Pandora’s Bo[to]x

After twenty years of trying to keep “Botox” in its box (i.e. ensure guidance1 from MHRA*, ASA*, GPhC*, JCCP* is followed), I wonder who else in Pharmacy worries like I do about the loss of control of a Prescription Only Medicine (POM)?

Does it matter to anyone in Pharmacy that the regulations we have been entrusted to uphold since the tragic days of Thalidomide, have been ‘worked around’ to such an extent that the public perception of the ‘experts’ on the use of this medicine are now social media ‘influencers’?

These questions come to mind as in the same week the Medication Safety Officers (MSO) observatory and GPhC Regulate both referred to the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021, which has come into force. More information can be found in the All-Party Parliamentary Group on Beauty, Aesthetics and Wellbeing (APPG-BAW) Report2 into advanced aesthetic non-surgical cosmetic treatments and the insights from Kingsley Napley on regulation3.

It seems incongruous that in the middle of a pandemic, parliamentary time had to be created for the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021.

The paradox is stark that regulation was required to mitigate the risks to stop injecting something that is an aesthetic ‘want’, at a time when vaccine hesitancy was gaining momentum. All the while the phrase ‘zoom face’ was being coined and procedures being offered to ‘correct’ it.

During the call for evidence, I wrote to the APPG-BAW, particularly around the role of pharmacy as the experts and leaders in medication safety, and also on informed decision making (given ubiquitous off-label use of Botulinum Toxin).

I had experience in this area, having previously given evidence in 2012 to the House of Commons Select Committee on Science and Technology into the regulation of medical devices, and I had also provided evidence in 2013 to the Review of Regulation of Cosmetic Interventions.

I did not hear back from APPG-BAW and had assumed that the expert voice of pharmacy was being picked up elsewhere.

The APPG- BAW report states that evidence was given from stakeholders including organisations representing the aesthetic industry, operators and practitioners, health bodies, regulatory agencies and consumers themselves. Written evidence was provided by GMC, HCPC and numerous nursing and dental practitioners.

However, it is the absence of pharmacy expertise that shouts out in Annexe 1 and 2 of the APPG-BAW report. The report had support from the APPG on Social Media, although it does not reference any liaison with Pharmacy APPG.

The APPG-BAW report recommendations call for more regulation, standards and enforcement, despite the failure of the POM controls on Botox. The APPG-BAW also considers ethics and mental health and looks at the evidence on the normalisation of invasive techniques. The Nuffield Council on Bioethics4 published a detailed report into the ethical issues in 2017 and raised the issues of supply and demand, as well as corporate social responsibility (CSR) as a way of protecting individuals from public health harms or discrimination. The evidence of the Centre for Appearance Research5 at UWE Bristol looked at how forces such as celebrities and influencers and image-editing phone apps have contributed to a dissatisfaction in appearance, psychological vulnerabilities and seeking “quick fixes” to achieve the “right” look.

The APPG-BAW heard that the majority of aesthetic practitioners do not have the necessary knowledge and skills to carry out psychological assessments. The licensed indications for skin use of Botox are the temporary improvement of appearance when the severity of the facial lines has an important psychological impact in adult patients. Moreover, this is restricted to vertical lines between eyebrows, crow’s feet, and forehead lines. The APPG-BAW recommendations include national minimum standards for risk assessing psychological vulnerabilities. 

The GPhC is clear in its guidance that pharmacist prescribers have an important role in making sure prescribing is safe and effective in non-surgical cosmetic medicine. The GPhC signposts to various references for prescribing cosmetic products, although does not specify the need to join the accredited registers. The Scottish Government ran a consultation6 in 2020 with the aim of closing the legislative gap by amending the definition of “independent clinic” so that it covers pharmacy professionals and would be regulated by Health Improvement Scotland7(HIS). Whilst this requirement is only where premises are not already covered by GPhC and NHS contract, it looks as though HIS separate approach to regulating independent healthcare is providing flexible options (different mechanisms apply in England). 

