non_medical_p
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http://www.kirklees.nhs.uk/fileadmin/documents/New/Public_Information/med_mgt/Policies/Non_Medical_Prescribing_Policy_August_2010.pdfTRANSCRIPT
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Non-Medical Prescribing Policy
Responsible Directorate:
Patient Care and Professions
Date Approved: 11th August 2010
Committee: Governance
Version: 2
Revision Date: 11th August 2013
Accountable Director: Sheila Dilks
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Contents
Section Page 1 Introduction 5
2 Associated Polices and Procedures 5
3 Aims and Objectives 5
4 Scope of the Policy 6
5 Accountabilities and Responsibilities 6
6 Forms of Non Medical Prescribing 7 7 PATIENT AND PUBLIC INVOLVEMENT
7.1 Patient Information
7.2 Patient Consent
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8 TRAINING FOR NON MEDICAL PRESCRBING
8.1 Nurses and Midwives
8.2 Pharmacists
8.3 Allied Health Professionals
8.4 All Applicants
8.5 Mentors
8.6 Support from an Experienced Non Medical Prescriber
8.7 The Course
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12 9 QUALIFICATION AS A NON MEDICAL PRESCRIBER
9.1 Actions by the Individual Non Medical Prescriber
9.2 Actions by the Line Manager
9.3 Actions by the Non Medical Prescribing Lead or Specialist Technician for Community and Support Services
9.4 Actions by Human Resources
9.5 Employment of a Non Medical Prescriber
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Section Page 10 PRACTICING AS A NON MEDICAL PRESCRIBER
10.1 Support for Non Medical Prescribing
10.1.1 Prescribing Across Organisational Boundaries
10.2 Accountability and Responsibility of a Non Medical Prescriber
10.2.1 Vicarious Liability/Indemnity Insurance
10.2.2 Continuing Professional Development (CPD)
10.2.3 Performance and KSF Development Review
10.2.4 Audit
10.2.5 Change of Role Within the Organisation
10.2.6 Return to Practice as a Non Medical Prescriber
10.2.7 Leaving a Non Medical Prescribing Role within the PCT
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11 PRESCRIBING PRACTICE
11.1 Principles of Prescribing
11.2 What Non Medical Prescribers can Prescribe
11.3 Prescribing Unlicensed Medicines
11.4 Prescribing Licensed Medicines for Use Outside Product License (Off Label)
11.5 Mixing Medicines in Clinical Practice
11.6 Controlled Drugs
11.7 Issuing Prescriptions
11.8 Prescription Writing
11.9 Reporting Arrangements and Record Keeping
11.10 Handling Adverse Drug Reactions (ADRs) and Medication Incidents
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12 GENERAL GUIDANCE
12.1 Recording and Security of Prescription Forms
12.2 Ordering and Supply of Prescriptions
12.3 Requirements for Handling Prescription Pads at Locality Bases
12.4 Ordering Prescription Pads
12.5 Loss or Suspected Theft of Prescriptions
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34 13 Equality Impact Assessment 35
14 Training Needs Analysis 35 15 Monitoring Compliance 35
16 References 36
Appendices A Definitions 38 B Key Stakeholders 39
C Equality Impact Assessment Tool 40 D Sign Off Sheet 41
E CPNP Intention to Prescribe Form 42 F Independent Prescribing Proforma 43-44
G Independent Prescribing Additions Form 45-46 H Supplementary Prescribing Clinical Management Plan (CMP) 47-48
I Community Nurse Prescribers and Nurse/Pharmacist Independent Prescribers Hand Held Prescription Pad Order Form (FP10/C)
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J Prescription Record Sheet for Non Medical Prescribers 50-51 K Application for Approval to Undertake Non-Medical Prescribing Course 52 L Course Details, Yorkshire and Humber SHA 53-54
M Good Practice Guidelines for the Safe and Secure Handling of Prescription Forms for Non-Medical Prescribers
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N Service Level Agreement 56-60
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POLICY STATEMENT
NHS Kirklees will develop non-medical prescribing practice to fulfil all statutory, organisational and
best practice requirements.
1. INTRODUCTION This policy provides operational procedures and a clinical governance framework to support non-medical prescribing within NHS Kirklees.
The policy covers:
• Community Practitioner Nurse Prescribers
• Nurse Independent/Supplementary Prescribers
• Pharmacist Independent/Supplementary Prescribers
• Optometrist Independent/Supplementary Prescribers
• Allied Healthcare Professional Supplementary Prescribers (Physiotherapists, Podiatrists, Radiographers and Optometrists).This list may expand to cover other Health Care Professionals given prescribing rights by the Department of Health.
This policy is a stand alone policy and is also included as an appendix to the NHS Kirklees Medicines Management Policy.
2. ASSOCIATED POLICIES, PROCEDURES AND GUIDANCE
This policy should be read in conjunction with the following policies and procedures:
• Medicines Management Policy • Incident Reporting Policy • Relevant professional and ethical standards for non-medical prescribers as defined by the appropriate professional body e.g. NMC, RPSGB etc.
3. AIMS AND OBJECTIVES The primary aim of this policy is to ensure that non-medical prescribing is delivered in a safe and effective manner within NHS Kirklees. Implementation will improve access to medicines without compromising patient safety and further utilise the skills of a range of practitioners resulting in increased flexibility of multidisciplinary working.
The purpose of this policy is to provide guidance for non-medical prescribers and to inform NHS Kirklees staff and those contracted to provide services for the PCT of the organizational processes involved. This includes:
• Forms of Non Medical Prescribing
• Selection/ identification of those to be trained
• Qualification as a Non Medical Prescriber
• Practice as a Non Medical Prescriber
• Accountability
• Prescription writing requirements and processes
• Record keeping
• Adverse Reactions
• Prescription queries
• Prescription pad security
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• Continuing Professional Development/Competencies
• Administration and Management Processes for NMP
4. SCOPE OF THE POLICY This policy will apply to all qualified non-medical prescribers, (NMPs), employed within NHS Kirklees who carry out the duties of independent/supplementary or formulary prescribing in their clinical role. Prescribing should be reflected as a key result area in an individual’s job description. Primary Care Contractors and their staff may also use this policy as a means of adopting good practice.
All Trust employees including those on temporary or honorary contracts, bank staff and students who are developing policy, procedural and guidance documents must follow the process set out in this document.
Independent Contractors are responsible for the development and management of their own documents and for ensuring compliance with relevant legislation and best practice guidelines. The Trust will provide such advice and support as required.
5. ACCOUNTABILITIES AND RESPONSIBILITIES
The Chief Executive has overall responsibility for the strategic and operational management of the PCT, including ensuring that Trust Policies comply with all legal, statutory, and good practice guidance requirements.
The Director of Patient Care and Professions has overall accountability for the safe and secure handling of medicines, supported by the Assistant Director for Medicines Management and the Medicines Management Committee.
