Welcome to the Primary Care Rebates webkit, on this page you'll find a range of materials for public use such as the operating model which explains our procedures for assessing schemes and has guidance and submission information for companies looking to submit a scheme to the PrescQIPP Pharmaceutical Industry Scheme Governance Review Board (PISGRB).

PrescQIPP has a reasonable amount of experience assessing rebate schemes and has produced background information, aimed both at the NHS and for industry. These documents appear on this webkit should you need some underpinning knowledge. See below for more details.

For subscribed commissioners within the UK, a range of rebate scheme packs including our assessments of individual schemes, company contracts, clinical reviews of the medicines involved and much more, is available after logging in.

If you're new to our primary care rebates, we'd highly recommend that you watch this quick 'flythrough' video. Alternatively, scroll down for more detailed information.

PrescQIPP's Pharmaceutical Industry Scheme Governance Review Board (PISGRB)

The PISGRB has been created by PrescQIPP in response to requests by commissioners to provide guidance as to the acceptability of Primary Care Rebate Schemes being offered to the NHS by the pharmaceutical industry. These rebate schemes are predominantly offered by medicines manufacturers as a way of reducing the effective price of a medicine to a commissioner without affecting the published list price. Companies may be reluctant to change the list price which is used as a reference for medicines pricing in other countries and of course a rebated price is less likely to be known by their competitors.

The role of the PISGRB is only to provide an independent assessment of any particular scheme. PrescQIPP does not approve or reject schemes, neither do we act as a partner in the contract between the NHS and the company. Individual commissioners can accept or reject any scheme as they see fit. Our assessment is there simply to assist that process.

The assessment process is described in detail below but is designed to identify potential issues that commissioners may wish to consider when deciding whether to use any of these rebate schemes. The assessment is split into three sections as follows.

Clinical: The PISGRB clinical assessment is not a substitute for a commissioner formulary committee who would be much better placed to make a clinical judgement on the suitability of any product for their formulary. Occasionally a rebate scheme is offered to reinvigorate a product which is not attractive to the NHS clinically. The purpose of this section is to try and identify these products. It may be that a commissioner would take up a good scheme for a medicine which is not clinically attractive but is used extensively in their area simply to reduce the spend on that medicine.

Contractual: The PISGRB scrutinise the scheme for complexity, ease of administration, length vs. market uncertainties etc. Any problems are identified and commented upon.

The PISGRB has published some further guidance around the contractual assessment process, designed to further support companies seeking to submit schemes. The guidance provides a breakdown of the questions used to score contracts submitted, with supporting commentary for a number of key questions. You can download the guidance below:

Guidance on PISGRB Contractual Assessment.pdf

Financial: The realisability (how likely the scheme is to work for a commissioner), and size of any payback are considered.

All assessments are placed on the PrescQIPP website and are available to subscribers. Requests are welcomed for additional schemes that need assessing. Any comments about assessments should be directed to Kirsty Shadbolt (Project Manager) at help@prescqipp.info.

What this means for commissioners

PrescQIPP has run this service for all NHS commissioners since 2013.

Whilst the PISGRB neither promotes nor actively supports rebates, the outcome of the PISGRB’s assessments will be featured on this page for commissioners to consider. The PISGRB’s role in the governance process will be to comprehensively assess these schemes, outlining issues, and grading schemes on a scale of acceptability.

Whilst our processes are comprehensive, we thoroughly recommend that commissioners work with local committees to assess whether they are comfortable with the scheme.

Please note that there is not a clear “political” consensus about the appropriateness of rebate schemes in primary care and as such commissioners sign up to the schemes at their own risk. There has however been some case law which clarifies the legal position somewhat.

A summary of Abbott vs Aymes and an NHS CCG held in the High Court of Justice Queens Bench Division Administrative Court on Wednesday 17th July 2019 [CO/506/2019] has been prepared by Kevan Wind, Chair PrescQIPP Rebates Board in his words.

Available here.

