Written evidence submitted by the Pharmacists’ Defence Association (PDA)




Pharmacists’ Defence Association (PDA) response to the Public Accounts Committee inquiry into access to urgent and emergency care

The Pharmacists’ Defence Association (PDA) welcomes the opportunity to provide evidence to the Public Accounts Committee into access to urgent and emergency care.

As the largest representative organisation of individual pharmacists in the UK, the PDA represents over 36,000 members, working across all areas of practice.  Our experience of dealing with over 5,000 cases each year on professional, regulatory and employment matters provide a unique insight into the issues that matter to pharmacists and where opportunities and risks arise.


  1. Pharmacists supporting access to urgent and emergency care

1.1  Pharmacists working across all areas of the NHS play a significant role in supporting the urgent and emergency care agenda, including those in hospital pharmacy supporting in-patient care and the effective discharge of patients, those in primary care preventing admission and readmissions to hospital, and those working in the community, being the first port of call and providing advice and treatment for certain conditions where appropriate.

1.2  In England, since the Community Pharmacist Consultation Service was launched, an average of 10,500 patients are being referred for a consultation with a pharmacist following a call to NHS 111; these are patients who might otherwise have gone to see a GP.[1]  The National Audit Office report[2] also highlights that in 2022, community pharmacists carried out an estimated 65 million consultations, seven million more than the 58 million in 2021.


  1. Meeting public and NHS expectations

2.1  With community pharmacy being positioned more than ever as the first port of call for patients seeking advice, there must be certainty that there is a pharmacist always present to provide a consultation and indeed that the pharmacy is open when it is expected to be.

2.2  PDA members say that there are unacceptable levels of temporary, unplanned pharmacy closures and we are aware of the decline in numbers of pharmacies open for extended hours, for example those based in supermarkets and that are open at weekends – where demand for additional capacity is likely to be higher.

2.3  Some pharmacy bodies have claimed that there is a shortage of pharmacists, however data from the General Pharmaceutical Council demonstrates that this is not the case[3] and there are more registered pharmacists in the UK than ever before.  The data around temporary pharmacy closures is complex, and there are many reasons why pharmacies have had to close temporarily[4]. Some of the data and anecdotal information supplied to us by our members may indicate that some pharmacy contractors have initiated temporary closures for reasons other than a “shortage of pharmacists”.

2.4  The pharmacist profession in the UK includes a significant sized population of pharmacists that locum, i.e., work on a self-employed basis to cover shifts where no employed pharmacist is available.  Some locum full time, others have a substantive employed role and locum in addition. Locum pharmacists tell us that there are many occasions where a pharmacy operator takes the commercial decision to temporarily close the pharmacy rather than pay the going rate for a locum.

2.5  Temporary pharmacy closures cause distress and concern to patients, who are unable to access their medication and advice, it is difficult for them to easily seek prescribed medication at an alternative pharmacy due to the electronic prescription system, which can also then create unnecessary work at GP practice level to try and remedy the issue. For pharmacists, this also creates back-logs and unnecessary pressure on pharmacists and their teams who are left to deal with the fall-out.

2.6  The PDA believe that more focus, including effective monitoring and the application of commissioning levers, should be in place to provide assurance around contractual opening hours of all pharmacies, to ensure that local, physical access is maintained. 


  1. Structural and contractual factors

3.1  The PDA has cautiously welcomed the latest government announcement of an injection of funding to support improving access to primary care.  However, the feedback that we have been getting from our members around the current extraordinarily high levels of workload and burnout in community pharmacy means that alongside these plans, serious consideration must now additionally be given to having more than one pharmacist being able to work in a community pharmacy if this NHS vision is to be delivered.

3.2  We recently made a submission[5] to the Health and Social Care Committee’s Independent Expert Panel in their evaluation of the Government’s commitments around pharmacy in England. We noted that whilst the developments around using pharmacists’ clinical skills to try and plug holes in the current primary care access crisis may seem innovative, the approach potentially serves to prop up a system that begs to be substantially overhauled because it fails to concentrate the use of healthcare professionals upon the areas in which they could drive the greatest benefits.

3.3  The contractual model and associated funding for community pharmacy also needs to be overhauled, to better reflect the expertise of pharmacists and their role in supporting access to NHS services and the effective and safe use of medicines, which go far wider than supply or a discrete menu of services or treatments for specific conditions

3.4  The increase in the number of pharmacist independent prescribers also provides an opportunity to further develop the role, and for commissioners to make full use of pharmacists’ skills.

3.5  A strategic plan from the NHS is needed to outline how this will be developed and implemented over time to widen access and improve outcomes for patients.


  1. How could a focus on medicines create more capacity in the system?

4.1  According to ONS data, the total pharmaceutical expenditure[6] in the UK stood at £39.6 billion in 2021, 14.1% of current health expenditure, representing both the final use of medicines and those used in wider courses of treatment.

4.2  Whilst this figure may have been slightly impacted by the effects of the Covid-19 pandemic, this can also be attributed to people living longer but with more chronic health conditions. 

4.3  However, research has shown that those same medicines are, in some cases causing unnecessary harm to patients due to a lack of pharmaceutical care, which can lead to further demands on the NHS.

4.4  In 2021, the Department of Health and Social Care published their report[7] Good for you, good for us, good for everybody, a plan to reduce overprescribing to make patient care better and safer, support the NHS, and reduce carbon emissions. 

4.5  The report recognised that, “With overprescribing, given that the NHS primary care medicines budget is around £9.2 billion a year, the potential savings and reductions in waste are very significant. Tackling overprescribing will also bring savings in preventing avoidable hospital admissions and the use of other services”.

For pharmacists, the current focus largely does not take advantage of the significant and powerful opportunities of pharmaceutical care, which could help with capacity issues elsewhere in the system.





  1. What is pharmaceutical care?

5.1  Pharmaceutical care has been defined as a patient-centred practice in which the practitioner assumes responsibility for a patient’s medicines-related needs and is held accountable for this commitment”[8].

5.2  The PDA’s strategy around pharmaceutical care can be found in the report Road Map for England[9], which describes how this approach could be beneficial in preventing avoidable hospital admissions through a better focus on the care of patients around medicines use.

5.3  As decision makers shape the future of health and social care systems there is the need for a wider, bolder and more comprehensive joined-up strategy; one which takes a fully integrated approach and one which also ensures that pharmacy adds the most benefit to the care and safety of patients via a focus upon the effective and safe use of medicines, whichever part of the primary or secondary care system they find themselves in.




[3] GPhC registers data | General Pharmaceutical Council (

[4] Revealed: The reasons behind temporary pharmacy closures | Chemist+Druggist :: C+D (




[8] Cipolle RJ, Strand LM, Morley PC. Pharmaceutical care practice: the clinician’s guide. 2nd ed. New York: McGraw-Hill; 2004