Distance Selling Pharmacy Market Entry



To successfully set up a Distance Selling Pharmacy (DSP) in England, Wales or Northern Ireland (Scotland lacks the legislation to open a DSP) the first step is to apply to the GPhC. In turn, the Council will review your application and then notify pharmacies in the proposed area to submit if they have any concerns against your proposal. Generally, as the local competing pharmacy businesses have something to lose, they will scrutinize your application and bring up specific attributes of your application which do not meet the Regulations set out in the NHS (Pharmaceutical Services Regulation 2013): Most common of which include:

  • 25 (3) Distance selling premises applications.
  • 31 a person on the pharmaceutical list (which may or may not be the applicant) is providing or has undertaken to provide pharmaceutical services (“the existing services”) from— (i)the premises to which the application relates, or (ii)adjacent premises.
  • 64 (3) - (except in relation to paragraph (1)(f)), a provider of primary medical services or any other person on the dispensing doctors list for the area of the relevant HWB if there is one (being a performer but not a provider of primary medical services).

The hubnet.io our online Pharmacy Quality Management System has been created to meet these requirements for more details please see this page. Below is a list of the most common queries we get from new market applications:

Signposting: It is unclear how the applicant will signpost to other services as required.
- Support for self-care: It is unclear how the applicant will support patients to self-care.

If you subscribe to the hubnet look at your organisation account... On the left-hand side, you will see: Contact Book>Sign Posting, this is a recording system you can use for self-care etc.


- Delivery of medication: the applicant has not given any details as to how the medication will be safely delivered to patients. Delivery of controlled drugs and fridge lines nationally: The applicant has not detailed the processes that would be followed if a delivery via a courier could not be made, including how the cold chain would be maintained for fridge lines overnight or how controlled drugs would be stored safely and securely overnight. In addition, the applicant has not detailed how it will ensure patient ID checks are completed for controlled drugs.

See, Governance > Essential Services > Medicine Delivery.


- Delivery of controlled drugs locally: The applicant has not shown how controlled drugs would be kept secure during transit and delivered safely to patients or how ID checks will be completed.

See, Governance > Controlled Drugs (GPhC Registration Holders only)> Delivering Controlled Drugs



- Delivery of fridge lines locally: The applicant has not detailed how the cold chain will be maintained when fridge lines are distributed locally.

See, Governance > Internet Pharmacy > Cold Chain Delivery and Operational > Cold Chain Maintenance 


-Clinical governance – the applicant has not detailed any clinical governance processes they will follow in the pharmacy.

The HubNet provides a specialised digital system which performs the following:

  • Remotely manage our Pharmacy SOPs with digital signatures.
  • Complete Clinical Audits.
  • Maintain a daily multidisciplinary Clinical Diary.
  • Record and report Errors - including NPSA classing.
  • Record Date Checking of medicines either by Class (GSL, POM...) or by location (dispensary, shop...).
  • Maintain Cleaning logs.
  • Record your Recalls and securely link staff members to actions taken.
  • Maintain a Responsible Pharmacist log.
  • Record Maintenance is done within the pharmacy

Furthermore, the applicant has detailed a list of enhanced and advanced services that they intend to provide. The LPC would like information as to how these services will be safely and effectively delivered by the pharmacy given the applicant has stated that a consultation room is not required, as face to face contact will not take place. The LPC noted that the enhanced services listed are in fact locally commissioned services and not enhanced services commissioned by NHS England.

Hubnet

Hubnet is an online pharmacy information system. We intend to provide healthcare professionals with an online ecosystem to allow for better communication between each other and their patients. Protected by law, the data you enter into this site remains your intellectual property and cannot be used by us. Our goal is to enable you to do more, if you like it you can subscribe for more!

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