Written evidence submitted by the Company Chemists’ Association (CCA)


About the Company Chemists’ Association (CCA)


Established in 1898, the CCA is the trade association for large pharmacy operators in England, Scotland and Wales. The CCA membership includes ASDA, Boots, LloydsPharmacy, Morrisons, Rowlands Pharmacy, Superdrug, Tesco, and Well, who between them own and operate around 6,000 pharmacies, which represents nearly half the market. CCA members deliver a broad range of healthcare and wellbeing services, from a variety of locations and settings, as well as dispensing almost 500 million NHS prescription items every year. The CCA represents the interests of its members and brings together their unique skills, knowledge, and scale for the benefit of community pharmacy, the NHS, patients and the public.



Summary and Recommendations:

We welcome the Committee’s independent evaluation. Whilst we are broadly supportive of the commitments, barriers to digital integration and interoperability continue to drive geographical variation in services, inefficiencies, and operational challenges for providers.


We have focused on policy area one and consider the government’s digital commitments for patient care and services. At the heart of our response, we propose the following as key priorities and benchmarks against which the government’s commitments should be measured:


1)      Consistent data sharing - Seamless use of, for example, the NHS App and other healthcare solutions would be facilitated by data flow maps showing which systems are linked and integrated. With this is the need for a consistent method for sharing information with system providers and organisations engaged in digital transformation.

2)      National data sharing agreements – We recommend that data sharing agreements are implemented nationally to facilitate the sharing of clinical information between community pharmacy and other health settings. There is a clear need for standardisation in information flows.

3)      Bespoke digital transformation for all needs – Personalised care is as much about transforming digital service use for patients as it is about enabling providers to deliver the best possible care for patients. Digital commitments must also take into account pressing issues such as digital exclusion, digital apathy (e.g., amongst elderly patient cohorts) and other barriers where patient prefer traditional access points to healthcare.


4)      Better engagement with the community pharmacy sector Underpinning all of this, it is essential that early discussions with the sector/providers and system suppliers take place to meet the needs of patients and the population.








Policy Area: Care of Patients and Service Users


Commitment 1: Uptake of the NHS App


We consider the NHS App to be an appropriate commitment. Greater uptake of the NHS App has the potential to deliver increased benefits for service users to ensure they have access to the best possible care.


There is nevertheless room to be ambitious to boost uptake. We have seen a positive impact for patients who are now able to order repeat prescriptions via the NHS App. We would encourage this to go a step further, creating a greater ability for patients to view the status of their prescriptions would offer benefits to pharmacies and patients alike. Patients should have the ability to request synchronization prescriptions to simplify the administration of repeat medication for patients and general practice


There is great potential for the NHS App to act as the digital ‘front door’ to the NHS. This should likely include the ability to ‘nudge’ patients to access less immediate care, such as self-care options and similar, to improve their general health. Critically the NHS App should have the ability to refer the patient to the service they need.


It is essential that this includes open standards for all providers to link their own systems, with full interoperability. The NHS app should be a lighthouse for providing digitised services integrated into the NHS’. These services should not be exclusive to the NHS app and by enabling third party integration this will drive forward innovation for patients.


Commitment 2: Personalised Care through Digital Connection


The pandemic has demonstrated the swift digital adaptability of both providers and patients.  Increased use of remote consultations, and uptake of other digital technologies, have highlighted new ways of working and accessing healthcare suited to individual need.


We support this commitment and the opportunities it presents. As with the NHS App, we would encourage increased accessibility of digital patient pathways to deliver more personalised care. For example, this commitment could be assessed against wider implementation of assistive technologies, such as auto-translate features, or adoption of more sophisticated screen readers. Greater flexibility to patient pathways will further enhance choice and outcomes.


However, there are several caveats integral to this commitment’s success. Firstly, digital exclusion is still faced by many patient cohorts across the country. To fulfil this commitment, multiple access points must be on offer for patients in line with their needs, taking into account rates of digital poverty. In England, 98% of community pharmacies are located within a 20-minute walk in the most deprived areas. This unique benefit means commissioning activity from community pharmacy can directly target those patients most at risk of digital inequality.


The CCA welcomes the expanding role of community pharmacy under the current Community Pharmacy Contractual Framework (CPCF) in England to deliver vital healthcare for patients. Commissioned activity is creating regular communication between clinicians and improving patient care, with a clear benefit for patients and value to the NHS of further embedding community pharmacy into the wider healthcare system.


