Guidance

2022 Pharmacy Access Scheme: guidance

Updated 12 May 2023

Executive summary

This document provides further information about the 2022 Pharmacy Access Scheme (PhAS) in support of the determination in Part XIIA of the Drug Tariff. This is a revised scheme that will apply from 1 January 2022. This document sets out the rules and eligibility criteria for the 2022 PhAS. Separately, a list of eligible pharmacy contractors has been published.

The 2022 PhAS is one of the elements agreed as part of the agreement on year 3 (2021 to 2022) of the Community Pharmacy Contractual Framework 5-year deal.

The Pharmacy Access Scheme

The aim of the Pharmacy Access Scheme (PhAS) is to ensure that a baseline level of patient access to NHS community pharmaceutical services in England is protected. The PhAS is not designed to replace the Local Pharmaceutical Services (LPS) provisions.

The scheme is paid for from the funding for the Community Pharmacy Contractual Framework (CPCF). The PhAS is an additional monthly payment made to all eligible pharmacies in areas where there are fewer pharmacies. The maximum expenditure on the 2022 PhAS will be £20 million per financial year. The 2022 PhAS will apply from 1 January 2022 and run until the next PhAS review.

The PhAS has been designed to capture the pharmacies that are most important for patient access, specifically those pharmacies where patient and public access would be materially affected should they close. The PhAS takes isolation and need levels into account.

The objective of the 2022 PhAS is to create a scheme that is more targeted and representative of the pharmacy market as it is now, and that better targets support to pharmacies that are deemed essential for local provision of physical NHS pharmaceutical services.

Pharmacies in areas with dense provision of pharmacies remain excluded from the scheme. In areas with high numbers of pharmacies, public access to NHS pharmaceutical services is not at risk. To best protect access, the scheme is focussed on areas that may be at risk of reduced access, for example, where a local population relies on a single pharmacy.

Distance-selling pharmacies (DSPs), dispensing appliance contractors, local pharmaceutical services (LPS) contractors, and dispensing doctors remain ineligible for the scheme.

The 2022 PhAS retains a review process to deal with any inaccuracies in relation to pharmacy premises addresses or any unforeseen circumstances affecting access, such as a permanent roadblock.

The 2022 PhAS will apply from 1 January 2022. The first payment of the 2022 PhAS will be part of the January reconciliation payment on 1 April 2022.

As part of the annual negotiation of the CPCF, we will continue to monitor the revised scheme and consider whether further updates and revisions are required, from April 2023 at the earliest.

All pharmacies deemed eligible for the 2022 PhAS following review will receive back payments from the start of the 2022 PhAS, that is from 1 January 2022. LPS pharmacies returning to the Pharmaceutical list, that meet the eligibility criteria, will receive backdated payments from 1 January 2022 or from the date they returned to the pharmaceutical list, whichever is later.

A list of pharmacies eligible for the 2022 PhAS has been published together with this document. The list includes pharmacies that are eligible by dispensing volume and by distance based on distance mapping analysis to the next nearest pharmacy. A condition for the first PhAS payment is that contractors must be registered on the Manage Your Service (MYS) platform to provide the Community Pharmacist Consultation Service (CPCS) by 31 December 2021. To continue to receive PhAS payments, they will have to continue to be registered for CPCS for greater than or equal to half of the number of full days in the relevant month.

Some contractors not currently on the PhAS list may be added following completion of the review process or if an LPS pharmacy returns to the pharmaceutical list.

Each pharmacy contractor currently receiving a PhAS payment will receive an individual letter via the NHS Business Services Authority (NHSBSA) indicating any changes in their eligibility and the PhAS payment amounts from 1 January 2022.

Those contractors who are eligible on the basis of the number of Single Activity Fees (SAFs) volume threshold but were deemed ineligible on the basis of the distance analysis, will receive details about access to the online portal to review the mapping analysis that was used to determine their eligibility.

