Published 28 October 2021
Key findings
The Prescription Processing Information Accuracy (PPIA) of the 600,000 prescription items that are checked as part of the NHSBSA published figures on accuracy in 2019/20 is 99.89% which is above the target of 99.60%.
The published Absolute Cash Variance (ACV) for prescriptions in 2019/20 was 99.86%. In the same year the ACV for prescription batches checked outside of routine assurance procedures was 99.88%.
In 2019/20 Post Payment Verification identified £44,700 (0.07% of the total paid) of over payment for Medicine Use Review and £23,700(0.10% of the total paid) of over payment for the New Medicines Service.
Payments for claims above the set threshold of 400 Medicine Use Reviews per year per contractor, resulted in a reclaim of £608,000 out of a total of £62.0 million paid to contractors.
The routine checking procedures and post payment verification activities carried out by NHS Prescription Services do not identify errors that significantly impact the accuracy of the General Pharmaceutical Services – England National Statistics publication. However, the NHS Business Services Authority (NHSBSA) will take steps communicate the uncertainty in the statistics to users more clearly.
1. Introduction
1.1 Background
The NHS Business Services Authority’s (NHSBSA) General Pharmaceutical Services – England National Statistic release was assessed from April 2021 to July 2021 by the Office for Statistics Regulation (OSR) to determine if it fully complied with the Code of Practice for Statistics, and met the highest standards of trustworthiness, quality, and public value.
The OSR identified 4 requirements for NHSBSA to address in order to ensure the high standards associated with National Statistics designation are met. The OSR Assessment report can be found on its website.
Two of the requirements identified by OSR to support the pillar of Quality within the Code of Practice of Statistics were:
• NHSBSA should ensure that the degree of uncertainty in the figures is clearly explained within the publication to ensure appropriate use.
• NHSBSA should explore the impact of checks made as part of the prescriptions processing procedure on the accuracy of the statistics and determine whether any adjustments to the statistics are needed. Depending on the findings of these investigations, NHSBSA should either make any necessary changes to the statistics and explain these changes and the reasons for them clearly to the users or communicate clearly to users the accuracy of the statistics and the sources of any uncertainty.
This report is intended to give users a better understanding of the uncertainty within the statistics, while also providing details on the impacts of post payment verification (PPV) and errors identified as part of checks carried out during prescription processing.
1.1.1 Monthly Accuracy Checks
The NHSBSA publish the results of the checks carried out during the processing of prescriptions. However, errors identified during these checks are not reflected within the General Pharmaceutical Services – England publication. This checking process involves reprocessing a random sample of 50,000 prescriptions on a monthly basis to estimate the accuracy of prescription processing. In a 12-month period a sample of 600,000 prescription items are reprocessed out of approximately 1.1 billion.
Data is published on Prescription Processing Information Accuracy (PPIA), Prescription Processing Payment Accuracy (PPPA), Net Cash Variance (NCV) and Accuracy of Absolute Cash Variance (ACV). The most recent accuracy figures can be found on the NHSBSA website.
The PPIA reflects the accuracy of prescribing information that is captured from the prescription form. The PPPA reflects the accuracy of information captured from the prescription form that also impacts payments that have been made to dispensing contractors. If an error in capture does not affect the financial payment made to a contractor this will not be reflected in the PPPA, all identified errors are reflected in the PPIA. For example, if an incorrect drug was captured from a prescription form it would be reflected in the PPIA. However, if this drug had the same monetary value as the correct drug, then this has not impacted the payment made to the dispensing contractor and will not be reflected in the PPPA.
The measure NCV reflects the accuracy of the overall drugs bill for prescription items dispensed in the community in England. NCV is calculated by dividing the reimbursement value of the reprocessed sample of prescription items by the actual value reimbursed to dispensing contractors displayed as a proportion.
NCV = 1- (Sum of monthly NET error values in the 12-month rolling period/Sum of the monthly value of items sampled for the 12-month rolling period).
