Nominations and patient consent

Nomination is a process that was introduced in Release 2 of EPS. It gives patients the option to choose, or ‘nominate’, a preferred dispensing contractor(s) to which their prescriptions can be sent electronically using EPS.

NHS App introduced a feature from April 2020 to allow patients to view and change their EPS pharmacy nomination.

Being able to update nominations in the NHS App means patients can more easily choose the pharmacy that is right for them during the COVID-19 pandemic and beyond. The NHS App team at NHS Digital have been working on this development for some time, but its release has been prioritised to help patients and primary care teams better cope with ordering and obtaining prescriptions during the pandemic.

Having a pharmacy nomination in EPS removes the need for patients to collect FP10s from GP practices and drop them off at a pharmacy, supporting the public to observe social distancing. It is also intended to help reduce the nomination-setting burden on pharmacy teams and GP practices during this busy time.

To nominate a distance selling pharmacy (DSPs), patients must register with the pharmacy through their website or contact them directly; this is because DSPs normally need to collect additional information on patients that are nominating their pharmacy beyond simple demographic data, so they are able to provide an appropriate service when the first nominated script arrives for the patient.

Patients when ordering a repeat prescription may confirm their nominated pharmacy: a brick and mortar (described within the app as ‘high street pharmacy’) or a distance selling pharmacy (described as ‘online only’). If the former is selected by the patient then a post code is entered to support selection.

Patient Consent:

A number of safeguards have been introduced to ensure that patient choice is maintained when the system is in use:

• The patient can always request a paper FP10: Even after EPS nomination, the patient can choose to have a paper prescription rather than an electronic one . An electronic prescription can only be issued to a patient’s nominated dispensing site. Patients who have not nominated a dispenser or who do not wish to have a particular script sent to a nominated dispenser will receive a paper prescription to take to any pharmacy.
• GP Practices must comply with patient choice: Regulations require* that a prescriber must not seek to persuade a patient to nominate a dispensing site recommended by the prescriber. If a patient asks for a recommended pharmacy, the prescriber is to provide a list of all R2 dispensing sites in the area. The information about which pharmacies are R2-anabled is provided by the NHS website therefore it is essential that pharmacy contact details held there are up-to-date and accurate.
• Contractors must comply with patient choice: Regulations** prohibit dispensers from providing patients with inducements to encourage nomination of a dispenser.
• NHS England should proactively monitor issues: NHS England have a duty to act on complaints about abuse of the service where the GP or pharmacy Terms of Service may have been breached. The NHS Digital are providing the NHS with both summary and detailed reports about nominations to support the investigation of complaints.

*The National Health Service (Primary Medical Services) (Miscellaneous Amendments) Regulations 2005

**The National Health Service (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013

Consent templates

Community Pharmacy England nomination form (NHS England suggested text)

Other options:

• RPS form (MS Word)
• Both the NPA and Numark have developed pre-printed EPS nomination patient information leaflet/consent forms which are available to purchase

The GPhC has published the following guidance to support contractors regarding patient consent:

Patient consent and the NHS Electronic Prescription Service | General Pharmaceutical Council