Every Pharmacy First consultation captured against the pathway, recorded fully, sent to the GP and claimed correctly. The pharmacist makes every clinical decision.
At a glance
An illustrative scenario. The numbers are typical examples, not a client case study. The cloud services and UK rules were checked on 9 November 2026.
Pharmacy First has become a large part of the working day. There are seven clinical pathways, each with its own age range: sinusitis (12 and over), sore throat (5 and over), acute otitis media (1 to 17), infected insect bites and impetigo (1 and over), shingles (18 and over) and uncomplicated urinary tract infection in women aged 16 to 64. On top of these come minor illness consultations and urgent medicine supplies, both of which need an electronic referral from NHS 111, a GP practice or another NHS service.
Each consultation has the same shape. The pharmacist checks the gateway criteria, follows the pathway, supplies under the PGD or clinical protocol (or, since 29 October 2026, prescribes, if they are an approved independent prescriber in an approved pharmacy), writes the record, makes sure the GP is told, and makes sure the consultation is claimed. In a busy branch the write-up happens between patients. Records end up thin, red flags and onward referrals are recorded inconsistently, and gaps are found weeks later when someone reconciles the claim.
The money and the rules both depend on getting this right. Each consultation earns a £17 fee, and the monthly fixed payment of £500 or £1,000 depends on reaching 20 or 30 clinical pathway consultations that crossed the gateway point and reached a pathway outcome. The updated service specification of 29 October 2026 strengthened record keeping and post-payment verification, and unsubstantiated payments can be recovered. Missed claims lose income; claims a record can't support are a bigger problem.
Agree these, and measure the baseline, before anything is built. Example targets are typical, not promises.
Pharmacist time spent recording after the patient has left.
ExampleDown by half
Share of records with every field the pathway requires, checked by a weekly audit sample.
ExampleAbove 95%
Where pathway red-flag criteria were met, was the referral or safety-netting recorded? Audited, not self-reported.
ExampleEvery case in the audit sample
How much pharmacists change the drafts. Very high means it isn't helping; near zero can mean drafts are being signed unread.
ExampleStable, and reviewed weekly
Consultations matched to the claim data before the deadline, including manual claims for prescribing consultations.
ExampleEvery consultation, every month
Money clawed back by post-payment verification because a record didn't support the claim.
ExampleFalling, measured against last year
Cross-sector rules are on the UK regulation map.
Consultations follow the published clinical pathways, the PGDs and clinical protocol, or NHS prescribing for approved prescribers. The assistant works from the current versions, controlled by the clinical governance team, and is re-tested whenever a pathway, PGD or the specification changes. It never creates a referral on a patient's behalf, which the specification now prohibits.
A consultation is only claimed if the record shows it crossed the gateway point and reached a pathway outcome. The claims check finds gaps and sends them back to the pharmacist. It never creates, changes or submits a claim, and it never fills in a record on someone else's behalf.
The pharmacist is accountable for the consultation and the record. Prescribing is done only by pharmacists with the independent prescriber annotation, approved by the ICB under NHS England's professional assurance framework. The design makes the pharmacist's sign-off explicit and logged.
If the group builds the assistant, it is the manufacturer under DCB0129 as well as the deploying organisation under DCB0160. That means a clinical safety officer, a hazard log and a clinical safety case before the pilot. The standards are under review, so watch for revised versions.
MHRA guidance (July 2026) says tools that transcribe, summarise or draft for clinician review are generally not medical devices, but tools intended to support diagnosis or treatment can be. Keep the intended purpose narrow and written down: red-flag prompts are the pathway's own published criteria, shown to the pharmacist, not the AI's own clinical judgement. Get a regulatory view on this in discovery.
Consultation records are special category health data. That means a DPIA before the pilot, processing in UK regions, a clear retention period, and a contract that stops providers training their models on your data. If audio is used, patients are told clearly and can say no, in line with NHS England's ambient scribing guidance. The new system is covered in the group's annual Data Security and Protection Toolkit submission.
Showing AWSAzuresovereign / on-prem services. Switch with the toggle; every diagram and table on this page follows it.