A review process will be managed by NHS England and NHS Improvement (NHSE&I). The only grounds for a contractor to apply for a review are inaccuracies with a pharmacy premises address or issues with access – for example, permanent roadblocks that should be taken into account in determining the walking distance to their next nearest pharmacy, therefore impacting the determination of their eligibility for the scheme (see below for details of the review process).

Eligibility

Pharmacies do not need to apply to the scheme to be eligible. Eligibility is calculated nationally for all contractors in England and has been reviewed against all pharmacies on the pharmaceutical list of 31 March 2021. Only pharmacy contractors on the pharmaceutical list of 31 March 2021 are eligible for the 2022 PhAS. Eligibility determinations are based on data on the number of SAFs associated with the dispensing volume of a contractor in 2019 to 2020 to assess their size, and data relating to the distances between pharmacies.

Eligible pharmacies will receive their first PhAS payment as part of the January 2022 reconciliation payment on 1 April. These payments will continue monthly.

From 1 January, eligibility for the 2022 PhAS will be based on meeting all of the following criteria:

• the pharmacy is on the pharmaceutical list of 31 March 2021. Distance-selling pharmacies (DSPs), dispensing appliance contractors, local pharmaceutical services (LPS) contractors, and dispensing doctors are not eligible for PhAS
• the pharmacy is more than one mile from the next nearest pharmacy, based on pharmacy to pharmacy distance calculations using Ordnance Survey^{[footnote 1]}
• where a pharmacy is in a deprived area (that is, the premises are located in the area assigned to IMD decile 1 to 2),^{[footnote 2]} distance to the next nearest pharmacy is reduced to more than 0.8 miles
• the pharmacy had a dispensing volume^{[footnote 3]} between 1,200 and 104,789 in 2019 to 2020. For pharmacies that opened after March 2019, a mixture of scaling and data from following months was utilised to get a full 12 months^{[footnote 4]}
• the pharmacy premises are directly accessible to the public, that is, not in an area with restricted access (for example, beyond airport security)

If a pharmacy with an LPS contract meets the eligibility criteria for the 2022 PhAS and would have qualified were it on the pharmaceutical list, and is subsequently included in the pharmaceutical list after 31 March 2021 (due to a right of return or other contractual change), that pharmacy would be treated for the purposes of the 2022 PhAS as if it actually were on the pharmaceutical list on 31 March 2021. If the pharmacy meets the other PhAS eligibility criteria, their PhAS payments will commence from the date they joined the pharmaceutical list. If a pharmacy is removed from the pharmaceutical list after March 2021, their PhAS payments stop from the month they leave the list.

If a pharmacy was eligible for the current PhAS based on the distance determination applied in 2016 and there has been no change to the address of their premises or the address of their next nearest pharmacy, that pharmacy will remain eligible for the 2022 PhAS until the next iteration of PhAS providing the contractor meets all other eligibility criteria.

To note, if the pharmacy is eligible for the current PhAS following a review process in 2016, it does not necessarily mean that they are automatically eligible for the 2022 PhAS and they might need to submit an application for the review process. This protection will not apply if the change in distance calculation is due to a change in circumstances (that is, a pharmacy changed location of premises, a new pharmacy opened or another pharmacy contractor relocated nearby or the IMD decile of the pharmacy changed).

Distances between pharmacies for the 2022 PhAS have been measured by road distance rather than as the crow flies and are therefore more representative of patient walking journeys. The data for the 2022 PhAS is based on Ordnance Survey (see eligibility criterion 2). This includes taking account of footpaths. For these calculations, public transport travel distances were not taken into account because of the regional variability of provision of public transport, and because public transport timetables are subject to change and would therefore not have been a robust basis for distance calculations. Walking distance has been deemed to accurately reflect equal access to patients irrespective of their location.

