It was revealed on 8th April 2020 that in an effort to focus NHS England regional team efforts where they are needed most, Primary Care Support England would be temporarily suspending all new market entry, market exit and consolidation applications, backdated to 25th March 2020. This is owing to the unprecedented impact of the coronavirus pandemic. 

Market Entry is the process by which all pharmacies in England gain approval by the NHS to join the Pharmaceutical lists; full details of the temporary measures can be found on the PCSE / NHS England website here.

Pharmacy owners will find that all unapproved applications will be temporarily suspended, and we’re not sure how long this will last for. This will affect all applications including fitness to practise, change of ownership, relocation and consolidation. 

It is likely that applications which have already been approved will not be affected by this recent change. Any ‘notice of commencement’ activity by new contractors should be processed as usual, however this may change at short notice.

It seems that share sale transactions in the pharmaceutical sector should mostly not be affected by the changes, as market entry applications are not normally an obligation for transactions if a company is already included on the pharmaceutical list.

If you need advice about any uncertainty you’re facing owing to coronavirus, please do not hesitate to get in touch.

This note comprises the view of the author at the time written. This note is not a substitute for legal advice. Information may be incorrect or out of date and may not constitute a definitive or complete statement of the law or the legal market in any area. This note is not intended to constitute advice in any specific situation. You should take legal advice in specific situations. All implied warranties and conditions are excluded, to the maximum extent permitted by law.