Consultation by: Department of Health and Social Care

The Department of Health and Social Care consulted on proposals to allow pharmacists to substitute medicines when the prescribed item is unavailable. Healthwatch Birmingham & Solihull supported increased flexibility where it helps prevent delays to treatment. We emphasised the need for clear, accessible information for patients when substitutions are made, consistent monitoring of how decisions are applied, and notifying prescribers so they can respond to any follow up concerns. We recommended that dedicated training should be implemented ahead of the suggested changes. We also highlighted risks for patients who may struggle to understand changes without clear explanations and noted that strict word limits in the consultation restricted respondents’ ability to fully outline their views.

05/12/2025
By Healthwatch Birmingham & Solihull
2025 DHSC Consultations

We responded to proposals allowing pharmacists to substitute medicines when prescribed items are unavailable, highlighting the need for clear communication, prescriber notification, and robust monitoring.

Healthwatch Birmingham & Solihull’s response
NHS England and the Department of Health and Social Care consulted on proposals to enable pharmacists to substitute medicines in cases of shortage or urgent need. We responded to ensure patient safety and experience remain central to any changes.

Supporting flexibility to prevent delays
We supported allowing substitutions where appropriate, to avoid harmful interruptions to treatment.

Clear communication with patients and prescribers
We emphasised the need for pharmacists to explain substitutions clearly to patients and notify the original prescriber.

Monitoring and consistency
We urged strong, transparent monitoring to ensure substitutions are used safely and consistently.

Limitations of the consultation process
We noted that strict word counts made it difficult for organisations to fully articulate their views.


HWBS Response to Enabling pharmacist flexibilities when dispensing medicines Download File (pdf 112.76 KB)

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