All non medical prescribers employed by NHS Kirklees must familiarise themselves with the correct procedures contained within this policy. Those in charge of services are responsible for ensuring that their staff, particularly new starters and locums, follow procedures in this policy. Hard copies of the policy will be available to all staff through service leads and line managers. An electronic version will also be available on the PCT intranet.
The procedures also apply to non medical prescribers who are contracted to work for the PCT on a sessional basis. Managers who contract for these services must make it explicit within the written contract that these sessional staff MUST follow the procedures described in this policy.
All professionals are required to work within their Professional Code of Practice and terms of service.
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6. FORMS OF NON-MEDICAL PRESCRIBING
Non-medical prescribing is the term used to describe prescribing by health care professionals other than doctors and dentists. Non medical prescribers must comply with the current legislation for prescribing and be accountable for that practice.
Non Medical Prescribers include:
• Community Practitioner Nurse Prescribers
• Nurse Independent Prescribers
• Pharmacist Independent Prescribers
• Optometrist Independent Prescribers
• Supplementary prescribers
Further details on the mechanisms for non-medical prescribing can be found at:
http://www.dh.gov.uk/en/Healthcare/Medicinespharmacyandindustry/Prescriptions/TheNon-MedicalPrescribingProgramme/index.htm
Furthermore the Department of Health (2006) guidance1 should be referred to for Independent Nurse and Pharmacist Prescribing at:
http://www.dh.gov.uk/dr_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_4133747.pdf
Finally for guidance on Supplementary Prescribing the Department of Health (2005)2 should be consulted at:
http://www.dh.gov.uk/PublicationsAndStatistics/Publications/PublicationsPolicyAndGuidance/PublicationsPolicyAndGuidanceArticle/fs/en?CONTENT_ID=4110032&chk=c4V6nR
1 Department of Health (2006) Improving Patients Access To Medicines: A Guide to Implementing Nurse and Pharmacist
Independent Prescribing within the NHS in England. London: DH
2 Department of Health (2005) Supplementary Prescribing by Nurses, Pharmacists, Chiropodists/Podiatrists,
Physiotherapists and Radiographers within the NHS in England: a guide for implementation. London: DH
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7. PATIENT AND PUBLIC INVOLVEMENT
The DH (2006) asserts that non-medical prescribing provides benefits to patients as follows:
• Improved patient care without compromising patient safety;
• Easier and quicker access for patients to the medicines they need;
• Increased patient choice in accessing medicines;
• Better use of the skills of health professionals;
Non-medical prescribing assists the provision of more patient-centred services. It enables rapid access to medicines with the use of less health care professionals in the patient journey, thus enhancing the patient experience.
NHS Kirklees is committed to effective communications with patients and local people and will ensure that the patient experience is constantly being evaluated and improved upon. Furthermore the patient experience of non-medical prescribing will be captured by the audit arrangement of non-medical prescribing described in section 10.2.4 of this policy.
7.1 Patient Information Non Medical Prescribers must ensure that patients are aware they are being treated by a Non-Medical Prescriber and the scope of their prescribing practice may mean referral onto another health care professional if necessary.
Information leaflets on non-medical prescribing should be produced in different presentational formats to meet the differing language and visual needs of patients.
7.2 Patient Consent
Patients must be informed of the status of those prescribing medicines to them and provide their consent before a non-medical prescriber should proceed. This consent must be recorded in the patient’s notes.
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8. TRAINING FOR NON-MEDICAL PRESCRIBING
Before individual non-medical prescribers apply for training to become a non-medical prescriber, they and their supporting manager must confirm the following criteria.
8.1 Nurses and Midwives
To undertake the preparation programme to prescribe as a community practitioner nurse prescriber, the Nursing and Midwifery Council (2007) state that nurses and midwives should:
• Have practiced for a sufficient period to be deemed competent in the area they intend to practice. This would normally be a minimum of 2 years.
• Provide evidence via the Accreditation of Prior and Experiential Learning (APEL) process of their ability to study at minimum academic level three (degree level).
• Be assessed as being competent to take a history, undertake a clinical assessment and make a diagnosis. For example, they must be able to carry out a comprehensive assessment of the patient’s physiological and/or psychological condition, and understand the underlying pathology and the appropriate medicines regime.
To undertake the preparation programme to prescribe as a nurse independent/supplementary prescriber the DH (2006)1 and the Nursing and Midwifery Council (2006)3 state that nurses and midwives should:
• Have the ability to study at Level 3 (degree level).
• Normally have at least three years’ post-registration clinical nursing experience, of which at least one year immediately preceding their application to the training programme should be in the clinical area in which they intend to prescribe.
• Be assessed as being competent to take a history, undertake a clinical assessment and make a diagnosis. For example, they must be able to carry out a comprehensive assessment of the patient’s physiological and/or psychological condition, and understand the underlying pathology and the appropriate medicines regime.
8.2 Pharmacists
To undertake the preparation programme to prescribe as a pharmacist independent/supplementary prescriber the DH (2006)1 and the Royal Pharmaceutical Society of Great Britain (2006)4 state that pharmacists should:
• Have the ability to study at Level 3 (degree level).
3 Nursing and Midwifery Council (2006) Standards of Proficiency for Nurse and Midwife Prescribers. London: NMC
http://www.nmc-uk.org/aFrameDisplay.aspx?DocumentID=1645
4 Royal Pharmaceutical Society of Great Britain (2006) Outline Curriculum for Training Programmes to prepare
Pharmacist Prescribers. London: RPSGB http://www.rpsgb.org/pdfs/indprescoutlcurric.pdf
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• Have at least two years’ experience practicing as a pharmacist in a clinical environment, in a hospital or a community setting, following their pre-registration year after their graduation.
• Be competent to prescribe in the area in which they will prescribe following training.
• Demonstrate how they will develop their own networks for support, reflection and learning, including prescribers from other professions.
8.3 Allied Health Professionals
To undertake the preparation programme to become a supplementary prescriber the DH (2005)2 and the Health Professions Council (2005)5 state that allied health professionals should: • Have the ability to study at Level 3 (degree level).
• Normally have at least 3 years relevant post-qualification experience.
For Nurses, Midwives, Pharmacists and Allied Health Professionals seeking to prescribe as supplementary pescribers their competencies will be agreed by their medical mentor.
8.4 All Applicants For all applicants the PCT needs to:
• Approve the designated mentor, (for community practitioner nurse pescribers), and ensure the mentor has agreed to provide supervision for the duration of the programme. It is the responsibility of the applicant to identify this mentor who must be a practising community practitioner nurse prescriber.
• Approve the designated medical practitioner, (for independent/supplementary prescribers), hereafter referred to as the medical mentor, and ensure the mentor is willing and able to contribute to and supervise 12 days of learning in practice. It is the responsibility of the applicant to identify this mentor. See below for further requirements and guidance.
