Published: 04/03/2005

Consultation on independent prescribing for pharmacists

The long-awaited consultation on independent prescribing for pharmacists has now been published by the Department of Health (DH) and the Medicines and Healthcare products Regulatory Agency (MHRA; download document here; accessed 2/3).

It has been well received by the Royal Pharmaceutical Society of Great Britain (RPSGB), whose President Nicholas Wood said, “We very much welcome this initiative… It will complement both the new community pharmacy contract and the established clinical role undertaken by pharmacists in secondary care”.

The document provides a framework for considering the different options for extending independent prescribing to pharmacists, the benefits it would bring, whether different frameworks would be appropriate for different settings, and training, regulation and safety. It refers to the current arrangements for independent nurse prescribing, although the DH and MHRA have just published a consultation on extending that further (see news item here)

Option 1: No change
As at present, pharmacists would be able to use PGDs, to train as supplementary prescribers and to be able to supply and sell Pharmacy and General Sales List medicines.

Option 2: Prescribing for certain conditions from a limited formulary
This would mirror the current arrangements for extended formulary nurse prescribers (EFNPs) and would allow pharmacists to expand the range of services they can provide in the community and primary care. It would, however, be unlikely to meet the service needs of hospitals. Views are particularly sought on whether the Nurse Prescribers’ Extended Formulary (NPEF) and list of conditions would be suitable for pharmacist independent prescribing and whether there are changes needed.

Option 3: Prescribing for any condition from a limited formulary
From a specific formulary, pharmacists would be able to prescribe for any condition for which the medicine was appropriate (as per the BNF) and which they were competent to manage. It would be possible to exclude certain conditions and views are requested on whether there are conditions that should never be treated by pharmacists and whether the NPEF is suitable for pharmacist independent prescribing under this option.

[N.B. An equivalent proposal is Option B in the consultation on extending independent nurse prescribing; see news item here]

Option 4: Prescribing for specific conditions from a full formulary
Pharmacists could prescribe any medicine from the BNF but only for a specified list of conditions. It would be possible to exclude medicines deemed inappropriate. Opinions on which conditions, over and above those listed in the NPEF, are treatable by pharmacists, are particularly sought.

[N.B. An equivalent proposal is Option C in the consultation on extending independent nurse prescribing; see news item here].

Option 5: Prescribing for any condition from a full formulary
Pharmacists would be able to prescribe any medicine from the BNF for any condition, although it would be possible to exclude medicines deemed inappropriate. Views on this, and in particular on whether any classes of medicines are inappropriate for pharmacist prescribing, are sought.

[N.B. An equivalent proposal is Option D in the consultation on extending independent nurse prescribing; see news item here].

Option 6: Different approaches for different clinical settings
Depending on the setting – primary care, hospital, community for example – a different framework could be adopted to ensure the most safe and effective approach is used in each setting. For example, hospital pharmacists could prescribe from the whole BNF within their specialised areas, whereas community pharmacists might be able to meet patients’ needs using a formulary similar to the NPEF.

Option 7: A hybrid approach
Under this proposal, those pharmacists (in whatever setting) who have been given a diagnosis from GP or hospital consultant would be able to prescribe from the full BNF. Pharmacists in the community and primary care who do not have access to a diagnosis would prescribe from a limited formulary.

Selection, training and regulation
Training for NHS prescribing for pharmacists will be funded through the workforce directorates of SHAs and their equivalents outside England. NHS bodies will have responsibility for introducing pharmacist independent prescribing in their organizations and will need to take into account various issues including access to the patient record.

The RPSGB and the Pharmaceutical Society for Northern Ireland (PSNI) will be asked to develop an outline training curriculum. The supplementary prescribing curriculum will provide a good starting point but the new curriculum will need to reflect the wider requirements of independent prescribing, under whichever option is adopted. A single curriculum for independent and supplementary prescribers is a possible outcome.

After qualification, a pharmacist’s entry in the RPSGB or PSNI register will be amended. If different approaches are adopted for different settings, the register annotations may need to reflect this. Pharmacists will be expected to act only within their competence, referring where necessary, and the RPSGB and PSNI will take action against those not maintaining professional standards or ethics. Pharmacists will need to demonstrate that they are keeping their skills and knowledge current to maintain accreditation.

Safety
It is suggested that, as with supplementary prescribing, prescribing and dispensing should be done by different individuals wherever possible. In exceptional circumstances, the same person could do both, provided a final accuracy check is carried out by someone else and that appropriate clinical governance and audit arrangements are in place. Views on this question are specifically sought. Pharmacists will be required to monitor responses to treatments and to report adverse reactions.

All prescribers will need access to the information they need to make safe and informed treatments decisions and they must also be able to record interventions in a way that allows other professionals access to this information. At present, hospital pharmacists have access to the patient record, as do most of those in GP surgeries. This presents more of a difficulty for community pharmacists. Eventually, all pharmacist prescribers will have access to the patient record through the National Programme for IT but, until then, it will be the responsibility of the bodies setting up prescribing for pharmacists to ensure that the information required for safe and effective prescribing will be available to prescribers.

Risks and benefits
All the options apart from Option 1 will allow safe and effective practice to operate with benefits for patients and the service, meeting the government aims in extending prescribing practice. Independent prescribing by pharmacists will improve access to medicines for patients, increase patient choice, allow doctors and nurses to use their skills for patients who most need them, support the introduction of more flexible team working, and ensure that patients and the service receive maximum benefit from pharmacists’ professional skills. It could help achieve primary care access targets.

The process
Comments must be received by 25 May 2005. The Committee on Safety of Medicines (CSM) will then be asked to consider the proposals in the light of the responses and the views of the devolved administrations. The advice will then go to Ministers and, subject to their agreement, changes will be made by Statutory Instrument later this year.

 

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