I am not a pharmacist prescriber and therefore I am unlikely to have direct involvement in these areas. However, I have been involved in medication safety since the NPSA focus on medicine Patient Safety Alerts, and subsequently as a Medication Safety Officer (MSO).

I have also been involved in many investigations where things go wrong, including wider governance issues where professionals work across NHS and private practice. A harmed patient, who is also a pharmacist recently said:

“If you are not actively working towards learning – you are actively letting things go wrong”.

This aligns with the words of Lieutenant General David Morrison – “the standard you walk past is the standard you accept”. In healthcare, this could be considered to be “micro-harms” in that if left unchecked these issues have the potential to lead to patient harm and erosion of professional standards.

Non-surgical cosmetic procedures are not a marginal issue but have become a barometer for wider societal behaviours and there is a need for ethical debate in pharmacy about supply and demand. The conversation about the safe and effective use of non-surgical cosmetic medicines should be a matter for all pharmacy professionals and we need to start a conversation about pharmacy leadership in this area.

Opinion by Karen Harrowing, Pharmacist and Independent Advisor in wider healthcare governance.


All links below were accessed 28th October 2021.

  1. *Medicines & Healthcare products Regulatory Agency (MHRA – guidance now archived) available here.

*The Advertising Standards Authority Ltd (ASA) available here.

*General Pharmaceutical Council (GPhC) available here.

*Joint Council for Cosmetic Practitioners (JCCP) available here.

  1. APPG – BAW Report available here.
  1. Kingsley Napley review of APPG – BAW Report here.
  1. Nuffield Council on Bioethics availble here.
  1. Centre for Appearance Research available here.
  1. Scottish Government Consultation available here.
  1. Health Improvement Scotland (HIS) – Independent Clinics available here.
  1. Health Improvement Scotland (HIS) – Independent Healthcare available here.

Robbing Peter to pay Paul

The stark call from Community Pharmacy Scotland to temporarily halt the recruitment of the pharmacy workforce to GP primary care support roles is a reminder that Government policy decisions taken with the best of intentions do not always survive the stress test of everyday reality.

Of course, we need pharmacists and pharmacy technicians working in every part of the NHS. This includes community pharmacies, GP surgeries, hospitals and elsewhere too.

This year, more than any other has demonstrated the critical role of pharmacy at every level. I want to see more career progression opportunities for pharmacy colleagues which could involve a blend of time spent in community, GP surgery and hospital settings.

However, the shift from where we are now to where we need to be, has to be planned carefully otherwise we end up with different parts of the NHS competing to recruit scarce people resources.

That is a zero-sum game that adds nothing to improving patient care.

Robbing Peter to pay Paul is not a sensible healthcare strategy, especially when UK PLC is under extreme pressure in many sectors.

In England, the situation is similar.

There are now over 2,200 pharmacy full-time equivalent posts in primary care networks. There is nothing in principle wrong with that, but the reality is those qualified professionals will have been mainly drawn from community pharmacy at a time when their frontline role is needed most. The move towards ICSs is only likely to increase that demand and put further pressure on an already overstretched and under-funded network.

We need patient-centric integrated healthcare provision. Planning for that must take account of the workforce needs of community pharmacy in the frontline: needed, valued, respected by the public.

Steve Anderson is an Executive Board member of operations and logistics at the Pheonix Group.


The trouble with life is that all aspects of it continue to change and evolve in a confusing, chaotic but often beautiful way.

Despite having a pre-conception that life within a profession would be different to wider society, somewhat surprisingly, it is similar in so many ways.

And what a period of recent history we continue to live through. Every single one of us has been touched by the maelstrom that continues around us. Perhaps Pharmacy in Practice should have been in there getting closer to the pharmacy practice action. Highlighting bravery, calling out injustice against our pharmacy peers or perhaps being first to the pass with a shouty, controversial headline.

Well maybe. Or maybe not.

I thought I had reached the point in my career where frankly I didn’t care what other people thought.

That has been tested recently and if I’m honest I have self-censored for fear of offending.

