Primary Care Rebates

Welcome to our Primary Care Rebates webkit. Here you'll find a range of materials for public use to inform both the NHS and the pharmaceutical industry how we assess rebates to assist the NHS in adopting them, should they wish to. There are also some general articles to give underpinning knowledge about the schemes.

For subscribed Integrated Care Boards (ICBs) and Health Boards (HBs) within the UK, a range of rebate scheme packs including our assessments of individual schemes, company contracts and clinical reviews of the medicines involved are available in the live schemes and fast track

Pharmaceutical Industry Scheme Governance Review Board: A function of PrescQIPP

The Pharmaceutical Industry Scheme Governance Review Board (PISGRB) provides guidance on the acceptability of Primary Care Rebate Schemes (PCRS) 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 a rebated price is less likely to be known by their competitors.

Our role is to provide an independent assessment of the rebate schemes offered to us. We do 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, it 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 clinical assessment looks at the licensed uses of the medicine, relevant national guidance and possible alternative treatments to establish whether the product has a place in therapy or not. It does not replace a local formulary committee assessment.

Contractual: We identify any potential issues from the terms and conditions that commissioners may want to consider in deciding on the acceptability of the scheme.

We have published some further guidance around the contractual assessment process that is designed to assist companies seeking to submit schemes and explain the assessment process. You can download the guidance below:

Guidance on PISGRB Contractual Assessment.pdf

Financial: The potential financial impact of the scheme, how difficult it is to administer and the likelihood of achieving savings are assessed.

All assessments are placed on our website and are available to subscribers once they are logged in. Requests are welcomed for additional schemes that need assessing. Any comments about assessments should be directed to rebates@prescqipp.info.

We have run this service for the NHS since 2013.

Whilst we neither promote nor support rebates, the outcome of our assessments are here for ICBs/HBs to consider.

We hope that our assessments can form a part of the ICBs/HBs governance procedures around management of rebate schemes.

Since 2019 there has been case law on this subject. A summary of the Abbott vs. Aymes and an NHS CCG case 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.

If you are an ICB/HB wanting to know more about our Primary Care Rebate Board, our operating model is a great place to start. If you're a company looking to understand our process, or submit a scheme, the operating model is an essential read before getting in contact with us.

Primary Care Rebate Board operating model v4.10.pdf

Pharmaceutical industry rebates in UK webinar

In 2017 we hosted a webinar on Primary Care Rebate Schemes (PCRS) governance systems. The session explains our assessment process, the background considerations, general principles, and the similarities and differences within the UK assessment systems. We also gave examples of where schemes commonly fail.  Whilst this is a few years old, the content is still relevant.

Standard terms and fast track route

Our Standard Terms of Agreement for Primary Care Rebate Schemes (PCRS) offers a standard contract that pharmaceutical companies may wish to utilise as a part of their submission to us.

When using our standard terms you will automatically go down our fast track route, which is a virtual process usually taking 4-6 weeks from start to finish.

Submit a scheme here.

Primary care rebate board standard terms v3.7.docx

Standard terms and fast track process webinar

This webinar explains the workings of the standard terms which were introduced in 2016.

Submission form and the PISGRB assessment route

If you're looking to submit a scheme using your own contract (instead of our standard terms), you'll also need to complete the submission form.
Submit a scheme here.

Primary Care Rebate Board submission form v3.5.docx

Our subscribers consist of all ICBs in England and Wales, as well several Scottish Health Boards and the Department of Health, Northern Ireland. As such, any advice we provide reaches almost all NHS ICBs/HBs in the UK. Whilst we neither support or endorse the uptake or existence of  Primary Care Rebate Schemes (PCRS) we firmly believe that any local use of rebates should be underpinned by good governance and transparent processes.

To support this activity, we produce a summary report of all rebates we have assessed. 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 for each scheme.  

View the administration system here

Quick guide to rebates and FOI

A number of ICBs/HBs have been receiving FOI requests about activity and claims around Primary Care Rebate Schemes (PCRS). 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.

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Principles of governance of PCRS for ICBs/HBs

This document will support the development of a local policy on how to deal with rebates. It lists the points an ICB/HB may want to consider.

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ICBs/HBs local rebate policies

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

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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 and 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 summarised here.

The LPP legal advice is available on request for use by our subscribers. Please contact us.

Rebates webinar - what you need to know

If primary care rebates are your thing, or you just want to learn more about them then our webinar presented on 3rd October 2024 may be for you.

The PrescQIPP rebates team explain how you can use the PrescQIPP assessments of industry rebate schemes to identify those that might work for you. We give some background information on rebates and guidance on their governance within your organisation.

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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.

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