Key Summary
- The new amendment will enable hub and spoke dispensing between separate community pharmacy businesses
- To carry out such hub and spoke dispensing, contractors must comply with certain requirements
- The spoke contractor must ensure that the owner of the hub pharmacy is fit to carry out the core dispensing functions on their behalf
- The spoke contractor should give notice to their integrated care boards (ICB) of the hub and spoke arrangements and seek their approval
The new hub and spoke dispensing Terms of Service (The National Health Service (Pharmaceutical and Local Pharmaceutical Services) (Miscellaneous Amendments) Regulations 2025) were laid before parliament.
On October 1, the new Terms of Service come into force, along with the Human Medicines Regulations 2012 (HMR) hub and spoke changes announced in April this year.
The two complement each other and apply to owners of NHS spoke pharmacies/contractors, while a different legal entity owns the hub pharmacy.
Hub-and-spoke dispensing is currently only allowed between pharmacy locations belonging to the same owner or legal entity.
The new amendment will enable hub-and-spoke dispensing between separate community pharmacy businesses.
To carry out such hub-and-spoke dispensing, contractors must comply with certain requirements.
They should not subcontract ‘core dispensing activities’ (broadly the assembly or part assembly of any prescription item, which includes labelling and bagging) unless certain conditions are met.
The spoke contractor must take reasonable steps to ensure that the owner of the hub pharmacy is a fit and proper person to carry out the core dispensing functions on their behalf and do this before entering into the hub and spoke arrangements.
They should make sure that the hub owner has suitably qualified and trained staff, has appropriate indemnity cover, and a business continuity plan.
The spoke contractor should give notice to their integrated care boards (ICB) of the hub and spoke arrangements (using the NHS England-approved written notification form) not less than 28 days before the hub and spoke arrangements are intended to commence.
The contractor may commence the hub and spoke arrangements if there is no objection from the ICB within those 28 days.
The spoke contractor should ensure the core dispensing functions are to be sub-contracted under written hub and spoke arrangements with the hub pharmacy owner.
The written arrangement should provide a comprehensive statement of the responsibilities of the spoke and the hub for the core dispensing activities.
There should be a provision that the hub will assemble or part-assemble patients’ prescribed medicines, and these will be dispensed/supplied at or from the spoke.
The arrangements must not allow the hub to fulfil the order directly to the patient.
A data sharing agreement between the parties, setting out the prescription data that will be shared between the spoke and hub (and that the data must be in accordance with the relevant NHS England information standard once it is published).
A clear exit clause so that the spoke can discontinue the hub and spoke arrangements (sub-contracting agreement) at the request of the ICB.
A provision that the hub may not further sub-contract any of the core dispensing functions that they perform on behalf of the spoke.
There should be a confirmation that the spoke has a business continuity plan which contains provisions specific to the hub and spoke arrangements that will seek to enable them to continue provision to patients/resume provision to patients as required following any temporary or permanent discontinuation or disruption of the service provision by the hub.
A requirement for the hub to cooperate in any investigations by the spoke, commissioner, or regulatory body in relation to any issue or incident arising from the sub-contracted functions.
There is provision for ICBs to raise objections to proposed hub and spoke arrangements by issuing a relevant notice, for dispute resolution with the contractor, and, at the contractor’s request, the involvement of the LPC.
If the ICB issues a notice of objection, the contractor must not commence the hub and spoke arrangements until or unless that notice is withdrawn.