Politeness, decorum and good manners were drummed into me as a youngster so the thought of possibly contributing to this chaotic environment we find ourselves in just didn’t sit well with me.

So I stopped.

I have always prided myself on being able to explore, understand and empathise with as many perspectives of an argument as possible all with a focus on trying to help folk articulate important issues, thought or ideas. In recent times this open-minded approach to matters of life, and in our case pharmacy, has become very difficult.

Some folk are just so angry at the moment and are certainly gunning for a fight.

Regardless of how benign the topic is you can be sure that the emboldened vocal minority will emerge and express outrage. Each time this happens the moderate dial moves a little bit more.

Pharmacist vs pharmacy technician.

Prescriber vs non-prescriber.

Manager vs employee.

Locum pharmacist vs contractor.

‘X’ representative body vs ‘Y’ representative body.

The list goes on…

Find your tribe, pick your fight and get your outrage on in your favourite social media echo chamber.

The battle lines have been drawn and the conflicts continue unabated. And these fights are designed to grab your attention. Draw you in and distort your thinking.

I must admit that in the past I have on occasion fallen into this vortex of negativity and outrage. I wonder have others felt the same.

My hope is that there are many more people like me who do not want to engage in such quarrels but do welcome open, honest and evidence-based debate.

‘The scientific profession’ said every pharmacy leader ever.

Most pharmacists go to work to do the very best they can for the people they care for.

And most of the time this doesn’t involve any high-level fancy pharmacy practice. In my experience care, compassion, empathy, common sense and hard work will take you far. Not giving up during your career is probably the most important skill of all.

Anyway, I came here to tell you that this internal bickering is becoming really boring. You don’t need to be alert to injustice the whole time and open debate is to be welcomed.

The future leaders of our profession will step back into the game, emerging from their self-censored positions and present a vision of what it means to be a pharmacist.

I honestly believe many are staying quiet at the moment.

It must be a tremendous act of political gymnastics to make it all the way to the top in pharmacy. Securing the position of Chief Pharmaceutical Officer is an incredible achievement but I’m not sure what skills it demonstrates. I know enough of the workings behind the scenes to consciously incompetently have a view on that.

Whoever successfully secures the position of Chief Pharmaceutical Officer in Scotland and England will have one hell of a job to unite all corners of the pharmacy profession.

It is my hope that these candidates don’t get dragged into trying to please the various tribes in pharmacy but instead presents a compelling vision of where we all fit and where we need to go.

We need some independent thought and a vision that we can all get behind.

I hope they use their influence to calm the anger and bring the majority together around a common goal.

Or maybe we will all just have another fight.

Johnathan Laird is a non-award winning pharmacist with absolutely no formal leadership training and is therefore unqualified to advise on such matters.

Could IR35 be good for pharmacist locums?


I have to say I’m getting a bit concerned about the lack of discussion around pharmacist locums and IR35.


From the 6th of April, the choice about whether you are working inside or outside IR35 no longer lies with the pharmacist locum trading as a limited company, but with the end-user, i.e. the pharmacy contractor. This will fundamentally change the way locum pharmacists work and trade, so you must understand the extension of IR35 into private companies -similar rules have applied in the NHS since April 2017.

You can access the tool for checking employment status by clicking here.


I think the expectation was that the extension of IR35 into the private sector wouldn’t happen, but all indications are that it will. The new Chancellor, Rishi Sunak, has suggested a gently, gently approach, but in my experience, HMRC will see this opportunity to gather more tax money and quickly.

Summary of what’s happening with IR35 from the Recruitment and Employment Confederation




The Government is extending the off-payroll rules, which have applied in the public sector since April 2017, into the private sector. The new rules will apply to work done by contractors working through intermediaries such as personal service companies. Importantly, the tests for IR35 status is not changing, but the responsibilities for making the status decision and related deductions are.




The new rules will apply to all payments made to personal service companies on or after 6th April 2021.


What’s the difference?


