For dispensing GP practices in England and their Hub pharmacies
Hub and Spoke – All You Need
Since October 2025 dispensing practices have been able to send prescriptions for assembly to a Hub pharmacy, including the one next door. Here is why you might want to do this, what you have to do, and how we can help.
Led by two experienced dispensing doctors. Supporting dispensing practices for over 25 years.
In three parts
Part one
Why you might want this.
Any dispensing practice in England can be a Spoke, though only a pharmacy can be a Hub. It may be most beneficial where a pharmacy and a dispensary already share a building, because those sites are carrying a cost the new arrangement can take away outright.
Hybrid sites
Where a pharmacy and a dispensary share a premises, stock moving from one to the other is moving between two legal entities, which is wholesaling, so one of them holds a Wholesale Dealer’s Licence. Hub and Spoke is a different route for the same medicines: the pharmacy assembles as your Hub rather than selling to you. Unless something else needs that licence, there is no longer a reason to hold it.
Staffing
Rural dispensaries are hard to staff and harder to find cover for. A Hub takes volume without another vacancy to advertise.
What it is not
It does not close your dispensary. The patient still collects from you. The final decision on each supply stays with your dispensing doctor. You keep the capacity to dispense everything in-house, and you still claim for the dispensing done on your behalf. It moves the assembly, not the service.
Part two
What you have to do.
The work is mostly paperwork, and all of it has to exist before you start.
Your ICB gets 28 days’ notice and can object, but it does not audit your file. What you sign is a declaration that the file is already there, and it is the CQC that may ask to see it once you are set up. This is what has to be in it.
- A written agreement with the Hub carrying the seven specific provisions the notification names
- A record of the checks you made on that Hub, before you chose it
- A continuity plan for the days the Hub cannot deliver
- A risk assessment of the risks that delegating assembly to a Hub creates
- A patient notice displayed in the practice and published
- A way of recording incidents when something does go wrong
If you are a hybrid site, this is also the paperwork that stands behind letting the wholesale dealer’s licence go, so it is worth doing properly.
The Five Steps to Compliance
Four come before you notify, because the notification declares that you have already done them.
-
Find a Hub and agree terms
A registered pharmacy. The patient orders the prescription, you send it to the Hub, the Hub assembles and returns the labelled, bagged medication to you, and you supply the patient: the Hub never supplies the patient directly. Schedule 1 to 3 controlled drugs stay with you.
-
Do due diligence on the Hub, and record what you found
Registration, staffing, indemnity, the Hub’s own continuity plan, and whether the owner is a fit and proper person. Your ICB declaration says you have done this, so keep the evidence rather than a tick.
-
Write your continuity plan
What the dispensary does when the Hub cannot deliver. You have to hold one before you can sign the notification, so start it early.
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Sign the written agreement
It has to contain seven specific provisions, which is what the notification asks you to declare. This is a commercial contract with another business, so have your own solicitor read it, and have both Data Protection Officers read the data sharing schedule, before anybody signs.
-
Notify your ICB, then wait 28 days
The clock starts the day you submit, not the day you decide. You cannot commence earlier unless your ICB agrees, and if it objects you must not start at all until that is resolved.
While you are waiting
Ensure the following are done. Patient notice up and published, privacy notice updated, risks assessed, and the dispensary team trained while the workflow is still hypothetical. Then check the first batch and record the date you went live.
Part three
How we can help.
Every one of those steps has a document behind it. We have written all of them, in four packs, one for each person who has to check and complete them. Only once every pack is completed and signed, and your ICB has not objected within 28 days, can you start.
Pack A · 20 pages
- Licence and Terms
- Implementation Guide
- Practice and Hub Details
- Due Diligence Record
- ICB Notification
Pack B · 7 pages
- Hub and Spoke Agreement
Pack C · 27 pages
- Business Continuity Plan
- Patient Notice
- Risk Assessment
- Incident Report Form
- CQC Evidence Pack
Pack D · 6 pages
- Hub Business Continuity Plan
The agreement is the hard part
Before you can notify your ICB you need a written agreement with the Hub containing seven specific provisions. Pack B is that agreement, with all seven already drafted. What is left is the commercial detail, which is yours and your Hub’s to settle: no contract between two businesses can be finished before both have seen it. The CQC Evidence Pack sets the suite against the five CQC key questions, so you have something to hand a CQC inspector.
A look inside
Written to be used, not filed.
Two pages from the packs. In the risk assessment, score is the inherent risk and residual is what is left once the controls beside it are in place.
6.1 The final decision on each supply rests with the dispensing doctor at the spoke. That is so in every case, including where the spoke’s decision does no more than confirm one the hub pharmacist has already reached.
6.2 Where the hub pharmacist would supply anything other than what was prescribed, whether as to quantity, directions or product, the hub shall refer the item back to the spoke rather than make the change itself.
7.1 The parties shall share prescription data on the terms set out in Schedule 1, which forms the data sharing agreement between them.
7.2 Schedule 1 is made under the statutory information gateway at Regulation 222B of the Human Medicines Regulations 2012, which permits sharing without explicit patient consent while its conditions are met.
| Hazard | L | I | Score | Residual |
|---|---|---|---|---|
| Dispensing error at hub | 4 | 4 | 16 | 8 |
| Records, stock or systems co-mingle between the two organisations | 4 | 4 | 16 | 6 |
| CDs accidentally sent to hub | 3 | 4 | 12 | 4 |
| Data breach | 3 | 4 | 12 | 4 |
| Single incident disables both organisations at once | 2 | 5 | 10 | 10 |
What it costs
One licence, one practice.
Standard
£2,499
+ VAT, single-practice licence
- All four packs in Word format
- The agreement itself, ready for your solicitor to check
- Pack D to hand to your Hub
- The Personaliser, so you type your details once
Dispex members
£1,874.25
+ VAT, single-practice licence
- Everything in the standard licence
- A saving of £624.75 + VAT
- Plus everything else membership includes
A short call to check the fit, then an invoice. Payment is due in full. Your copy is then licensed to your practice by name, and you fill in one worksheet for the Personaliser to write into all four packs.
The packs are written for England. They are a professional resource and do not constitute legal, regulatory or clinical advice.
Dispex Ltd | Company Registration No. 4203677 | VAT No. 775365201 | 48 King Street, King’s Lynn, Norfolk, PE30 1HE | dispex.net
Thinking about it, or ready to set it up?
We will talk it through: whether it is likely to be worth it for a practice your size, and what to ask a Hub before you agree anything.