• Verify that the member of staff’s post is one in which they will have the need and opportunity to act as a prescriber immediately upon qualifying, with an appropriate prescribing budget in place.
• Ascertain whether the individual will need to prescribe for children and young people on qualification. If the individual is to prescribe for children and young people the PCT must ensure only non medical prescribers with relevant knowledge, competence, skills and experience in treating children and young people should prescribe for children and young
5 Health Professions Council (2005) Standards for Education and Training. London: HPC http://www.hpc-
uk.org/assets/documents/10000BCF46345Educ-Train-SOPA5_v2.pdf
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people. This is in compliance with NMC Circular 22/2007 http://www.nmc-uk.org/prescribing for children and young people
• Agree with the individual independent/supplementary non-medical prescriber the therapeutic area in which they will prescribe.
• Support staff undertaking their course whilst training.
• Support continuing professional development (CPD) opportunities related to their prescribing role on completion of the course. For more details contact the PCT training department or the PCT Non Medical Prescribing Lead.
• Provide written confirmation to the Higher Education Institution providing the training that the applicant has had a recent Criminal Records Bureau Check within the previous 2 years.
8.5 Mentors The mentor has a crucial and highly responsible role in teaching and assessing the non-medical prescriber and assuring competence in prescribing as identified by the Higher Education Institution providing the training. For community practitioner nurse prescribers the mentor:
• Must be an experienced practicing community practitioner nurse prescriber. For independent/supplementary prescribers the medical mentor:
• Has normally had at least 3 years medical, treatment and prescribing responsibility for a group of patients/clients in the relevant field of practice.
• Is within a GP practice and is either vocationally trained or is in possession of a certificate of equivalent experience from the Joint Committee for Post-graduate Training in General Practice Certificate or is a specialist registrar, clinical assistant or a consultant within NHS Kirklees.
• For those non medical prescribers intending to prescribe for children and young people, should be experienced and competent in prescribing for children and young people to confirm the demonstration of competence for those wishing to prescribe for this age group on qualification.
• Has some experience or training in teaching and/or supervising in practice
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Support for the Medical Mentor
The National Prescribing Centre (2005)6 has produced a guide to help doctors prepare for and carry out the role of the medical mentor. This guide can be found at: http://www.npc.co.uk/npc_publications/resources/designated_medical_practitioners_guide.pdf The University chosen for non-medical prescribing training may also provide medical mentor
training as well as support by the course leader.
8.6 Support from an Experienced Non Medical Prescriber
The Nursing and Midwifery Council states that practice assessment in Independent/Supplementary prescribing programmes is the legal responsibility of a designated medical practitioner who supports, teaches and supervises the student with, where possible, an experienced non medical prescriber who should ensure that the learning is applied to specific areas of practice. NHS Kirklees supports this statement and will where possible seek to allocate an experienced non medical prescriber to assist non medical prescribing students apply their learning to their specific area of practice.
8.7 The Course
Course details can be obtained from the Higher Education Institution to which the applicant wishes to apply. See appendix L for course details within the Yorkshire and the Humber Strategic Health Authority.
Applicants should seek approval from the PCT Non Medical Prescribing Lead before applying to undertake a prescribing course. Applicants should complete the ‘Approval to Undertake Non Medical Prescribing Course’ form (appendix K) and return, together with the university application form, to the Non Medical Prescribing Lead.
Once agreement to train as a non medical prescriber has been reached, the applicant must apply for study leave as per PCT policy.
Without management agreement, study leave approval, an agreed mentor and approval from the PCT Non Medical Prescribing Lead, application to the non medical prescribing courses must not be made.
6 National Prescribing Centre (2005) Training Non-Medical Prescribers in Practice: A guide to help doctors prepare for
and carry out the role of designated medical practitioner. Liverpool: National Prescribing Centre
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9. QUALIFICATION AS A NON-MEDICAL PRESCRIBER
The following subsections describe the actions to be taken when an individual non-medical prescriber successfully completes their prescribing training by:
• The individual non-medical prescriber
• Their line manager
• The Non-Medical Prescribing Lead or Specialist Technician for Community & Support Services
• Human Resources by completion of a ‘Changes to Staff Contract Form’ with their line manager.
9.1 Actions by the Individual Non-Medical Prescriber
Once the individual non-medical prescriber has successfully completed their prescribing training, they will be notified by the relevant Higher Education Institution. The Higher Education Institution also notifies:
• The Nursing and Midwifery Council in the case of Nurses and Midwives
• The Royal Pharmaceutical Society of Great Britain in the case of Pharmacists
• The Health Professions Council in the case of Physiotherapists, Podiatrists, Radiographers, and Optometrists
The relevant regulatory body will then make the appropriate non-medical prescribing annotation on the register for the individual non-medical prescriber. Any costs associated with recording their qualification with the appropriate regulatory body will be met by the individual non-medical prescriber. The individual non-medical prescriber cannot legally prescribe until this annotation has been made.
Once the individual non-medical prescriber has received notification from the relevant regulatory body that an annotation has been made on the register they must provide a copy to:
• Their line manager
• The PCT Non-Medical Prescribing Lead Before prescribing can take place the non-medical prescriber must:
• Ensure their job description reflects their non-medical prescribing role. The job description MUST state that non medical prescribing is a requirement for the post. (For PCT/KCHS employed staff ensure Human Resources have received a completion of a ‘Changes to Staff Contract Form’ from your line manager)
• Be registered with the NHS Business Services Authority as follows:
• Community Practitioner Nurse Prescribers must complete the CPNP intention to prescribe form (appendix E), and return to the Specialist Technician for Community & Support Services or Non Medical Prescribing Lead.
• Independent/Supplementary Prescribers must complete the Independent Prescribing proforma, (appendix F), and return to the Specialist Technician for Community & Support Services or Non Medical Prescribing Lead.
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9.2 Actions by the Line Manager
The line manager will ensure that they:
• View a copy of the individual non-medical prescriber’s course results letter and notification of annotation to the register from the relevant regulatory body.
• Ensure that the individual non-medical prescriber’s job description refers to their non-medical prescribing role. The Job description MUST state that Non medical prescribing is a requirement for the post. (For PCT/KCHS employed staff, complete a ‘Changes to Staff Contract Form’ and submit to Human Resources).
• Sign the completed independent prescribing proforma, (for independent/supplementary prescribers), or the CPNP intention to prescribe form, (for community practitioner nurse prescribers), to confirm that prescribing is a requirement of that non-medical prescriber’s role.
9.3 Actions by the Non-Medical Prescribing Lead or Specialist Technician for Community & Support Services
The PCT Non Medical Prescribing Lead and/or Specialist Technician – Community and Support Services will be responsible for:
• Registering the non medical prescriber with the NHS Business Services Authority.