From 6th April 2021, the client, and not the contractor, will be responsible for assessing IR35 status. For inside IR35 assignments, the fee-payer will have to make tax and national insurance deductions before paying the personal service company.


My advice for all locums is to complete the online test via the link above then talk to your accountant. This is not the time to stick your head in the sand because not spending time to understand your personal position regarding IR35 could leave you with a huge tax bill.

Following the budget on 3rd March 2021, it is clear that IR35 will come into effect on 6th April 2021. The PDA has published a really helpful, considered article on the IR35 issue, which can be found here.


The NPA has also published guidance that is more geared to pharmacy owners and operators but it’s useful to understand the challenges that IR35 brings for pharmacies too. You can access this article here.


What now?


It’s really important that you take the time to understand your obligations and risks. You need to remember that you need to consider each arrangement you have with pharmacies individually.  After consideration of the increased complexity, it may be that you decide that locuming is no longer the right choice for you.


The irony is that the way locum pharmacists have worked and been booked has always been an anomaly when you compare it to other healthcare professions. The way that multiples have classically covered vacancies and holiday cover has never really made sense to me.


Why would you book locums by the day and not on longer-term, temporary contracts?


After all,  the pharmacy gets the consistent cover and the pharmacist can earn a premium for this consistency and earn holiday pay too? It may be that IR35 is the catalyst for change that benefits locum pharmacists in the long run.


Shaun Hockey is the Managing Director of Medacy Healthcare Support Solutions.


Please note that this article is not advice. You should seek advice from registered tax professionals or accountants who are qualified to give such advice.


Read more


Will IR35 change locum life forever?


Is IR35 a potential tax time-bomb for pharmacist locums?

Why I don’t fear Amazon in pharmacy


There seems to be a good deal of trepidation among my fellow community pharmacy Superintendents and owners about when and how Amazon Pharmacy will commence operations in the UK.


First, there was the registration of the UK trademark and then some recent job adverts which at first glance appeared to be based in London, suggesting a launch was imminent but further inspection reveals they are roles at their Pillpac operation in Arizona USA …. phew!


That said, it does feel like it is coming pretty soon. I don’t think it’s a coincidence that both Lloyds Pharmacy and now Pharmacy2U have recently “hired bankers” to explore sales. I don’t know about you but this feels like a bit of a coincidence and, while I am no expert on these things, it looks like they are both effectively holding up a “Please buy me Amazon” sign, judging it to be a good time to be acquired by the online giant with seemingly unlimited resources.


Pharmacy2U would be a better fit but there are plenty of other distance selling operations that would enable Amazon to hit the ground running with an existing NHS contract. Given Pharmacy2Us costly false start at their new Leicester facility last year (excellent analysis of that here), Amazon may wish to skip past the pesky NHS control of entry mechanisms and the scrutiny that comes with that process. We should also not forget Amazon’s recent partnership with Morrison Supermarket on grocery fulfilment. They happen to own a few pharmacies themselves. So Amazon has multiple relatively easy points of entry to the UK market.


To some extent though I think we just need to stop wasting any time speculating on what Amazon may or may not do. We need to focus on our customer service and prepare.


Amazon has multiple relatively easy points of entry to the UK market.


So, you may be wondering by now why I’m not worried about Amazon Pharmacy?


Well, the journey of helping to build up 15 new pharmacies from scratch across Scotland and England as well as working on numerous health-tech projects which then led to co-founding MedPoint over the last few years has meant I have spent a lot of time thinking about what patients want and need. These are not always the same thing.


Call me old-fashioned but there is a lot that happens in the relationship between a good community pharmacy and their patients that simply cannot be replicated by a faceless distribution centre hundreds of miles away with a slick app. The unfortunate thing is that more & more, community pharmacies aren’t paid for all that they contribute to society, especially in England (don’t get me started on that topic!).


In Scotland, the term “ART of Pharmacy” has been coined to try to encapsulate what pharmacies can do when speaking to commissioners. Advice, Referral, Treatment.