Some errors will be overpayments and others will be underpayments, the NCV measure nets off under and overpayments. A negative NCV indicates an underpayment and a positive NCV indicates an overpayment. Ideally, the measure should be as close to 100% as possible, but with a tolerance of +/- 0.2%.
Absolute Cash Variance (ACV) aggregates under and overpayments, where NCV nets off underpayments against overpayments, ACV. This measure provides an absolute monetary indication of the financial accuracy of prescription processing.
Variance against ACV will always be wider than NCV. ‘Absolute’ indicates all values are positive. For example, the absolute value of £2.34 is £2.34, but the absolute value of £-2.34 is also £2.34.
The ACV is defined through the following: the sum of the monthly absolute error values for 2019/20 divided by the sum of the monthly value of items sampled for 2019/20, then subtracted from 1.
ACV = 1- (Sum of the monthly absolute error values for 2019-20/Sum of the monthly value of items sampled for 2019-20).
Additional checks are carried out beyond the monthly checking which must also be considered to understand the uncertainty within the statistics.
1.1.2 Arrangements for Contractors Concerning Prescription Pricing Errors
As laid out in Part XIVB of the Drug Tariff, a contractor who thinks there is an issue with their monthly payment can ask the NHSBSA, in writing, to recheck a month or specific months’ prescriptions.
To ensure that adjustments fairly reflect both underpayments and overpayments, the NHSBSA will select an equivalent number of additional months to check, where appropriate. Using the results:
• Where a net underpayment is revealed, the contractor will be paid the value of the underpayment.
• Where a net overpayment is revealed, the NHSBSA will recover the value of the payment.
Once the 18-month deadline for requesting a check has elapsed, for example 31 October 2021 for prescriptions dispensed in April 2020, no further requests can be made for that particular month.
As well as requested checks from contractors, a number of random checks are undertaken each month with a minimum of 56 complete batches being checked each month.
These random rechecks may not relate to the processing month in which they are carried out as batches can be selected from any of the previous 18 months that the NHSBSA retain. However, the results of these checks are reported against the month that they were carried out.
1.1.3 Post Payment Verification for Advanced Services.
There are several Advanced Services within the NHS Community Pharmacy Contractual Framework (CPCF). Community pharmacies can choose to provide any of these services as long as they meet the requirements set out in the Secretary of State Directions. The data held by the NHSBSA relates to claims made by contractors which may not relate to activity carried out. The NHSBSA undertakes provider assurance activity and post-payment verification (PPV) on advance services provided by contractors to check on this activity. This report looks at three advanced services which are included in the General Pharmaceutical Services publication and the provider assurance carried out for these services.
• Seasonal influenza vaccination advanced service
• Medicines Use Review Service (MUR)
• New Medicines Service (NMS)
Post Payment Verification was put on hold in March 2020 due to the Coronavirus (COVID-19) pandemic.
Data for PPV is held for the period at which it was reclaimed and not for the period in which the activity was undertaken.
The provider assurance activity is undertaken by the NHSBSA to deter and identify any inappropriate claims or issues that can be collaboratively remedied. This involves requesting evidence from a sample of contractors to support the payment claims they have submitted for Advanced Services over a specific three-month period.
The evidence requested will be the signed patient consent forms for the service that correspond to the payment claims made. Contractors will be asked to submit the requested forms with their next monthly prescription bundle.
Contractors are reminded that a consent form signed by the patient is a prerequisite for undertaking an Advanced Service such as a MUR or NMS. These forms include the permission from the patient that they can be shared with NHS England, NHSBSA and the Secretary of State for Health to make sure the pharmacy is being correctly paid by the NHS for the service provided.
The NHSBSA will review the submitted forms against the payment claims received for the period, checking for duplicates and that the dates are within the correct period, and will share their findings with the contractor. If there appears to be missing evidence, the NHSBSA will discuss this with the contractor, and they will be asked if they can provide alternative evidence that the service was provided such as a Pharmacy Management Records (PMR) summary.