• Entering the individual non-medical prescriber’s non-medical prescribing status on the non-medical prescribing data base.
• Sending the independent prescribing proforma or CPNP intention to prescribe form to the newly qualified non medical prescriber.
• Verifying that the prescribing qualification is annotated on the relevant regulatory body’s register as follows:
The Nursing and Midwifery Council at:
http://www.nmc-uk.org/aSection.aspx?SectionID=19
The Royal Pharmaceutical Society of Great Britain at:
http://www.rpsgblist.org/membership.asp
The Health Professions Council at:
http://www.hpcheck.org/lisa/onlineregister/MicrositeSearchInitial.jsp
9.4 Actions by Human Resources
Human Resources will be responsible for receiving and retaining on file the individual non-medical prescriber’s:
• Changes to Staff Contract Form
• Revised job description
• Proof of CRB check if appropriate.
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9.5 Employment of a Non-Medical Prescriber
When NHS Kirklees/KCHS employs a non-medical prescriber that they have not supported through training, the individual non-medical prescriber, their line manager, the PCT Non Medical Prescribing Lead and Human Resources need to act in accordance with sections 9.1 to 9.4 of this policy. The individual MUST demonstrate they have completed the appropriate training and have their competencies assessed before applying to be registered as a non medical prescriber within NHS Kirklees.
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10. PRACTICING AS A NON-MEDICAL PRESCRIBER
Section 10 is divided into 2 main subsections each subsection dealing with different aspects of practice as a non-medical prescriber. The subsections are:
• Support for non-medical prescribing (10.1)
• Accountability and responsibility as a non-medical prescriber (10.2)
10.1 SUPPORT FOR NON-MEDICAL PRESCRIBING
Provision of Support
The following table details the support for non-medical prescribing and the responsibilities of key personnel in the provision of this support:
Support Responsibility
Provision of a current BNF/NPF
Medicines Management Team when editions are delivered - normally in March and September of each year. Nurse prescribers will be provided with an NPF when published -normally biannually in September.
Information relating to pharmacovigilance and other non-medical prescribing related updates
PCT non-medical prescribing lead when notified.
Medicines information Medicines Management Team or individual Practice Support Pharmacists.
Prescription pads
Sourced by WYCSA and delivered to either Locality Bases or GP Practice. PCT Individual non-medical prescribers collect from Locality Base.
Arrangement for cross boundary prescribing. Line manager to complete cross boundary agreement (appendix N) and forward to PCT Non Medical Prescribing Lead.
Buddying for Non-Medical Prescribers
The DH (2006) recommends buddying for non-medical prescribers. NHS Kirklees accepts this recommendation. Support from other professional colleagues is invaluable to non-medical prescribers, especially to those who are newly qualified. A buddy or mentor could be a doctor or another non-medical prescriber. The PCT will encourage the engagement of newly qualified non-medical prescribers with buddying and furthermore will encourage doctors, non-medical prescribers and line managers to provide this role.
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Supplementary Prescribing for Nurses, Midwives and Pharmacists
The DH (2006) notes that supplementary prescribing is a useful mechanism to enable new non-medical prescribers to develop their expertise and confidence in prescribing. NHS Kirklees accepts this recommendation. Non-medical prescribers will be encouraged to prescribe following qualification as a supplementary prescriber to gain expertise and confidence and will also encourage doctors and managers to assist with this process.
Clinical Supervision
The DH (2006) recommends that nurse and pharmacist independent prescribers should use clinical supervision arrangements or equivalent as an opportunity for reflection on prescribing, as well as other aspects of practice. NHS Kirklees accepts this recommendation for all of its non-medical prescribers. The model of clinical supervision should be agreed at local level, taking into account;
clinical supervision is regular, protected time for facilitated, in-depth reflection on clinical practice. It aims to enable the supervisee to achieve, sustain and creatively develop a high quality of practice through means of focus, support and development. (Bond,1998).
Non-Medical Prescribers Network
It may be helpful for PCT/KCHS Non-Medical Prescribers and those undergoing training to form network links. Any issues can be discussed and concerns taken forward to the Non-Medical Prescribing Sub Committee which is accountable to Kirklees PCT Medicines Management Committee.
10.1.1 Prescribing Across Organisational Boundaries
The practice of some Non Medical Prescribers necessitates prescribing across the boundaries of local NHS organisations e.g. a PCT employed independent non medical prescriber may have to treat a patient within the hospital setting. Or it may occur through an honorarium contract between two organizations e.g. Tissue Viability nurses employed by a Secondary Care Trust who during the course of their duties are required to prescribe for patients in primary care using the local Primary Care Trusts’ prescription pads.
An agreement has been drawn up to ensure that the proper elements and commitment are in place to provide optimal services and addresses risk management issues from an accountability, responsibility, quality and resource perspective for the prescribing practice of these non-medical prescribers.
The non-medical prescriber must comply with any terms and conditions relating to ordering and/or receipt of prescription pads/treatment charts as outlined in the service receivers’ non medical prescribing policy/framework.
Any resources required specifically for the prescribing setting should be provided by the receiver organization, for whom the individual is undertaking prescribing duties
If you will be required to prescribe outside this organisation’s boundaries you must discuss with the Non-medical Prescribing Lead at the relevant organisation
� Calderdale and Huddersfield Foundation Trust Mike Culshaw � Mid Yorks Hospitals Trust Philip Shaw � South West Yorkshire Partnership NHS Foundation Trust Lynn Haygarth
In addition you must inform both the PCT and service receiver organisations’ Non-medical prescribing lead(s), and complete the proforma in appendix N.
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10.2 ACCOUNTABILITY AND RESPONSIBILITY AS A NON-MEDICAL PRESCRIBER
Professional Accountability and Responsibility
All non-medical prescribers must work within their own level of professional knowledge and competence, and must seek advice and make appropriate referrals to other professionals with different expertise. Non-medical prescribers are accountable for their own actions and must be aware of the limits of their knowledge and competence.