We also have examples of sectors that Amazon tried and failed (so-far) to dominate. Not that long ago we were hearing about the death of the supermarkets as Amazon tried to disrupt grocery shopping.


It largely failed. Why?


It failed because existing operators adapted quickly and offered their customers the same level of convenience via home delivery service, click and collect and a smooth online and offline experience. So there was no significant advantage for customers to make the change en-masse to using Amazon for groceries and other household items.


Customers value being able to go to a physical store if and when they need or want to. This applies even more to community pharmacy given everyone needs face-to-face care and healthcare services from time to time. Yes, a monthly subscription-style delivery of your medicines sounds great when you are on a few stable medicines and nothing changes, but life isn’t like that. Invariably when there are complications and a patient cannot get through to their chosen online provider, who do they turn to sort it out?


That’s right, the local community pharmacy where they can go and speak to a human and be seen, heard and cared for. The level of “churn” of patient nominations at the larger online pharmacies demonstrates this.


That’s aside from the times you throw in the odd ‘Beast from the East’, Royal Mail delay or strike, and oh yeah, pandemics, just to mess with the supply chain.


These events served to demonstrate the value of having a distributed network of community-based pharmacies as it spreads the risk. What blockchain does for cryptocurrency, community pharmacies do for the medicines distribution system to draw an analogy from the world of tech.


Would large monolithic central hubs hundreds of miles away from the patient that rely on postal services have coped with shocks like that? It’s no big deal if those new slippers don’t show up on time but medicines are not something you can wait two or three weeks for.


I used to be pessimistic about the future of our profession but now can see a path and a bright future for those pharmacy operators that take up the challenge and adapt to new ways of working.


Don’t wait around to see what happens if and when Amazon arrives. Take a page out of the supermarket play-book and give your patients what they increasingly want convenience, and a user experience akin to what they are already used to in other aspects of their lives.


Most, (not all) will stay loyal and why would they not?


I’m certainly enjoying working with all the innovative pharmacy owners and other health-tech partners who see the opportunities, as well as the threats and, are choosing to “lean in” to the challenge by harnessing technology to bring pharmacy services into the digital age.


I used to be pessimistic about the future of our profession but now can see a path and a bright future for those pharmacy operators that take up the challenge and adapt to new ways of working.


On the dispensing side, a lot of operators are already investing in a hub and spoke model to realise efficiencies and for others, there will be options for outsourcing that logistical work like HubRx and Golden Tote from Numark among others I’m sure.


Efficient supply is very important as it is the foundation of the relationship with local patients. It is their main reason for interacting with your pharmacy, but I don’t feel it is where the future value for our profession is. That is surely in clinical services to those same patients via the network of what are essentially walk-in clinics in every neighbourhood. Whether that be via NHS commissioned or increasingly private services given the inevitable long-tail effect of the pandemic on NHS service levels.


One area I’m particularly excited about is the potential for diagnostics & pathology testing in community pharmacy with the cost of equipment no longer being a barrier with solutions from the likes of Agilis Health.


So I’m pretty sure most community pharmacies have a place on the high street of the future but we need to move quickly as a profession to achieve that slick digital patient experience and get the final mile of collection/delivery working well to ensure patients stick with us, Amazon or no Amazon.


Kevin Murphy is a superintendent pharmacist and CEO of MedPoint. You can find him on Twitter here.


Read more


Is Amazon about to move your pharmacy cheese?


Amazon, digital dentistry and how community pharmacies fit


Professor Harry McQuillan on the ‘ART’ of community pharmacy


The ‘ART’ of Scottish community pharmacy is all about data



Will IR35 change locum life forever?


Typically, locums have been treated as if they are self-employed, giving them certain advantages over employees who are taxed on a pay as you earn (PAYE) basis.


However, the status of locums throws up a number of issues.