Once NHSBSA’s findings are agreed with the contractor, information will be shared with the relevant Sustainability and Transformation Partnership (STP). Where necessary, the STP will contact the contractor to discuss the findings. The original consent forms submitted by contractors will be returned to them once the NHSBSA has finished reviewing them.
The NHSBSA will request evidence to support payment claims using a combination of targeted and random sampling which means that any pharmacy could be selected. Information will be shared with the regional team to inform them of the performance of selected accounts in their area.
The sampling methodology will cover the following:
• Outliers (metrics)
• Random Stratified
• Requested or Targeted
• Follow up from previous PPV
Data held for PPV reports on the amount claimed but not the value of the services that have been sampled for this process.
1.1.4 Claim threshold for Advanced Services.
Some advanced services have limits on the maximum number a pharmacy can provide and be paid for. The NMS threshold relates to the monthly volume of dispensed items and varies between 10 and 100 per month. MURs have a set threshold for the financial year. The yearly threshold and monthly claim system allows for pharmacies to submit more claims than the threshold and where this happens the NHSBSA will reclaim this money unless an exception is agreed with NHS England.
1.2 Scope
Due to a hold on provider assurance activity and post-payment verification during the COVID-19 pandemic, data from the 2019/20 processing period will be used in this report.
Post-payment verification is still being carried out for both the 2019/20 and 2020/21 periods for the services mentioned in this report as well as for additional services and for some services that were introduced as part of the COVID-19 pandemic. A further examination of the impact of this work may be possible in future.
2. Findings
The charts in these statistics are interactive and allow you to isolate the topics that you are interested in by selecting or deselecting a series from the legend of the chart. For example, if you only want to view data for reclaimed or adjusted fees, you can click the other categories in the legend of the chart to deselect them. If you wish to include them again just click on their legend entry once more.
2.1 Monthly Accuracy Checks
Data on the most recent monthly accuracy check measures are published on the NHSBSA website.
The 12-month rolling averages for the published accuracy measures in 2019/20 are shown in table 1.
Table 1: Published Prescription Accuracy Measures for 2019/20
2.2 Arrangements for Contractors Concerning Prescription Pricing Errors
In 2019/20 874 batches were rechecked, 150 at the request of the contractor and 724 at random. The data held from these rechecked batches has both the financial net adjustment and absolute adjustment for each rechecked contractor. This process captures the absolute and net financial value of any errors and the total account value for the rechecked batch. It does not capture the number of errors or items per batch which means it has not been possible to calculate the measures PPIA or PPPA for these rechecks, but we can calculate both the ACV and NCV.
This report considers the ACV when looking at the accuracy of the data.
In 2019/20, out of the prescription items checked with a value of £54.9 million, total absolute adjustments of £68,300 were made.
The ACV for rechecked batches in 2019/20 is 99.88%. This is in line with the ACV determined by the NHSBSA monthly accuracy checks
Both the monthly checks and the rechecked batches have similar ACV results for 2019/20 though these are different assurance procedures on different processed prescription data with different sample sizes. Both ACVs are above the target for 2019/20 (99.70%) and the target for the current financial year (99.80%).
Figures 1 and 2 show the monthly breakdown of the ACV in 2019/20. Figure 2 has an abbreviated y axis focused above 99% to allow visibility of the variation over time - which is small. The ACV for rechecked batches was above the target for ACV for every month in 2019/20.
2.3 Post Payment Verification for Advanced Services.
2.3.1 Flu Vaccination Service
Community pharmacy has been providing flu vaccinations under a nationally commissioned service since September 2015.
Each year from September through to March the NHS runs a seasonal flu vaccination campaign aiming to vaccinate all patients who are at risk of developing more serious complications from the virus. This service was made available via community pharmacy to improve accessibility as pharmacies have extended opening hours and walk-in options.
As part of the service specification, contractors are required to gain patient consent for each influenza vaccine prior to the vaccine being administered. Contractors should gain written patient consent regardless of whether the claim is made by paper or online.
