Community pharmacy has spent the past two years adapting to a fundamental change in its role. Pharmacy First has moved pharmacists further into the assessment and management of clinical conditions, requiring them to identify red flags, apply clinical pathways, make treatment decisions and determine when patients need onward referral.
Until now, much of the conversation has understandably focused on delivery: how many consultations pharmacies are providing, how patients can access the service and how Pharmacy First can relieve pressure elsewhere in the NHS.
NHS England's newly published Pharmacy Quality Scheme (PQS) 2026/27 clinical services audit introduces another important dimension to that conversation. The focus is not simply on whether a Pharmacy First consultation has taken place, but on whether the clinical record adequately demonstrates what happened during it.
That may sound like a relatively small change. I believe it represents something much bigger.
As community pharmacy becomes more clinically responsible, it is also entering an era in which the reasoning behind clinical decisions will increasingly need to be visible, structured and auditable.
What is changing?
Under Domain 2: Professional Practice of the 2026/27 PQS, participating contractors are required to undertake a clinical audit of Pharmacy First clinical pathway consultation records.
The audit applies across the seven Pharmacy First clinical pathways and is designed to assess the quality and completeness of the clinical record. Contractors undertaking the domain must audit at least 10 unique patients and subsequently discuss their findings with pharmacy professional peers, identify improvements and submit their anonymised results through the Manage Your Service platform by 31 March 2027.
Importantly, NHS England has set a 100% standard for each of the seven record elements being assessed.
The detail of those elements matters because they go to the heart of what constitutes a meaningful clinical record.
NHS England expects records to provide enough information for another healthcare professional to understand why the patient was eligible for the pathway, what was established during the assessment, why the eventual treatment decision was reached and what safety-netting advice was provided. The audit also considers other aspects of the consultation record, including safeguarding.
These are not simply boxes that need to be completed. Collectively, they demonstrate the clinical reasoning that sits behind the pharmacist's decision.
Recording an outcome is not the same as recording clinical reasoning
There is an important distinction here.
A record showing that a medicine was supplied tells us the outcome of a consultation. It does not necessarily tell another healthcare professional why that outcome was appropriate.
A meaningful clinical record needs context. What symptoms did the patient present with? Were relevant exclusion criteria considered? Were there red flags? What did the assessment establish? Why was treatment considered appropriate? What was the patient told to do if their symptoms persisted or deteriorated?
That information becomes increasingly important as community pharmacy moves beyond transactional services and further into clinical care.
Pharmacists have always exercised professional judgement, but the expansion of services such as Pharmacy First means that this judgement is increasingly being exercised in areas that would historically have resulted in a GP consultation.
The record therefore becomes part of continuity of care. Another healthcare professional should be able to look at it and understand not simply what the pharmacist did, but why.
Pharmacy technology needs to catch up with pharmacy practice
There is a wider challenge behind the new audit.
Many of the digital systems used in community pharmacy were originally designed around medicines supply. They are exceptionally good at recording transactions: a prescription was received, an item was dispensed, a service was completed or a claim was submitted.
Clinical consultations create a different requirement.
When a pharmacist assesses a patient with a suspected urinary tract infection, sore throat or infected insect bite, for example, the important information is not simply the eventual outcome. It is the sequence of information and decisions that led to that outcome.
Our technology therefore needs to evolve alongside the profession.
The answer cannot simply be to give pharmacists increasingly sophisticated clinical responsibilities and then add more documentation for them to complete afterwards. Anyone who has worked in a busy community pharmacy knows how unrealistic that can become.
Instead, clinical documentation needs to be designed into the consultation itself.
If the workflow naturally captures eligibility, presenting symptoms, relevant history, clinical findings, red flags, treatment rationale and safety-netting as the consultation progresses, the record becomes a product of good clinical practice rather than an administrative exercise performed after it.
That distinction may seem subtle, but it could have a considerable impact on both record quality and pharmacist workload.
Independent prescribing makes this even more important
The timing of this development is particularly significant.