During the COVID-19 pandemic in 2020 to 2021, many pharmacies have seen unusual changes in their dispensing volumes. Therefore, the eligibility determinations for the updated PhAS are based on contractors dispensing activity for 2019 to 2020. Pharmacies that received fewer than 1,200 or more than 104,789 SAFs in 2019 to 2020 are not eligible for the scheme. The upper threshold excludes the largest 30% of pharmacies, as larger businesses have the ability to remain viable without this additional support.

Any changes to contractors’ eligibility for the 2022 PhAS will only be made if a full review of the scheme is undertaken and a refreshed distance mapping analysis is conducted. Therefore, if a qualifying PhAS pharmacy subsequently increases its dispensing volume and thus receives more SAF payments, that pharmacy will not automatically lose entitlement to the PhAS but may become ineligible when the next revision to PhAS eligibility takes place. If a new pharmacy opens very close to a pharmacy receiving PhAS payments, the PhAS pharmacy will not lose entitlement. Likewise, any new pharmacy opening will not be eligible for the 2022 PhAS until the next update of the PhAS scheme.

In summer 2021, all contractors meeting the PhAS criterion for the number of SAF payments will receive a letter with login details for the online portal and will be able to review the details of their mapping analysis and distance determination for their premises. If a contractor does not qualify for the number of SAF payments criteria, the contractor is not eligible for the scheme.

An eligibility flowchart is attached at Annex A.

Payment calculations

When the PhAS scheme was initially introduced in 2016, payments were calculated as a top-up to provide an equivalent overall payment to account for the funding reduction for each pharmacy’s 2015 payments, taking into account a small efficiency saving.

For the 2022 PhAS, payments will not be calculated as a top-up to the 2015 payment. A new payment allocation model has been developed to encourage growth for smaller pharmacies and minimise reliance on this additional support for larger pharmacies that are able to remain viable through the provision of NHS pharmaceutical services.

The PhAS payments are based on a pharmacy’s 2019 to 2020 number of SAF payments. For pharmacies that opened after March 2019, a mixture of scaling and data from following months was utilised to get a full 12 months.^{[footnote 5]}

All pharmacies eligible for the 2022 PhAS must have received between 1,200 and 104,789 SAF payments in 2019 to 2020. The pharmacies at the mid-points of this range (2019 to 2020, between 45,000 to 65,000 SAF payments) will receive the maximum PhAS payment, and the smallest and largest pharmacies will receive the lowest payments.

The maximum 2022 PhAS payment is based on the average annual PhAS payment in the previous scheme (£17,500). All pharmacy contractors are placed in bands based on the 2019 to 2020 number of SAFs paid as per Figure 1.

Figure 1: 2022 PhAS payment structure

PhAS payments for each band are presented in Table 1.

Table 1: PhAS payment bands

Lower bound (number of SAFs 2019 to 2020)	Upper bound (number of SAFs 2019 to 2020)	Yearly PhAS payment £	Monthly PhAS payment £
1,200	2,500	1,312.56	109.38
2,501	5,000	3,500.04	291.67
5,001	10,000	6,562.56	546.88
10,001	15,000	9,187.56	765.63
15,001	20,000	11,375.04	947.92
20,001	25,000	13,125.00	1,093.75
25,001	30,000	14,437.56	1,203.13
30,001	35,000	15,312.48	1,276.04
35,001	40,000	16,187.52	1,348.96
40,001	45,000	17,062.56	1,421.88
45,001	50,000	17,499.96	1,458.33
50,001	55,000	17,499.96	1,458.33
55,001	60,000	17,499.96	1,458.33
60,001	65,000	17,062.56	1,421.88
65,001	70,000	16,187.52	1,348.96
70,001	75,000	15,312.48	1,276.04
75,001	80,000	14,437.56	1,203.13
80,001	85,000	13,125.00	1,093.75
85,001	90,000	11,375.04	947.92
90,001	95,000	9,187.56	765.63
95,001	100,000	6,562.56	546.88
100,001	102,500	3,500.04	291.67
102,501	104,789	1,312.56	109.38

The 2022 PhAS eligibility review process

A review process has been developed by NHSE&I to allow for consideration of extenuating circumstances in relation to the distance mapping which may have resulted in a pharmacy being classified as not eligible for 2022 PhAS and access not being protected as the scheme intended.