Nurses and Midwives must act according to:
• Nursing and Midwifery Council (2008) Code of Professional Conduct: Standards of Conduct, Performance and Ethics. Available at: http://www.nmc-uk.org/aDisplayDocument.aspx?documentID=5982
• Nursing and Midwifery Council (2006) Standards of Proficiency for Nurse and Midwife Prescribers. Available at:
http://www.nmc-uk.org/aDisplayDocument.aspx?documentID=6942
Pharmacists must act according to:
• Royal Pharmaceutical Society of Great Britain’s (2007) Code of Ethics and Standards. Available at: http://www.rpsgb.org.uk/pdfs/coeppt.pdf
Allied Health Professionals must act according to:
• Health Profession Council’s (2008) Standards of Conduct, Performance and Ethics. Available at: http://www.hpc-uk.org/assets/documents/10002367FINALcopyofSCPEJuly2008.pdf
Furthermore Allied Health Professionals must abide by their respective Standards of Proficiency as thus:
Physiotherapists
http://www.hpc-uk.org/assets/documents/10000DBCStandards_of_Proficiency_Physiotherapists.pdf
Podiatrists
http://www.hpc-uk.org/assets/documents/10000DBBStandards_of_Proficiency_Chiropodists.pdf
Radiographers
http://www.hpc-uk.org/assets/documents/10000DBDStandards_of_Proficiency_Radiographers.pdf
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All non-medical prescribers must abide by non-medical prescribing related PCT policies and procedures as described in the PCT Medicines Management Policy, A Guide to the Safe and Secure Handling of Medicines7
Finally should independent/supplementary prescribers seek to prescribe additional items not approved in their independent prescribing proforma, they should complete an additions form, (appendix G), which should be submitted to the Non Medical Prescribing Lead
10.2.1 Vicarious Liability/ Indemnity Insurance
Where a PCT/KCHS employed nurse, midwife, pharmacist or allied healthcare professional is appropriately qualified and prescribes within their agreed area of practice, as part of their professional duties with the consent of the employer, the PCT/KCHS is vicariously liable for their acts and omissions.
For Non Medical Prescribers who are directly employed by GPs or other commissioned services, the responsibility for vicarious liability/indemnity insurance lies with the individual prescriber and their employer.
It is the personal responsibility of ALL Non Medical Prescribers to ensure arrangements for vicarious liability/indemnity insurance provides a suitable level of protection for their intended prescribing practice.
10.2.2 Continuing Professional Development (CPD)
NHS Kirklees accepts the recommendation from the DH (2006) that non-medical prescribers must keep up to date with evidence and best practice in the management of the conditions for which they prescribe and in the use of the relevant medicines.
Furthermore the respective regulatory bodies all stipulate CPD requirements and non-medical prescribers must fulfill these obligations in terms of both their prescribing role and their wider practice. Therefore NHS Kirklees requires each non-medical prescriber to use CPD as a means of enhancing their professional knowledge and competence related to their non-medical prescribing role.
To assist non-medical prescribers review their competency, the National Prescribing Centre have produced a series of competency frameworks which can be found at the following link:
http://www.npc.co.uk/prescribers/resources/maintain_comp_prescribing.pdf
NHS Kirklees encourages non-medical prescribers to use these frameworks to review their competence in non-medical prescribing.
CPD takes a variety of forms8. Examples of how individual non-medical prescribers may undertake CPD include:
7 The Medicines Management Policy can be found via the PCT website at:
http://www.kirklees.nhs.uk/uploads/tx_galileodocuments/Medicines_Management_Policy_January_2009.pdf
8 Bramley, I (2006) Continuing Professional Development: what is it and how do I get it?
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• Attendance at external formal events such as conferences or events delivered by Universities
• Attendance at PCT study events
• Attendance at non-medical prescribing network meetings
• Buddying
• Time spent with medical colleagues on relevant prescribing activities.
• Reviewing their competence using the National Prescribing Centre competency frameworks
• Undertaking audit
CPD remains the responsibility of the non-medical prescriber. It is the responsibility of the non-medical prescriber to keep up to date in their field of practice and any changes in national and local policy. Individual non-medical prescribers will negotiate their CPD requirements using the PCT performance and KSF development review process.
The line manager should ensure that CPD is encouraged to maintain competence in their clinical area.
10.2.3 Performance and KSF Development Review
The Performance and KSF Development review will facilitate non-medical prescribing in two key ways:
• The identification of individual non-medical prescribers suitable to train as non-medical prescribers.
• The ongoing review of performance related to non-medical prescribers once trained. Non-medical prescribers should include prescribing as part of their review annually in order to continue in this role. Once such a review has been undertaken, non-medical prescribers should notify the PCT Non-Medical Prescribing Lead and the date should be recorded on the non-medical prescribing database.
Annual Declaration of Competence Each year, as part of their annual review, all Non-Medical Prescribers will be asked to declare ongoing competence. Details will be recorded within the individual’s IPR.
10.2.4 Audit
Audit is an essential element of the clinical governance of non-medical prescribing. Within the organisation audit will operate at two levels:
• PCT level - the PCT will audit non-medical prescribing as a means of determining the standard of current non-medical prescribing practice and future service requirements.
• Non-medical prescriber level - non-medical prescribers will audit their own prescribing practice as a means of demonstrating its quality. However non-medical prescribers can fulfill such audit requirements by participating in audit being undertaken within their prescribing team.
Nurse Prescribing, Volume 4, Number 3, Pages 117 -121
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10.2.5 Change of Role Within the Organisation
Non-medical prescribers may change their role within an organisation as a result of:
• Career development
• Service redesign
• Succession planning The non-medical prescriber should notify the Non Medical Prescribing Lead or Specialist Technician for Community and Support Services of any role change so that the PCT database of prescribers can be amended to reflect the non-medical prescriber’s new prescribing area.
If a non-medical prescriber moves to another area of practice they must consider the requirements of their new role and only ever prescribe within their own level of knowledge and competence.
• Existing prescribing competence. If a non-medical prescriber moves to a new area, they can prescribe within their expertise gained in their previous prescribing area, for example if from a dermatology background the non-medical prescriber can prescribe within this area for patients with these conditions if this is appropriate within the new team.
• Continuing professional development (CPD) needs. The non-medical prescriber and their new manager must work in partnership to identify individual non-medical prescribing CPD needs within their new area of practice. Individual CPD needs will determine the length of time it takes for a non-medical prescriber who has moved practice areas, to feel confident and competent to prescribe in their new area of practice. This must be incorporated into the Performance and KSF Development Review process. The non-medical prescriber is responsible for attaining the knowledge and competence that will give them the skills to apply the principle of prescribing in a new area. It would be good practice to undertake reflective supervision with the prescribing team in practice, which should include the lead clinician.
• Independent prescribing. Before independent prescribing can take place a new independent prescribing proforma (see appendix F) must be completed and submitted to the Non Medical Prescribing Lead. The non-medical prescribing data base will then be amended by the PCT Non Medical Prescribing Lead or Specialist Technician – Community and Support Services to reveal the individual non-medical prescriber’s new prescribing area.
• Supplementary prescribing. Before supplementary prescribing can take place the non-medical prescriber and the independent prescriber involved must be satisfied that the individual non-medical prescriber has achieved the necessary knowledge and competence in their new area of prescribing practice. A clinical management plan must then be completed as required by the DH (2005) (see appendix H). For those only prescribing on a supplementary basis, the non-medical prescribing data base will be amended by the PCT Non Medical Prescribing Lead or Specialist Technician – Community and Support Services to reveal the individual non-medical prescriber’s new prescribing area.
