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PDA responds to NHS England consultation on draft Primary Care Network DES Service Specifications

NHS England consulted from 23 December 2019 to 15 January 2020 on draft Primary Care Network DES (Direct Enhanced Service) Specifications.

Mon 27th January 2020 The PDA

Last year, NHS England and GPC England agreed a five-year GP contract framework which aimed to alleviate the workforce pressures on general practice, secure enhanced investment into primary medical care, and roll out new service models.

A key element of the new GP contract framework was the creation of primary care networks (PCNs) through the new Network Contract DES. The GP contract framework set out seven national services specifications that will be added to the Network Contract DES: five starting from April 2020, and a further two from April 2021.

The PDA is responding to this consultation because part of the new network contract DES involves the recruitment, training and embedding into general practice of 7,500 Clinical Pharmacists by 2023-2024 and assumes that an average PCN will have recruited 3 clinical pharmacists (in total around 3,500) for 2020-2021.

We have a significant number of members who may have their workload, training requirements and practice risk profile affected by the proposals contained within this consultation. Our response to the consultation is informed by the emerging evidence from clinical pharmacists already working within GP practices and focuses on key areas of concern.

The PDA noted the following:

  • This consultation had a very short response period and was launched just two days before Christmas. This was unfortunate given the importance of the content.
  • NHS England does not appear to have done any form of meaningful impact assessment on the effect of the service requirements.
  • NHS England is potentially introducing patient risk by including junior and inexperienced pharmacists as clinicians expected to provide structured medication review to complex patients.
  • NHS England has assumed that all PCNs have been able to appoint a full complement of clinical pharmacists and has based their estimations of the work to be done on this, rather than on the actually available workforce.


thumbnail of W 001 PCN DES Consultation January 2020 final (002)


thumbnail of Draft PCN Service Specifications December 2019

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