NHSE&I will manage the 2022 PhAS eligibility review process. The review processes will be managed by NHSE&I regional pharmacy contracts teams.

The only grounds on which it is possible to apply for a review of the 2022 PhAS eligibility are restricted to either or both of the following distance criteria:

• inaccuracies in pharmacy premises location (for example if the pharmacy address was incorrect or the distance from the next pharmacy was calculated incorrectly)
• physical feature anomalies (such as a semi-permanent roadblock or a steep hill) meaning the viable route between 2 pharmacies is not as represented in the modelling

It is not possible to apply for a review of eligibility to NHSE&I on any other grounds (that is, the eligibility criteria outlined above). Contractors who do not meet the SAF payment criteria are not eligible to apply for review.

The review application window for contractors to submit applications is between 04 January 2022 and 04 March 2022. Subject to the overall number of applications received, it is envisaged that all contractors will have been informed about the outcome of their review by the end of May 2022.

Contractors wishing to apply for review are required to draw on the mapping analysis undertaken as described above and the data held in the mapping portal. Distance calculations using other maps (for example, Google Maps) will not be accepted.

Contractors wishing to apply for review are required to provide evidence of an incorrect premises address or physical anomaly along the mapped route.

Contractors who participated in the review process as part of the 2016 scheme and who were successful in gaining access to the scheme owing to the physical anomaly may not automatically qualify for the 2022 scheme. Contractors should check that they do meet the revised eligibility criteria and may then reapply via the 2022 PhAS review process. Contractors can use the evidence previously submitted, including copies of the letter confirming that the previous application for review was successful.

Contractors wishing to apply for a review are required to do so via a dedicated portal (details of which will be shared prior to the opening of the review application window in the individual letters which will be sent to contractors). Contractors will be required to upload the evidence to support their application on the portal and will only be able to submit an application if they meet the dispensing volume and other eligibility criteria of the 2022 PhAS.

Completed applications will be reviewed by the relevant NHSE&I regional pharmacy contract team who manage pharmaceutical list for the Health and Wellbeing Board area where the pharmacy premises are listed.

The outcome of the review will be determined by the relevant Pharmaceutical Services Regulations Committee (PSRC).

NHSE&I regional pharmacy contract teams will communicate the outcome of the application. Contractors who are deemed to be eligible for the 2022 PhAS will be added to the scheme and payments will be backdated to 1 January 2022.

Annex A: 2022 PhAS eligibility

This is a brief explanation of PhAS eligibility. Please refer to the guidance for more detail.

Figure 2: PhAS eligibility

1. The analysis to establish walking distances between pharmacies is underpinned by the UK national mapping agency Ordnance Survey (OS) mapping products for official addressing (OS AddressBase) to locate pharmacies from address details, and for highways routing networks (OS MasterMap Highways Network Roads and Paths) datasets to create the walking routes. The respective datasets were the versions extracted on 31 March 2021 according to OS product revision cycle for each dataset. The analysis to generate the walking routes between pharmacies was undertaken using the ESRI ArcGIS software products ArcGIS Pro and related Network Analyst Extension. ↩

2. Based on the National Statistics English indices of deprivation 2019. ↩

3. Based on the number of SAFs paid and not the number of items dispensed. ↩

4. For openings during 2019 to 2020, we scale the 2019 to 2020 dispensing volume to reflect a full year. For openings during 2020 to 2021, we scale the 2020 to 2021 dispensing volume to reflect a full year and use this as a proxy for 2019 to 2020. ↩

5. For openings during 2019 to 2020, we scale the 2019 to 2020 dispensing volume to reflect a full year. For openings during 2020 to 2021, we scale the 2020 to 2021 dispensing volume to reflect a full year and use this as a proxy for 2019 to 2020. ↩