Primary Care Rebate Board operating model

If you are a commissioner wanting to know more about our Primary Care Rebates Board, this is a great place to start. If you're a company looking to understand our process, or even submit a scheme this document is an essential read before getting in contact with us. You can download the operating model here: Primary care rebate board operating model v4.8.pdf

PrescQIPP webinar – October 2017 - Pharmaceutical industry rebates in UK

On 30th October 2017 PrescQIPP hosted a webinar on primary care rebate scheme (PCRS) governance systems in the United Kingdom, covering the PISGRB. The session was chaired by Kevan Wind, and was a general educational session for stakeholders, including the pharmaceutical industry to help explain our assessment process. We look at the background, key system considerations, general principles, and the similarities and differences within the UK systems. We also gave examples of where schemes commonly fail.

Primary Care Rebate Board standard terms and submission form

Standard terms

The PrescQIPP Standard Terms of Agreement for Primary Care Rebate Schemes offers a standard contract that pharmaceutical companies may wish to utilise as a part of their submission to PrescQIPP’s PISGRB. You can download the standard terms here:
Primary care rebate board standard terms v3.7.docx

PrescQIPP webinar – September 2016 – Standard terms and fast track process

In September 2016, Kevan Wind and Liam Cahill introduced the recent developments from the PISGRB, in particular, the launch of a set of standard terms for companies, a new fast track process for assessment, and some changes to the ever-evolving landscape. The main part of the session which aims to help CCGs understand and feel comfortable with the Standard Terms, a step-by-step guide through the contract, including advice and guidance can be found 37 minutes in.

Submission form for Industry

Looking to make a submission using your own contract (instead of our standard terms)? You'll need to send this completed form and any contracts you would be using with commissioners to Kirsty Shadbolt (Project Manager) at help@prescqipp.info. You can download the submission form here: Primary Care Rebate Board submission form.docx

Primary Care Rebates administration system

PrescQIPP subscribers consist of almost all CCGs in England, as well as Wales, Scotland and Northern Ireland. As such, any advice we provide reaches almost all NHS commissioners in the UK. Whilst we neither support or endorse the uptake or existence of Primary Care Rebate Schemes, we firmly believe that any local use of rebates should be underpinned by good governance and transparent processes.

To support this activity, we have produced a rebates administration system to assist commissioners in monitoring the possible financial returns from any rebate scheme you may seek to sign up to. You will only get the benefits if you sign up to the scheme yourself. Every month we take the NHSBSA ISP full data download and apply the working of the scheme to the relevant data set. This gives a theoretical rebate amount so commissioners don't have to work it out themselves or solely rely on data from pharmaceutical companies.

View the administration system here >>

Useful information for commissioners

Quick guide to rebates and FOI

A number of commissioners have been receiving FOI requests about activity and claims around primary care rebates. This guidance seeks to provide some information about what to expect from FOI requests in this area, and how you may wish to respond proactively or reactively.

Quick guide to rebates and FOI v3.2.pdf >

Principles of Governance of Primary Care Rebates for Commissioners

This document will support the review or production of a local policy on how to deal with rebates. It lists the points a commissioner may want to consider including, although the final decision about a policy should be taken by the local commissioner.

Principles of Governance of Primary Care Rebates for Commissioners.pdf >

Legal guidance - London Procurement Partnership

The London Procurement Partnership (LPP) commissioned two sets of legal advice in 2012 and 2015 which they made available to the NHS for interest. The advice is specific to LPP however whilst others might find it of general interest, they should not rely on it in a dispute or case but seek their own independent legal advice. As well as being dated now, this advice was produced prior to there being any case law in this area. This now exists as a result of the Abbott vs. Aymes case, the result of which have been summarised by PrescQIPP in the document available here.

The LPP legal advice is available on request for use by PrescQIPP subscribers from Kevan Wind (Chair of PISGRB) at rebates@prescqipp.info.

Money Money Money - Primary Care Rebates, what’s not to love?

On 17th March, Kevan Wind, our Chair of Rebates Board, presented on Primary Care Rebates.

Primary Care Rebates have been a contentious issue for many years as their acceptability and place in practice has been unclear.

If you have been unsure about whether to adopt the rebates offered by industry this webinar should place you in a position of understanding the issues.

View > >

Commissioners local rebate policies

These documents will help commissioners produce their own local rebate policy. If you have a policy you'd be happy to share, please contact us.

Rebate policies.zip >

Suggested commercial dispute process

There may be some instances where suppliers have defaulted on their payments due to commissioners where there is a signed rebate contract. Our suggested commercial dispute process includes some suggestions that might assist receiving payment.

Suggested commercial dispute process.pdf >