Calling a pharmacist a locum does not automatically confer self-employed status on a pharmacist. A few years ago, HMRC investigated a number of pharmacy businesses that had treated locums as if they were self-employed. There were particular issues over locums who had worked in the same pharmacy for a long time; or if they worked a regular pattern, such as every Wednesday. HMRC took the view that these locums were really employees and even if the locums had paid their income tax and National Insurance, the owners were exposed to the risk of penalties and interest on the tax they had not deducted.


The new IR35 legislation will be implemented on 6th April 2021. Locum pharmacist Andrew Jukes has taken some time to write the article below to highlight a number of pressing issues that are now swiftly emerging.


Before continuing it is important to note that no individual or organisation can advise you on your own specific tax circumstances unless they are qualified and authorised to do so. This article seeks to provide a summary of the background issues that locum pharmacists will shortly face as the new IR35 tax arrangements are implemented in April 2021. Andrew also provides some helpful signposting to qualified and appropriate sources of advisory support.


What is IR35?


IR35 is an item of tax legislation aimed at addressing perceived tax avoidance, in the main via limited company contractors, such that contractual or locum workers taxation, is aligned to that of employees.


So what is the relevance and impact to locum pharmacists after IR35 is implemented from April 6th 2021?


The first aspect is that only medium to large companies as defined by Her Majesties Revenue and Customs (HMRC), will be subject to the applied legislation. This is the first thing to check if this applies to you in your locum activity (see table below).


If you are contracting to companies that are subject to the legislation, then you will no longer receive your earnings without any tax deducted. Many contracts from 6th April 2021 will be deemed inside IR35 and that will mean that PAYE taxation and national insurance will be deducted at source by the end client (i.e. agency or hiring organisation).


This essentially presents a situation from April 2021, that locum pharmacists may not be able to use their limited companies as before and will end up being renumerated via ‘PAYE’ or ‘direct engagement models’. This can represent a significant reduction in locum pharmacist salaries, as the tax-efficient operation of limited companies will not be permitted.


The legislation does not apply to those locums working as sole traders or via umbrella companies as appropriate taxation will occur. However, the designation of employment status may still be affected, as this is closely related to IR35. You will have to check how this may affect terms and conditions.


The burden of responsibility for assigning IR35 status will be via the ‘end client’ or hiring firm, utilising the HMRC IR35 tax assessment tool (‘CEST’=Check Employment Status for Tax). This will cause companies a higher administrative burden to implement and oversee.


What might you need to consider?


Every situation is different and requires early preparation for the changes that are coming. I will signpost you to some recognised sources of advice and support in the table that follows. The impact could be potentially significant in terms of salary reduction. This will largely be because you will not be permitted to operate via a limited company.


So what new arrangements will you be subject to?


You will need to be prepared for how your working benefits will present themselves.


After 6th April 2021, will you receive any form of holiday, sick pay and pension benefits, under the new contractual arrangements?


It is the case that expenses will not be paid to the same level, as was the case via previously limited company operation. You need to conduct a financial comparison of pre and post April 6th 2021 as a locum pharmacist that are applicable, in your circumstances.


The table below provides a route to answering your questions, and each individual locum pharmacist will need to take responsibility to ensure they have prepared for the changes and mitigated any risks they may face. The sources below serve to provide clarity on specific tax aspects and related issues, in order to support locum pharmacists.


Potential sources of official advice and support for locum pharmacists and pharmacy operators to engage with in advance of the IR35 roll out from April 6th 2021.


This list is not exhaustive.


1. End Client.


  • The organisation or company engaging you as a locum should confirm if IR35 applies to them (as per ‘HMRC’ definitions).
  • If so they should inform you of your assigned IR35 status.
  • Cannot provide you with specific personalised overall tax advice as they are not authorised to do so.


2. Your own certified accountant.


  • They know your working pattern and history.
  • They can advise on IR35 and specific personalised tax matters.


3. Locum agency.


  • If you make a contract via a locum agency, they will be able to give some general level advice about your work assignments and IR35 taxation, however, they cannot provide you with specific personalised, overall tax advice as they are not authorised to do so.


