Project Overview
A UK pharmacy group with 280 branches and 1.2 million NHS prescription patients wanting to build an online NHS...
Technology Stack
Compliance & Standards
The Challenge
A UK pharmacy group with 280 branches and 1.2 million NHS prescription patients wanting to build an online NHS pharmacy — allowing patients to order NHS repeat prescriptions online, track dispensing status, and receive delivery or click-and-collect. NHS EPS (Electronic Prescription Service), CQC registration (distance selling pharmacy), GPhC (General Pharmaceutical Council) online pharmacy standards, FMD (Falsified Medicines Directive — DSCSA UK equivalent), UK GDPR Article 9, and WCAG 2.1 AA were the requirements. Budget: £130,000.
Our Approach
NHS EPS Release 2
patient nominates the online pharmacy as their nominated dispensing contractor (via NHS App or GP surgery).
Electronic prescription
GP practice creates EPS prescription (coded in FHIR R4 MedicationRequest with dm+d drug code) → transmitted to NHS Spine → online pharmacy downloads outstanding prescriptions for their nominated patients.
Dispensing notification
pharmacy dispenses prescription → EPS dispensing notification submitted to NHS Spine (confirms prescription dispensed).
EPS claim
monthly submission to NHS BSA for reimbursement.
CQC registration
online pharmacies are regulated as distance selling pharmacies (DSP) — separate CQC registration from physical pharmacy.
CQC DSP standards
superintendent pharmacist oversight, patient consultation access (pharmacist available by telephone, video, or secure messaging), emergency supply arrangements, and privacy of patient health data.
Platform
superintendent pharmacist consultation request workflow (patient triggers request → available pharmacist notified → video/phone consultation scheduled via Doxy.me).
GPhC online pharmacy standards
- internet pharmacy logo, legal compliance statement, superintendent pharmacist displayed.
- FMD (Falsified Medicines Directive)
UK
UK FMD (Falsified Medicines Directive — implemented post-Brexit as UK Medicines Verification System, UKMS): all prescription medicines must have a 2D barcode (DataMatrix) verified at point of dispensing.
Platform integration
FMD verifier at dispensing → UKMS API (Arvato — UK FMD operator) → unique identifier verified as authentic → status updated to "dispensed".
FMD alert
alert if medicine decommissioned (verified dispensed elsewhere), recalled, or unverifiable.
FMD audit
all verifications logged for MHRA and UKMS audit.
NHS prescription data
medication data is Article 9 special category (health data).
Legal basis
Article 9(2)(h) — provision of health or social care.
NHS EPS data retention
- dispensing records retained 2 years (NHS EPS technical standard).
- Patient-controlled deletion: patient can withdraw EPS nomination (stops new prescriptions — historical dispensing records retained per NHS retention requirements).
Prescription data access
patient can view their own dispensing history.
Superintendent pharmacist audit log
every pharmacist access to patient records logged.
The Results
CQC distance selling pharmacy registration obtained.
GPhC standards compliance confirmed.
Platform live at 18 weeks, £122,000 — under budget.
NHS EPS nominations: 84,000 in first 6 months.
Online prescription orders: 320,000 in first 6 months.
FMD verification: 100% compliance (zero unverified dispensings).
EPS monthly BSA claim: automated — previously 2 days.
WCAG 2.1 AA: zero non-compliances.
Patient satisfaction: 4.6/5.
NHS BSA payment error rate: 0.2% (industry benchmark: 3.4%).
“84,000 EPS nominations and 320,000 prescriptions in 6 months. FMD 100% compliance — zero unverified dispensings. NHS BSA payment error rate 0.2% versus 3.4% benchmark. Patient satisfaction 4.6 out of 5. The CQC and GPhC compliance work was the hardest part — ClickMasters navigated it without a single regulatory issue." — Head of Digital, UK Pharmacy Group (name withheld)”
Project Details
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