In turn, the expanded offer of clinical services in pharmacies means that the volume of information and data captured by pharmacy teams is increasing. Bespoke digital transformation must therefore take a patient-first approach that is mindful of differences in access and choice. Personalising patient pathways is as much about modernising the digital infrastructure available to providers as it is about enhancing the patient’s digital experience. However, information flows remain patchy or outdated, against the increasing complexity of clinical data recording requirements, in the absence of the appropriate and supportive digital infrastructure.


Patchy or inconsistent data flow increases bureaucratic burden and impacts patient care. One such consequence is that many patients are faced with having to repeat conversations to different healthcare professionals, which can be cumbersome or even distressing. Rather than empowering patients, this discourages interaction with healthcare providers. Fit-for-purpose systems present a dual benefit to patient and provider. Better-informed clinical decision-making based on real-time information improves patient outcomes, whilst reducing bureaucracy and increasing capacity for practitioners.


We would also like to see improvements to information reporting and performance evaluation of services. For example, our members’ experience of the Covid-19 vaccine programme found that the monitoring of uptake rates amongst certain patient cohorts was inconsistent or not accessible. Contractors need a real-time understanding of service performance to properly assess which aspects are delivering and where efforts should be redeployed to fully support priority patient groups. Data clarity will allow contractors to enhance operational service management and deliver better outcomes for patients.


Commitment 3: Roll out of Integrated Health and Care Records

We are certainly in strong support of this commitment, but we would like to highlight that this remains a longstanding problem despite sector calls for improvement. Indeed, this commitment needs to be met with a clear plan and set of objectives.

A roadmap, with the NHS and government fully engaging community pharmacy as a delivery partner, must be made a priority to fulfil this commitment. The increase in new services commissioned under the CPCF have highlighted the urgency for improvements to systems integration, to the design of formal referral pathways, and to the interoperability between pharmacy and other healthcare providers. The lack of appropriate infrastructure has led to regional variation in the delivery and offer of services. This ‘post-code lottery’ benefits neither patients nor the NHS.


As a sector, we have emphasised that shared records are key to interoperability and joint working, to enable effective and efficient care for patients across all settings. Despite some promising evidence, there is no clarity on a commissioning timeline that could inform work from both NHS and community pharmacies to implement these records. There is a need for a joined-up approach, succinctly describing the need and value of shared digital records alongside the desired timelines.


Furthermore, against the current ICS landscape, the ability for community pharmacy to access shared care records is currently extremely difficult due to localised data sharing agreements, security access and technical requirements with lack of standardisation at a national level. To enable community pharmacy to integrate with shared care records effectively, there is a need for a national standard which allows large organisations with a national reach, such as our members. Implementing one solution allows both access of clinical information, smoother flows, and sharing outcomes with a patients shared care record.


Indeed, as the scope and offer of clinical community pharmacy services expand, access to more complete patient information through shared records is essential. Examples such as the Discharge Medicine Service show increasing routes of communication and information flow between pharmacies and the secondary care sector; share care records are paramount to patient safety and timely intercommunicability.


This is true for the design of formal referral pathways, which should have a mandatory requirement for minimum data sets. Again, the government must take into account the increasingly dynamic portfolio of community pharmacy services, as the sector becomes more embedded within the NHS architecture. Locally, referral systems do not follow nationwide technical standards, meaning multiple different systems require checking for patient referrals based on the system chosen by the referrer. This inefficiency risks the timelessness of action in the pharmacy.


Referrals should have consistent standards across services and settings, with nationally determined data sets. The Professional Record Standards Body (PRSB) have defined minimum standards for what should be recorded in service delivery, with minimum information requirements for all services and by all parties. Technical and data standards are essential to enable interoperability.


We note recent technical products such as the National Booking System, developed rapidly in response to the pandemic. This does not currently offer external integration with existing (and mature) systems in community pharmacy. This limits the ability to fully use the NBS or expand it beyond its initial remit. Integration with any suitable system should be a default requirement for any NHS commissioned/designed service. In this way clinicians and providers can use the digital systems that suit their own needs yet have equal seamless access to the necessary digital pathways.


We welcome the NHS Digital Booking and Referral Standard (BaRS) programme which should standardised referrals across the NHS. We would encourage this programme to begin implementation quickly, consider practical steps to engage all providers and encourage uptake of new standards, as well as to prioritise community pharmacy referrals – given their ability to directly improve access to GP appointments.


Nov 2022