Moving from contractor‑led funding models to NHS neighbourhood governance and population health assurance
Community pharmacy has always adapted to meet the needs of patients and the NHS. The current moment is no different, but the scale of change now underway demands a fundamental rethink of how services are commissioned, governed and assured.
Yet the way we commission and assure these services has not kept pace.
The PDA is advocating for a new commissioning framework for community pharmacy clinical services, rooted in local NHS governance, population health commissioning and neighbourhood‑level accountability. This is not a rejection of existing contractual arrangements, but a recognition of their limits and that the system has evolved, and our commissioning models must evolve with it.
Recognising what CPCF was designed to do and why that matters
Community Pharmacy Contractual Frameworks (CPCF) have played an important role in supporting community pharmacy’s traditional function as a medicines supply and distribution network, alongside a defined set of professional and public‑health services.
In that context, a national, contractor‑led framework, negotiated within a fixed financial envelope, was both logical and proportionate. It provided stability, consistency and a mechanism for remunerating a network delivering high‑volume, transactional activity at scale.
However, whether you like it or not, the role of community pharmacy is changing. Rapidly.
Pharmacists are increasingly delivering complex, risk‑bearing clinical services, including independent prescribing, long‑term condition management and urgent care pathways. These are not simply extensions of supply; they are clinical interventions, delivered to defined populations, with direct implications for patient safety, outcomes and system flow.
A framework designed primarily for medicines distribution is therefore being asked to do something it was never built for.
The limits of CPCF and PQS for modern clinical services
CPCF negotiations are, by design, contractor‑led discussions focused on distributing a pre‑determined global sum, often dominated by Drug Tariff mechanics, retained margin and clawback rather than prospective service design and readiness.
Similarly, the Pharmacy Quality Scheme (PQS) in England, while well‑intentioned, operates largely through contractor self‑declaration against process measures, rather than commissioner‑verified patient‑level outcomes. Positioned firmly within the CPCF architecture, it has not functioned as an outcome-based population health framework, nor a robust vehicle for assuring prescribing‑based clinical services with associated clinical outcomes.
These mechanisms may remain appropriate for funding distribution and baseline quality improvement, but they are structurally unsuited and not sufficient as assurance vehicles for prescribing‑based and diagnostic‑adjacent care.
Clinical services require commissioner‑owned assurance
As NHS‑commissioned clinical services expand in community pharmacy, the locus of assurance must move.
The PDA’s Roadmap position is clear: professional and clinical assurance should be designed, owned and audited at NHS local system level, not left to contractor self‑attestation.
This reflects established NHS practice elsewhere. GPs, dentists and optometrists delivering NHS care operate within performers list frameworks, embedded in commissioning governance. These systems provide:
- Clear entry and maintenance standards
- Ongoing appraisal and scope assurance
- Proportionate remediation and suspension powers
- Public confidence through transparent governance.
Pharmacists delivering NHS‑commissioned prescribing services currently do not benefit from equivalent structures, despite holding comparable clinical risk and responsibility.
Population health is local – commissioning must be too
Health inequalities, access challenges and prescribing pressures vary significantly between neighbourhoods. A nationally uniform, contractor‑centric framework struggles to respond to this variation.
By contrast, neighbourhood‑level NHS commissioning enables services to be:
- Designed around local population health needs
- Integrated with general practice and wider multi-disciplinary teams
- Commissioned with agreed outcomes and minimum datasets
- Assured through local NHS governance and clinical leadership.
This elevates community pharmacy from a transactional provider to a core component of neighbourhood health systems.
Elevating professional assurance through NHS governance
Placing commissioning and assurance within NHS governance does not diminish professional autonomy. It strengthens it. To support this, the PDA has set out a six‑step test that should be applied to any new community pharmacy clinical service.
At its core, this test asks whether a service is:
- Clinically appropriate for the setting
- Properly governed and assured
- Supported by the necessary workforce, supervision and time
- Integrated into NHS systems and pathways
- Focused on patient outcomes and population health
- Safe, fair and sustainable for the profession.
Embedding this test upstream in commissioning decisions, rather than after services are announced, would significantly reduce risk and improve quality.
Equity across devolved healthcare systems
One of the most compelling arguments for NHS‑led commissioning frameworks is equity.
The UK’s healthcare systems are devolved. Yet community pharmacy commissioning in England remains heavily tied to contractor funding models, while other nations increasingly use health‑board‑led population health commissioning.
Aligning England’s approach with NHS governance principles creates a framework that is:
- More portable and coherent across the UK
- Focused on public assurance rather than commercial negotiation
- Better able to prioritise NHS population health objectives.
This creates a fairer, more coherent approach for patients and pharmacists alike.
A necessary evolution, not a criticism of the past
Independent prescribing expanded clinical pathways and neighbourhood care models demand a different commissioning mindset.
If we continue to rely on contractor‑led frameworks designed for funding distribution, we risk repeating mistakes seen elsewhere in the NHS: fragmentation, inequity and difficulty re‑aligning services to public priorities once private delivery dominates.
The PDA’s advocacy for a new commissioning framework is therefore not radical, it is necessary.
It is about ensuring that as community pharmacy steps fully into its clinical role, it does so within robust NHS governance, population health commissioning, and transparent public assurance.
That is how we protect patients, support the workforce, and future‑proof the profession.
By Jay Badenhorst, PDA Director of Pharmacy
Learn more
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- Over 3,000 pharmacies send an SOS letter to Streeting
- Poor pharmacy funding will blow “enormous hole” in Labour’s NHS plan, Streeting warned
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