Dear Matthew 

Confirmation of National Statistics designation for Statistics on General Pharmaceutical Services in England 

We have reviewed the actions that your team has taken to address the requirements in Assessment Report number 359: Statistics on General Pharmaceutical Services in England. I would like to commend you and your team’s engagement with us during the assessment, demonstrating your commitment to improving the statistics for the public good. 

On behalf of the Board of the UK Statistics Authority, I am pleased to confirm the designation of National Statistics for Statistics on General Pharmaceutical Services in England, produced by the NHS Business Services Authority. The statistics prove a valuable, trusted source of information about services that community pharmacies and appliance contractors provide, along with some of their associated costs 

Following on from your first assessment of Prescription Cost Analysis statistics in 2020, you and your team continued to show great enthusiasm and ambition throughout the process. We were particularly impressed with your commitment to understanding more about uncertainty in relation to the statistics and explaining this to your users. We have included more detail around our judgement in an annex to this letter. 

I am copying this letter to Michael Brodie, CEO of NHSBSA, and to Lucy Vickers, Head of Profession for Statistics at the Department for Health and Social Care. 

Yours sincerely  

Ed Humpherson 

Director General for Regulation 


Annex: Review of actions taken in response to Assessment Report number 359: Statistics on General Pharmaceutical Services in England

Requirement 1:

NHSBSA should improve the supporting summary tables to make them more user friendly and easier to extract data from. It should consult with users on any planned changes to ensure that the tables better meet users’ needs. 

Actions taken by NHSBSA to meet Requirements

NHSBSA have redesigned table 1 to split it into 2 tables. Table 1 now relates to the counts of dispensing contractors and the attributes that they hold, while table 2 shows information relating to costs, volumes, and fees payable to contractors for carrying out essential and advanced services. They’ve also implemented the GSS guidelines on releasing statistics in spreadsheets to make the summary tables more accessible and machine readable.  NHSBSA have used existing user feedback to guide development of the table redesign. After publication NHSBSA now plan to engage with users to make sure that the supporting summary tables better meet their needs. This will be done by a future user engagement event to be announced on their website. 

Office for Statistics Regulation’s evaluation of evidence in meeting Requirements

The separation out of the information into tables covering numbers (table 1) and volumes (table 2) seems to represent a sensible solution to addressing this requirement. The tables are now more user friendly and less lengthy without breaking them down into too many tables, which would also be overly burdensome on users. 

NHSBSA have redesigned the tables based on existing user feedback and now have plans in place to seek feedback on the new layouts. 

In our view, the evidence shows that the Requirement is met. 


Requirement 2:

To provide clarity on the methodological changes for as wide a range of users as possible, NHSBSA should provide a brief explanation of the changes in the main report. This could include linking to the background information and methodology note for those users who require more detailed information. 

Actions taken by NHSBSA to meet Requirements

BSA have expanded section 3 – About these statistics in the statistical narrative to cover the changes in methodology from the NHS Digital releases and provide high level details of the reasons for these changes. They’ve also added a link to the Background Information document here to allow for quick access to the full descriptions of these changes, which we’ve also revised to make sure that the rationale for these changes is clear to users. 

Office for Statistics Regulation’s evaluation of evidence in meeting Requirements

The summary paragraphs in section three of the main report provide clear and concise information on the methodological changes and why they have been made. 

The link to the Background Information document is prominent and the Background Information document itself provides a clear rationale for the changes. 

In our view, the evidence shows that the Requirement is met. 


Requirement 3: 

NHSBSA should ensure that the degree of uncertainty in the figures is clearly explained within the publication to ensure appropriate use. 

Actions taken by NHSBSA to meet Requirements

BSA have produced an ad-hoc report on sources of uncertainty in these statistics that is linked in the statistical narrative, and available on the website on the same page as the latest release of these stats.  

The introduction in the statistical narrative has also been expanded to include information on how data is collected for these statistics and accompanied by an expanded Background Information and Methodology document. 

Office for Statistics Regulation’s evaluation of evidence in meeting Requirements  

The ad-hoc report is comprehensive and outlines the sources of uncertainty and levels of accuracy very clearly. 

The additional information in the report and the Background information and Methodology document is also useful additional context. 

In our view, this evidence shows that the Requirement is met. 


Requirement 4:

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. 

Actions taken by NHSBSA to meet Requirements

 The ad-hoc report is focussed on the impacts of the regular assurance processes that BSA have in place for data capture and the post payment verification (PPV) activity carried out on certain advanced services. BSA had to focus on 2019/20 for the report as a lot PPV activity was halted during the COVID-19 pandemic, but this is now starting to wind back up. They’re looking to publish an update to the report once they have more data available to them, including working with their Provider Assurance team to enhance the data they capture during PPV activity.  

Office for Statistics Regulation’s evaluation of evidence in meeting Requirements

Given the lack of activity during the pandemic, focusing on data from 2019/20 seems to represent a suitable solution. The accuracy of the figures is outlined clearly in the report. Updating this when more up-to-date information becomes available will add to the strength of this.  In our view, this evidence shows that the Requirement is met.