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10.2.6 Return to Practice as a Non-Medical Prescriber
A non-medical prescriber may complete return to practice requirements laid down by their regulatory body and wish to resume non-medical prescribing. The individual non-medical prescriber and their line manager will need to:
• Assess prescribing competence - this will be undertaken using the PCT performance and KSF development review process. The individual non-medical prescriber’s personal portfolio will also be of use in determining existing competence and continuing professional development needs. Individuals will be encouraged to review their prescribing competency using the National Prescribing Centre competency frameworks detailed in section 10.2.2 of this policy. The non-medical prescriber and new manager must work in partnership to identify individual non-medical prescribing CPD needs within their new area of practice.
• Continuing professional development (CPD) needs - individual CPD needs will determine the length of time it takes for a non-medical prescriber who has returned to practice to feel confident and competent to prescribe in their area of practice. This must be incorporated into the Performance and KSF Development Review process. The non-medical prescriber is responsible for attaining the knowledge and competence that will give them the skills to re-apply the principle of prescribing. It would be good practice to undertake reflective supervision with the prescribing team in practice, which should include the lead clinician.
• Independent prescribing - before independent prescribing can take place an independent prescribing proforma, (appendix F), must be completed and submitted to the Non Medical Prescribing Lead. The non-medical prescribing data base will then be amended by the PCT Non Medical Prescribing Lead or Specialist Technician for Community and Support Services to reveal the individual non-medical prescriber’s prescribing area following return to practice.
• Supplementary prescribing - before supplementary prescribing can take place the non-medical prescriber and the independent prescriber involved must be satisfied that the individual non-medical prescriber has achieved the necessary knowledge and competence in their new area of prescribing practice. A clinical management plan must then be completed as required by the DH (2005) (see appendix H). For those only prescribing on a supplementary basis, the non-medical prescribing data base will be amended by the PCT Non Medical Prescribing Lead or Specialist Technician – Community and Support Services to reveal the individual non-medical prescriber’s prescribing area following return to practice.
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10.2.7 Leaving a Non-Medical Prescribing Role Within the PCT
The following actions must be undertaken when a non-medical prescriber leaves the organisation.
The Non-Medical Prescriber should:
• KCHS/PCT staff must return all unused FP10 prescription forms to the Locality Manager’s PA or service secretary for recording and shredding.
• GP practice staff must return all unused FP10 prescription forms to the Practice Manager who will then return them to WYCSA.
• All staff should notify the Specialist Technician for Community and Support Services to be de-registered with the NHS Business Services Authority.
The Line Manager must:
• Notify, or ensure that the Non Medical Prescribing Lead or Specialist Technician for Community and Support Services has been notified, so that the non-medical prescriber can be de-registered with the NHS Business Services Authority.
• Notify Human Resources.
• Ensure all unused FP10 prescription forms are returned to the Locality Managers PA or service secretary for recording and secure shredding (for KCHS/PCT staff).
• For GP practice staff unused FP10 prescription forms must be returned to WYCSA.
The PCT Non-Medical Prescribing Lead or Specialist Technician for Community and Support Services must:
• Remove the individual non-medical prescriber from the non-medical prescribing database. • Notify the NHS Business Services Authority and WYCSA Support Services to request the
non medical prescriber is removed from their databases.
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11. PRESCRIBING PRACTICE
11.1 Principles of Prescribing
The following principles should be applied to all prescribing:
• Ensure that the treatment prescribed is both safe and cost effective and meets the clinical needs of the patient.
• Prescribing should follow PCT formularies and guidelines where possible.
• Patients requiring treatments should have their needs continually assessed and prescriptions issued should reflect assessed need.
• If requested to prescribe large quantities for patients travelling abroad, prescribers should be aware that a patient ceases to be registered with a GP after 3 months absence from the country.
More information on prescribing principles is available in the PCT Medicines Management Policy.
11.2 What Can be Prescribed by Non-Medical Prescribers?
Community Nurse Practitioners who have completed the necessary training can prescribe only items listed in the Nurse Prescribers’ Formulary for Community Practitioners (NPF). This can be found in the appendix of the British National Formulary (BNF) and in part XVIIB(i) of the Drug Tariff.
Nurse Independent Prescribers who have completed the necessary training programme can prescribe any licensed medicine for any medical condition, including some controlled drugs. The disease management areas that prescriptions are to be issued for must have been agreed and approved prior to any prescribing taking place. See section 9.1.
Pharmacist Independent Prescribers can also prescribe any licensed medicine for any medical condition but currently cannot prescribe any Controlled Drug independently. See section 9.1.
Supplementary prescribing was introduced in April 2003 for nurses and pharmacists. It was extended to physiotherapists, chiropodists/podiatrists, radiographers and optometrists in May 2005.
Supplementary prescribing is a voluntary prescribing partnership between the independent prescriber (doctor or dentist) and supplementary prescriber, to implement an agreed patient-specific clinical management plan (CMP), with the patient’s agreement.
Following agreement of the CMP, the supplementary prescriber may prescribe any medicine for the patient that is referred to in the plan, until the next review by the independent prescriber. There is no formulary for supplementary prescribing, and no restrictions on the medical conditions that can be managed under these arrangements. Supplementary Prescribers can prescribe Controlled Drugs and unlicensed medicines in partnership with a doctor, where the doctor agrees within a patient’s CMP
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Non medical prescribers may prescribe only:
• For patients they have personally assessed.
• Using their own prescription pad or personalised computerised prescriptions.
• With an agreed Clinical Management Plan (CMP) for Supplementary Prescribers
• Only as described in the formulary for community nurse practitioner prescribers.
• Within their own agreed level of professional competence and expertise
• No more than six repeat prescriptions, and only for patients they have reviewed within the last six months
Non medical prescribers may not prescribe:
• Outside their own agreed areas of competence and expertise.
• For themselves, family, friends or colleagues.
• On another prescribers prescription pad
• On behalf of another person
• To replace an item that has been administered to a patient using GP or clinic stock items.
• For patients in GP practices not covered within the PCT or which a prescribing budget has not been agreed.
• For patients they believe may have received a recent prescription for the same product but have been unable to assess the relevant documentation.
11.3 Prescribing Unlicensed Medicines From 21st December 2009 legislation changed to allow nurse and pharmacist independent prescribers to prescribe unlicensed medicines for their patients, on the same basis as doctors and dentists (and supplementary prescribers if part of a Clinical Management Plan9). Medicines prescribed should be licensed, and licensed for the indication for which they are to be prescribed. Prescribing an unlicensed medicine increases the clinical and legal liabilities on the prescriber. Before prescribing an unlicensed medicine the prescriber must ascertain that a reasonable body of medical opinion would support the use of the product in that way (or expert guidelines support its use), and that there is no suitable licensed alternative. In all cases of “unlicensed ” prescribing within NHS Kirklees, the prescriber is fully accountable and liable for their actions and must be satisfied that:
• An alternative licensed treatment would not meet the patient’s needs.