01Channels
02Intake
03Intelligence
04Orchestration
05Systems of record
06People
| Layer | AWS | Azure | Sovereign / on-prem |
|---|---|---|---|
| Intake: events, audio, filesAudio is optional. Many consultations work well with structured prompts alone. | API Gateway, Amazon Transcribe, S3 | API Management, Azure Speech in Foundry Tools, Blob Storage | Kong or your existing API gateway; open-weight speech models (e.g. Whisper) on your own GPUs; Ceph or IONOS S3 Object Storage |
| Voice: build or buyThe registry is self-certified, so it isn't a clinical validation. Check its evidence like any other supplier's. Test any speech model on UK accents and busy-branch background noise. | Amazon Transcribe, or a product from NHS England's ambient voice supplier registry | Azure Speech, or a product from NHS England's ambient voice supplier registry | Open-weight speech models (e.g. Whisper) on your own GPUs, or a registry product that can be hosted privately |
| Drafting and reasoningBoth clouds offer a choice of models, including Claude and others. Open-weight models need their own testing against the pathways. | Amazon Bedrock | Microsoft Foundry | Open-weight models served with vLLM on your own GPUs, or IONOS AI Model Hub |
| Pathway knowledge (retrieval)Only the approved, current pathways, PGDs, protocol and group SOPs. Each answer cites the document and version. | Bedrock Knowledge Bases | Foundry IQ, built on Azure AI Search | OpenSearch, or PostgreSQL with pgvector |
| Agent runtimeThe original Bedrock Agents closed to new customers on 30 July 2026; new builds use AgentCore. | Amazon Bedrock AgentCore | Foundry Agent Service | An open-source agent framework (e.g. LangGraph) on Kubernetes |
| Workflow | AWS Step Functions | Logic Apps or Durable Functions | Temporal, or n8n |
| Middleware and events | Amazon EventBridge, SQS | Event Grid, Service Bus | Apache Kafka or RabbitMQ |
| Link to the clinical IT systemThis decides the design. Agree in discovery what the supplier allows: drafts written into the record, or a side panel the pharmacist copies from. | Through the supplier's published API | Through the supplier's published API | Through the supplier's published API |
| GuardrailsBlocks the assistant from naming a medicine or dose that isn't in the pathway or PGD in front of the pharmacist. | Bedrock Guardrails | Azure AI Content Safety | Open-source guardrails (e.g. NeMo Guardrails, Llama Guard) |
| Platform | Managed AWS services | Managed Azure services | Kubernetes on-prem (e.g. OpenShift, Rancher), or IONOS Managed Kubernetes |
| Identity, keys, data protectionPharmacists sign in with the identity they already use. NHS smartcard access stays with the clinical system. | IAM Identity Center, KMS, Macie | Entra ID, Key Vault, Purview | Keycloak or your existing Active Directory; OpenBao or HashiCorp Vault; an HSM |
| Monitoring and auditLog every prompt shown, every draft, every edit and every sign-off, with the document versions used. | CloudWatch, CloudTrail | Azure Monitor, Log Analytics | Prometheus, Grafana, OpenTelemetry |
| UK data residencyThis is NHS patient data. Some NHS commissioners and the group's own IG policy may require UK residency, so an EU-hosted option may not fit. | eu-west-2 (London) | UK South / UK West | Your own UK data centre, or a UK/EU provider (IONOS AI Model Hub runs in Germany) |
On a phone, the table shows the platform you pick. Sovereign / on-prem means open, portable components you can run in your own data centre or with a UK or European provider; IONOS is shown as one example, and others exist. What sovereign cloud means →
Many organisations keep core systems and sensitive data on their own servers. This is how the same design works across both.
Stays on-prem
The assured Pharmacy First IT system, the PMR and the clinical records stay exactly where they are today, with the clinical IT supplier. So do the flows to Manage Your Service and GP Connect, and NHS smartcard access. The AI never becomes the record.
Uses cloud AI
Drafting, pathway retrieval, optional transcription and the claims check run in the chosen platform: a UK cloud region, or the group's own GPUs for the sovereign option. Only the consultation details needed for a draft are sent, and nothing is kept longer than the agreed retention period.
How they connect
Through the clinical IT supplier's published API and an API gateway, over a private link such as AWS Direct Connect or Azure ExpressRoute from the group's network, or across its own data centre for the sovereign option. Branches reach the assistant the same way they reach the clinical system today.
If the link drops
The consultation carries on safely in the clinical system, exactly as it did before the AI: the pharmacist uses the pathway documents they already have and writes the record themselves. Queued events catch up when the link returns, and the claims check simply runs later in the month.
What each agent may do through its tools, what it may not, and where a person signs off. The limits are enforced by the platform, not the prompt.
Consultation assistant
Where a person signs offThe pharmacist decides and signs every consultation. Drafts stay marked as drafts until they do. The agent's permissions are enforced by the platform's identity and policy controls, not by instructions in a prompt.
Claims check
Where a person signs offBranch and claims staff submit claims, as now. Only the pharmacist who carried out the consultation can complete or correct its record.
The assured Pharmacy First IT system stays the clinical record. It already sends data to Manage Your Service through its API and sends the GP a structured summary through GP Connect Update Record, falling back to NHS.net Connect email. The assistant works alongside it and never replaces those flows.