4. The Pharmacists’ Defence Association Union.


  • Can advise members on issues involving work-related scenarios, regulation, disputes professional issues or signpost as appropriate. ‘PDAU’ cannot provide you with specific personalised overall tax advice as they are not authorised to do so.
  • Click here to access the PDAU website.
  • 0121 694 7007


5. Pharmacist Support charity


  • Confidential support and advice provided in many areas including stress, financial assistance, debt and employment law etc. However, they Cannot provide you with specific personalised, overall tax advice as they are not authorised to do so.
  • Click here to access the Pharmacsit Support website.
  • 0808 168 2233


6. Her Majesty’s Revenue and Customs


  • Can advise on your IR35 status and determination.
  • Useful if ‘end client’ determination in question, especially if you don’t have an accountant.
  • A useful source of general advice on preparation for IR35 implementation. However, they cannot provide accountancy services. You will have to oversee your overall tax affairs and submit the relevant documents (seek advice), or via an authorised tax specialist or accountant.
  • General TAX advice via their website that you can access here.


7. National Pharmacy Association


  • Support membership to achieve professionally and commercially in the interest of patients.
  • Can advise members commercially or professionally on aspects of IR35.
  • Cannot provide you with specific personalised overall tax advice as they are not authorised to do so.
  • You can access their website by clicking here.
  • 01727 858687


8. The company chemists’ association


  • Represents the interests of its larger multiple pharmacy operator members, from the community pharmacy sector.
  • Can advise pharmacy operators on various aspects relating to the implementation of IR35 in April 2021.
  • Cannot provide you with specific personalised overall tax advice as they are not authorised to do so.
  • You can access their website by clicking here.
  • 02037418254


9. Contractor calculator


  • Expert advice (across all business sectors) on aspects related to contracting (i.e., working as a locum).
  • The ‘go to’ experts on all facets of IR35. There is a wealth of resource on the website and various publications on the topic and current developments.
  • Cannot provide you with specific personalised overall tax advice as they are not authorised to do so.
  • You can access their website by clicking here.


A respectful reality check, and a call to action


There are many thousands of Locum Pharmacists engaging in the private sector (i.e community pharmacy/private hospitals), that could potentially be impacted by the implementation of IR35 on 6th April 2021.


My personal motivation for creating this supporting article is that I was totally unprepared for the public sector roll out in 2017 of IR35. It did a lot of damage and compromised the financial position of many locum contractors (not just pharmacists). The effects are well documented in the public arena.


The reality


The legislation is confirmed, and IR35 will be implemented in the private sector on 6th April 2021. There is no longer a chance to lobby or circumnavigate what is coming on the horizon. If you prepare and establish the facts you can plan for the situation more readily, or make changes. If you do not plan or become aware of this issue then you could be in for a change in financial circumstances that are unexpected that have detrimental impacts on you personally.


Call to Action


I would advise taking the time now to seek the advice you need. Please be aware that each situation is different and you need to utilise any sources of advice that apply to your given situation. It may be the case that you engage services for several companies or have a portfolio style of working. All of this has to be considered. Please act to ensure you have the information you need in advance and factor in the time it may take to clarify everything. Taxation issues are seldom plain sailing.


A Final word and reflection


IR35 has caused significant impacts in many sectors. Alongside the personal finances which are a valid consideration and concern, there are also ‘secondary effects’. You cannot predict the future, and it is beyond the scope of this article, but you may wish to consider how such implementation may affect workforce dynamics if locum pharmacists consider changing to permanent roles or leave altogether, and how continuity of services may be affected? How would this impact on remaining staff in these workplaces?. The whole viability of being a locum could be called into question with far reaching consequences.


I saw all this ‘play out’ in the public sector, in 2017 and felt the impacts personally. I hope with a little forward planning, awareness and a realisation that this change will need to be faced, it can be approached and tackled more effectively, with less stress.


Andrew Jukes is a locum pharmacist. 


Read more


Is IR35 a potential tax time-bomb for pharmacist locums?


Could IR35 be good for pharmacist locums?