The NHSBSA undertakes provider assurance activity to deter and identify any inappropriate claims or issues that are collaboratively remedied. This involves calls and emails made to contractors 6 months after the previous year’s scheme has ended as claims are eligible 6 months after the dispensing month, requesting patient consent forms be included in the pharmacy’s prescription batch. Consent forms are processed and the results of the PPV are reported back to the corresponding regional teams and NHS England & NHS Improvement central team.
Flu Vaccination PPV started in March 2020 and was then put on hold due to the COVID-19 Pandemic so there is insufficient data to be included in this report.
2.3.2 Medicines Use Reviews
The Medicines Use Reviews (MUR) service was an Advanced Service within the NHS Community Pharmacy Contractual Framework, the service was decommissioned on 31 March 2021. It was a structured review that was undertaken by a pharmacist to help patients to manage their medicines more effectively.
The MUR involved the pharmacist reviewing the patient’s use of their medication, ensuring they understood how their medicines should be used and why they have been prescribed, identifying any problems and then, where necessary, providing feedback to the prescriber. An MUR Feedback Form was provided to the patient’s GP where there was an issue for them to consider.
The fee for providing the MUR was set out in Part VIC of the Drug Tariff and claimed via the FP34C Submission Form. The fee for provision of an MUR was £28.
2.3.2.1 Medicines Use Reviews PPV
Data is not held on the number or value of services subject to PPV only the amount reclaimed. Therefore, we can only report on the percentage of the total value reclaimed by PPV. In 2019/20 a value of £44,700 for MUR was reclaimed under the PPV process out of a total of £62.0 million paid to contractors for MUR. This is 0.07% of the total paid to contractors for this service.
2.3.2.2 Medicines Use Reviews Over threshold
The Drug Tariff Part VIC states that contractors are able to claim payment for up to a maximum of 250 MURs from 1 April 2019 to 31 March 2020.1 The NHSBSA monitor this on a monthly basis and recover monies from contractors who exceed the yearly target. The recoveries are applied, and the contractor notified. If the contractor continues to over claim through the year the same recovery process would apply. The only exception to this would be if NHS England agreed, as part of the individual’s contract, that the contractor could carry out more MURs to assist with service provision in the area.
This process runs alongside the contractors sampled for PPV. Only data on the total value reclaimed via this process is held.
In 2019/20 a value of £608,000 for MUR was recovered under the yearly target process out of a total of £62.0 million paid to contractors for MUR. This is 0.98% of the total paid to contractors for this service.
1. This was reduced to a maximum of 100 from 1 April 2020 to 31 March 2021.
2.3.3 New Medicines Service
The New Medicine Service (NMS) is an Advanced Service within the NHS Community Pharmacy Contractual Framework. The service provides support for people with long-term conditions newly prescribed a medicine to help improve medicines adherence; it is focused on specific patient groups and conditions. Details of the currently covered patient groups can be found in the NHS England Service Specification.
The fee for NMS varies between £20 and £28 depending on the volume of prescriptions dispensed by a contractor and the number of NMSs undertaken.
Data is not held on the number or value of services subject to PPV only the amount reclaimed. Therefore, we can only report on the percentage of the total value reclaimed by PPV. In 2019/20 a value of £23,700 for NMSs were reclaimed under the PPV process out of a total of £24.4 million paid to contractors for NMS. This is 0.10% of the total paid to contractors for this service.
3. About this report
This report is an ad-hoc publication using data from the NHSBSA provider assurance and checking processes to explore the impact of checks made as part of the prescriptions processing procedure on the accuracy of the statistics published in the General Pharmaceutical Services – England National Statistic release.
Scope
Although intended as a singular ad-hoc report, delays to PPV processes due to the COVID-19 pandemic allow scope for further analysis when these processes return to normal. The NHSBSA will assess how best to inform users of our statistics of the impact of ongoing PPV activities and any other provider assurance activity and how to communicate this in the future releases.
4. Statistical Disclosure Control
The high-level figures in this report have been rounded where appropriate for clarity, in most cases to three significant figures. This is to make this narrative as accessible as possible to all readers.
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