Prescribing consultations work differently for now. Under the interim arrangements from 29 October 2026, they are recorded in a separate prescribing system, the GP is told by secure email because Update Record isn't available for them yet, and each one needs a manual claim. The claims check is designed for both routes, so nothing falls between them.
Events keep the AI decoupled. A started or completed consultation becomes a message on a queue. If the cloud service is slow or down, the pharmacist carries on in the clinical system exactly as before, and drafts catch up later. Nothing is lost or created twice.
Map today's consultation and claims process, measure the baseline, agree what the clinical IT supplier allows, and get a regulatory view on intended purpose.
Gate · must be true to passBaseline agreed, supplier route confirmed, clinical safety officer named, DPIA and hazard log started.
Two or three pathways in 10–15 branches, in shadow mode: the assistant drafts, pharmacists record as normal, and the two are compared.
Gate · must be true to passRecord quality and edit rate within agreed limits, no missed red flags, clinical safety case and superintendent sign-off.
Drafts and the claims check go live in the pilot branches, with monitoring, support and a rollback plan.
Gate · must be true to passMonitoring, support model, rollback plan and pharmacist training in place.
Add pathways and branches in waves, then the prescriber-only pathways and the Pharmacy Contraception Service.
Gate · must be true to passEach new pathway passes the same pilot gate.
| Activity | Superintendent pharmacist | Product owner | Solutions architectI can fill this | Technical PMI can fill this | EngineersI can fill this | Clinical safety officer | IG & DPO | SecurityI can fill this |
|---|---|---|---|---|---|---|---|---|
| Business case and benefits | Accountable | Responsible | Consulted | Consulted | Informed | Consulted | Informed | Informed |
| Target architecture and supplier integration | Consulted | Consulted | Accountable and Responsible | Consulted | Consulted | Consulted | Consulted | Consulted |
| Clinical safety case and hazard log | Accountable | Consulted | Consulted | Informed | Consulted | Responsible | Informed | Consulted |
| DPIA and DSPT | Consulted | Consulted | Consulted | Informed | Informed | Consulted | Accountable and Responsible | Consulted |
| Build and integration | Informed | Consulted | Accountable | Responsible | Responsible | Consulted | Informed | Consulted |
| Pilot testing on real consultations | Accountable | Responsible | Consulted | Responsible | Responsible | Responsible | Informed | Informed |
| Go-live decision | Accountable | Responsible | Consulted | Responsible | Informed | Consulted | Consulted | Consulted |
| Run, monitor and improve | Accountable | Responsible | Consulted | Consulted | Responsible | Consulted | Consulted | Consulted |
R ResponsibleA AccountableC ConsultedI Informed· not involved
Option A
If there's no architect on the programme, I'd own the design end to end: how the assistant sits beside your assured clinical system, the integration with your supplier, the claims check and the gates, working closely with your clinical safety officer. I'd report to your programme board and your superintendent pharmacist.
Option B
If your partner, your clinical system supplier or your own team already has an architect, I'd take on the knowledge base, the agents and the claims reconciliation under their lead, and give them a second senior opinion on integration, security and the clinical safety evidence.
Goes wrong
The assistant answers from general knowledge, not the current pathway or PGD.
How the design avoids it
Retrieval from approved, versioned documents only, citations on every prompt, and guardrails on medicines and doses.
Goes wrong
Red-flag prompts slide into clinical advice, and the tool becomes a medical device without anyone deciding it should.
How the design avoids it
A narrow, written intended purpose, prompts drawn from the pathway's own criteria, and a regulatory view before the pilot.
Goes wrong
Pharmacists sign drafts without reading them.
How the design avoids it
Drafts that are short and specific, an edit-rate measure, and a weekly audit that reads the records against the consultations.
Goes wrong
The claims check turns into a way to make records qualify.
How the design avoids it
It only finds gaps. Only the consulting pharmacist can complete a record, and the claims team can't edit one.
Goes wrong
The design assumes an integration the clinical IT supplier doesn't offer.
How the design avoids it
Agree the supplier route in discovery, before anything is built.
Changes already announced or under way that affect this design. More in the UK horizon scan.
Design the claims check and GP notification for both routes, so the interim arrangements can be retired without rebuilding.
Make the assistant aware of whether the pharmacist is supplying under a PGD or prescribing, and show the right guidance for each.
Keep the hazard log and safety case structured and current, so moving to the new versions is an update, not a rewrite.
Write the intended purpose down now and review it against the new guidance as it lands.
Build on national standards such as GP Connect rather than one-off integrations, so the assistant can use a fuller record when it becomes available.
Good answers are specific. Vague answers to any of these are worth following up.
Whether you need someone to lead the design or to support the architect you already have, let's talk it through.