From September, newly qualified pharmacists joining the GPhC register will be independent prescribers from the point of registration. At the same time, the NHS continues to explore how prescribing can become a greater part of community pharmacy services.
The direction of travel is therefore clear. Pharmacists are being given greater clinical autonomy and will increasingly make decisions about diagnosis, treatment and prescribing.
Greater autonomy inevitably brings greater accountability.
This should not be seen negatively. It is a natural consequence of community pharmacy becoming a more clinically integrated part of the NHS.
However, it does mean that the systems surrounding pharmacists must be capable of supporting this new level of responsibility.
Clinical records will need to demonstrate the basis upon which decisions were made. Governance will become increasingly important, as will consistency, auditability and the ability for other healthcare professionals to understand the pharmacist's reasoning.
Where does artificial intelligence fit?
This also raises an important question about the rapid emergence of artificial intelligence in pharmacy.
There is understandable excitement about what AI might do for pharmacists. Large language models can summarise information, generate text and assist with increasingly complex knowledge tasks.
But simply placing an AI assistant beside a pharmacist does not necessarily solve the problem.
If the pharmacist uses AI to obtain information but must then move to another system to complete the consultation, another to document the clinical reasoning and perhaps another to submit the service, we risk adding technology without actually improving the workflow.
The opportunity for AI in pharmacy is much greater when we start with the clinical process rather than the technology.
I have seen this first-hand while developing PharmBot AI. One of the principles behind our work has been that AI should sit within a structured clinical workflow, with the pharmacist retaining responsibility for the final decision. The objective is not to have AI "make" the clinical decision, but to help ensure that the information required to make and document that decision is available at the right point in the consultation.
This distinction will become increasingly important as AI enters regulated clinical environments.
The question we should be asking is not simply, "What can the AI do?" It is whether the system improves the safety, consistency and accountability of the clinical process while keeping the healthcare professional in control.
Documentation should not become another burden
There is a danger that the profession responds to increasing accountability by simply creating more forms, more mandatory fields and more administrative requirements.
That would be the wrong lesson to take from the new PQS audit.
Good clinical documentation is essential, but achieving it should not depend upon pharmacists remembering at the end of a busy consultation to reconstruct everything that happened.
Technology should make the correct way of working the easiest way of working.
A well-designed clinical system should guide the pharmacist through the relevant considerations and capture the resulting information as part of that process. By the time the consultation is completed, the clinical record should largely already exist and be ready for pharmacist review.
That is very different from treating documentation as a compliance exercise.
A sign of what comes next
The significance of NHS England's Pharmacy First audit extends beyond the 2026/27 PQS.
It provides an indication of what a more clinically mature community pharmacy service will require.
For the first phase of Pharmacy First, the challenge was establishing the service, creating public awareness and enabling pharmacies to deliver consultations at scale. As the service matures, attention will inevitably turn increasingly towards quality, consistency, clinical outcomes and the evidence supporting individual decisions.
That is a positive development for the profession.
But it also means we need to think carefully about the infrastructure pharmacists will require to practise in this environment.
Community pharmacy cannot move towards independent prescribing, increasingly complex clinical services and greater integration with the wider NHS while relying indefinitely on technology primarily designed for a transactional model of pharmacy.
The clinical role has changed. The digital infrastructure supporting that role now needs to change with it.
The 2026/27 Pharmacy First clinical audit may appear to be a relatively modest PQS requirement, but it reflects a much larger transition. The future of community pharmacy will not simply be about whether a consultation was delivered. Increasingly, it will also be about whether the clinical record clearly demonstrates what was assessed, what was decided, why that decision was made and what happened next.
For a profession taking on greater clinical responsibility, that is not bureaucracy. It is part of what good clinical practice now looks like.
Asif Mukhtar is a UK pharmacist and Founder of PharmBot AI, a healthcare technology company developing AI infrastructure for pharmacy practice.
Reference: NHS England, Pharmacy Quality Scheme 2026/27: Clinical Services Audit – Pharmacy First Clinical Pathways Consultations, published 26 August 2026.