• The prescribed drug and indication is within their area of competence.
• There is satisfactory evidence or experience of safety in prescribing the medication in the circumstances faced.
• The patient or carer understands that they are being prescribed an unlicensed medication, understands the implications of this, and gives consent
Legal responsibility for any prescription lies with the person who signs the prescription. It is the responsibility of prescribers to be aware of the license status of products they prescribe.
9 The status of unlicensed medicines must be recorded on the Clinical Management Plan.
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Patients MUST be informed of the license status and their consent gained. This discussion must be documented in the patient’s record. Important Note: In the case of both unlicensed and “off label” prescribing it is the personal responsibility of each prescriber to ensure they have a suitable level of indemnity protection for their prescribing practice.
11.4 Prescribing Licensed Medicines for Use Outside their Product License -“Off- Label” Prescribing Independent Prescribers may prescribe medicines outside their licensed indications (off-label) where it is accepted clinical practice. In doing so, they are fully accountable and liable for their actions, and should comprehensively document their reasons for prescribing. Supplementary prescribers may prescribe medicines outside their license if they are included in relevant Clinical Management Plans. Supplementary prescribers are also fully accountable and liable for such prescribing and should comprehensively record their reasons for prescribing. Community Practitioner Nurse Prescribers (CPNPs) may not prescribe medicines off-label, except for nystatin oral suspension for neonates under 1 month of age, where the diagnosis of oral thrush is absolutely clear. In these circumstances, it should be prescribed at the dose recommended in the BNF for Children. This exception is without precedent and there are no other exceptions for off-label prescribing by CPNPs.
In all cases of “off-label” prescribing within NHS Kirklees, the prescriber is fully accountable and liable for their actions and must be satisfied that:
• An alternative licensed treatment would not meet the patient’s needs.
• The prescribed drug and indication is within their area of competence.
• There is satisfactory evidence or experience of safety in prescribing the medication in the circumstances faced.
• The patient or carer understands that they are being prescribed an unlicensed medication, understands the implications of this, and gives consent.
Important Note: In the case of both unlicensed and “off label” prescribing it is the personal responsibility of each prescriber to ensure they have a suitable level of indemnity protection for their prescribing practice.
11.5 Mixing Medicines in Clinical Practice
Mixing of Medicines
From 21st December 2009 legislation changed to allow pharmacist independent prescribers and nurse independent prescribers to mix medicines to produce an unlicensed medicine, where the “mixing of medicines” means the combining of two or more medicinal products together for the purposes of administering them to meet the needs of a particular patient In a registered pharmacy, hospital, care home service or health centre, legislation already enables medicines to be mixed, by or under the supervision of a pharmacist.
A supplementary prescriber can mix medicines to produce an unlicensed medicine but only where the mixing of medicines forms part of the clinical management plan for an individual patient.
The mixing of medicinal products to produce an unlicensed medicine can also be undertaken by another person acting on the written directions of a pharmacist independent prescriber, a nurse
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independent prescriber or by a supplementary prescriber where the mixing of the medicines forms part of the clinical management plan for an individual patient.
The mixing of drugs should be avoided unless essential to meet the needs of the patient, and that those involved in both the prescribing and actual mixing should be competent to do so and take full professional and clinical responsibility for their actions. In addition such actions must be within the governance structures and guidance of the employing authority and of the relevant statutory bodies.
This change in legislation does not apply to the mixing of Controlled Drugs.
The Medicines (Exemptions and Miscellaneous Amendments) Order 2009 SI 3062:
www.opsi.gov.uk/si/si2009/uksi_20093062_en_1
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11.6 Controlled Drugs
All non-medical prescribers must abide by the PCT policy for controlled drugs. This can be found at: http://www.kirklees.nhs.uk/public-information/policies-and-procedures/medicines-management/
Only nurse independent prescribers may prescribe some Controlled Drugs independently. However the nurse independent prescriber must have specified which of the following controlled drugs he/she intends to prescribe on the independent prescribing proforma (see appendix F), which needs to be submitted to the Non Medical Prescribing Lead.
Nurse Independent Prescribers are able to prescribe independently the following list of Controlled Drugs for the medical conditions indicated:
Table 1
DRUG INDICATION ROUTE
Buprenorphine Transdermal use in palliative care Transdermal
Chlordiazepoxide Hydrochloride
Treatment of initial or acute withdrawal symptoms caused by the withdrawal of alcohol from persons habituated to it.
Oral
Codeine Phosphate
N/A Oral
Co-phenotrope N/A Oral
Diamorphine
Hydrochloride
Use in palliative care, pain relief in respect of suspected myocardial infarction or for relief of acute or severe pain after trauma, including in either case post-operative pain relief
Oral, parenteral
Diazepam
Use in palliative care, treatment of initial or acute withdrawal symptoms caused by the withdrawal of alcohol from persons habituated to it, tonic-clonic seizures
Oral, parenteral,
rectal
Dihydrocodeine tartrate
N/A Oral
Fentanyl Transdermal use in palliative care Transdermal
Lorazepam Use in palliative care, tonic-clonic seizures Oral, parenteral
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Midazolam Use in palliative care, tonic-clonic seizures Parenteral, buccal
Morphine Hydrochloride
Use in palliative care, pain relief in respect of suspected myocardial infarction or for relief of acute or severe pain after trauma, including in either case post-operative pain relief.
Rectal
Morphine Sulphate
Use in palliative care, pain relief in respect of suspected myocardial infarction or for relief of acute or severe pain after trauma, including in either case post-operative pain relief.
Oral, parenteral,
rectal
Oxycodone Hydrochloride
Use in palliative care Oral, parenteral
For the purposes of nurse independent prescribing, palliative care means the care of patients with advanced, progressive illness.
*Note* The Home Office have consulted on independent prescribing of controlled drugs by nurse and pharmacist independent prescribers. The consultation ended on June 15th 2007. Should legislation be amended which permits changes to controlled drug prescribing by independent nurse and pharmacist prescribers, this policy will be amended.
11.7 Issuing Prescriptions
An independent prescriber can only issue a prescription for a patient whom they have personally assessed for care and should only write prescriptions on a prescription pad bearing their own unique prescriber number or on an in-patient drug chart. A supplementary prescriber can only issue a prescription for a patient who has an agreed clinical management plan and should only write prescriptions on a prescription pad bearing their own unique prescriber number. Staff qualified to prescribe should not issue prescriptions on behalf of colleagues. Accountability for the prescription rests with the non-medical prescriber who has issued the prescription. Non-medical prescribers within the PCT can only prescribe for patients of a GP contracted with NHS Kirklees and for whom the GP has responsibility under the NHS. This includes patients temporarily registered with a GP. The exceptions are non medical prescribers working in Walk-In-Centres or practices who routinely see non-registered patients, such as the Equitable Access Centre for Dewsbury, or where a cross boundary prescribing agreement is in place - see section 10.1.1.
