payment via individual contractor letters.
Easter opening hours: NHSE&I required all community pharmacies in England to open from 2pm to 5pm on 10 April 2020 (Good Friday) and 13 April 2020 (Easter Monday). Contractors needed to submit their claim for the £250 per hour payment between the 17th April and 5th May 2020, with payment due on 1st June. This payment will not appear on the FP34 Schedule of Payment but NHSBSA will provide confirmation of payment via individual contractor letters.
For any queries, please contact Gordon Hockey, PSNC’s Director of Operations and Support.