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11.8 Prescription Writing
For further guidance refer to Prescription writing: British National Formulary. For information about prescription form types refer to appendix E of the PCT Medicines Management Policy.
• Writing must be clear and legible using indelible ink
• A line should be inserted between each item being prescribed
• Space should be blocked out using a ‘Z’ line
• Prescriptions may be computer generated if this facility is available
• The prescription must be completed with the following details:
(1) Patient Details:
• Full Name (forename and surname)
• Full Address (including postcode)
• Age & Date of Birth should preferably be stated. This is a legal requirement when prescribing Prescription Only Medicines to children under 12 years of age.
(2) Details of the items to be supplied:
• Name, form and strength
• Dose and frequency
• Directions
• Quantity
• Signature & date
• Code for the practice where the patient is registered
• Non medical prescribers correct contact telephone number
The names of medicines should be written clearly using approved generic titles, wherever possible.
Prescribers working for more than one organisation or practice will need separate prescription pads corresponding to the organisation or practice for which they are to prescribe.
Prescribers employed by the PCT/KCHS and working across different practices can use one prescription pad, but must add the relevant practice number for each patient for whom they prescribe.
It is the responsibility of the non medical prescriber and employer to ensure the security of the prescription pads at all times.
11.9 Reporting Arrangements and Record Keeping All Non-Medical Prescribers are required to keep records, which are unambiguous and legible. Prescription details must be entered immediately into the prescriber’s patient records / parent-held child health records / professional record / medication sheet, as appropriate. The record of all non-medical prescriptions should clearly indicate: • Date • Name of prescriber • Name and form of item prescribed
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• Dosage schedule • Route of administration • Quantity (where possible) and frequency of application (for topical)
• Advice given
GP records should be amended as soon as possible. Notification of any prescription must be forwarded to the relevant GP within 48 hours. In some situations it may be necessary to advise the GP immediately of the prescription. In these circumstances the action should also be documented in the records.
The GP may be informed:
• In person
• By telephone
• By secure fax
• By Nurse Prescribing Communication Sheet
• By other local protocols agreed with the GPs
If a prescription is given to a patient from another community nurses’ caseload. The caseload holder must be informed within 24 hours where possible, but within 48hours of writing the prescription. The caseload holder may be informed by any of the routes above, or by e-mail.
11.10 Handling Adverse Drug Reactions (ADRs) and Medication Incidents
The Non-Medical Prescriber must report any medication incidents in accordance with the PCT incident reporting policy. If a patient suffers a suspected adverse drug reaction to a prescribed, over the counter or herbal medicine, the adverse drug reaction should be reported via the Yellow Card Scheme. Yellow cards are available electronically, together with instructions on how to complete the form, which are detailed on the MHRA website; http://yellowcard.mhra.gov.uk/
Whilst electronic submission of forms is encouraged, yellow cards are also available at the back of the BNF. Suspected adverse reactions to medicines prescribed by another prescriber should be reported and ideally discussed with the prescriber.
All ADRs should be recorded in the patient’s notes and GP record.
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12. GENERAL GUIDANCE
12.1 Recording and Security of Prescription Forms
• Prescription pads are controlled stationary and MUST be obtained, stored securely, and issued ONLY to the individual prescriber named on it. Guidelines for Good Practice in the Safe and Secure Handling of Prescription Forms for Non Medical Prescribers are detailed in appendix M.
• A permanent record of prescription pad serial numbers must be recorded when prescription pads are received and issued.
• It is also good practice to record the first and last serial number of an in-use pad at the end of the working day. Such steps will identify any prescriptions that are lost or stolen overnight.
• Blank prescription forms must never be pre-signed.
• Prescribers must only use their own prescription pads.
• It is the responsibility of each prescriber to ensure the security of his/her prescription pads at all times. When on duty, the prescriptions must remain in the possession of the prescriber at all times
• When travelling between patients the prescription pad must not be visible and must be locked in the car boot (within the nursing bag for nurses).
• The nursing bag and prescription pad must always be removed from the car, when the car is unattended (apart from exceptional circumstances where the risks of taking out the bag are deemed to be greater).
• On leaving the organisation or changing roles where prescribing is not required, ALL remaining prescription pads MUST be returned to the Locality managers PA/service secretary for recording and secure destruction. They should be annotated as returned on the individual non medical prescribers prescription record log and signed out of the log when shredded.
• Practice employed staff must return unused prescription forms to the Practice Manager or GP Prescribing Lead.
12.2 Ordering and Supply of Prescriptions
The non medical prescriber will receive notification from the Non Medical Prescribing Lead or Specialist Technician - Community and Support Services when the registration process is complete and prescribing can commence.
The non medical prescriber can commence to prescribe electronically with immediate effect. The non medical prescriber’s details must be added to the clinical system prior to issuing electronic prescriptions to patients. This is to ensure any prescribing undertaken is attributable to the individual prescriber and that the regulations for writing prescriptions are complied with.
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Hand Held Prescription Pads
Non medical prescribers should routinely generate electronic prescriptions. However in the event of there being a need to prescribe using hand held pads;
• For GP practice staff requests for hand held prescription pads should be sent to WYCSA by the non medical prescriber on a PN FP10 order form. (This is available from WYCSA on request). The order form can either be faxed or posted to WYCSA at Broad Lea House as instructed on the form.
The prescription pads will be returned to the individual non medical prescriber at the GP practice via the GP post bag system.
• For PCT/KCHS employed staff requests for hand held prescription pads should be sent to the relevant Locality Manager’s PA/service secretary by the non medical prescriber on an FP10/C form (appendix I). The form can be sent by post, email or fax, but MUST go via the Locality Manager’s PA/service secretary.
Staff will be notified when the prescription pads arrive and asked to collect in person from the relevant locality base.
• For PCT employed pharmacist and allied health care professionals. Currently this cohort of prescribers use electronically generated prescriptions. However in the event of hand held pads being required, consent should be gained from the line manager and a request submitted using the order form FP10/C, (see appendix I), to the relevant Locality Managers PA or service secretary. See section 12.4.
The pads will be available to collect from the relevant Locality base when notified.
Ordering, receipt, distribution and destruction of hand held prescription pads for PCT employed Non- Medical Nurse Prescribers is the responsibility of the relevant Locality Managers Personal Assistants (PA).
12.3 Requirements for Handling Prescription Pads at Locality Bases
Each Locality Base MUST have limited access secure lockable storage for prescription pads. The keys to this location must be kept by the Locality managers PA, or designated deputy, and the keys securely stored at the end of each working day.
Each non-medical prescriber must have an individual file within the secure location containing a prescription record sheet, (appendix J). This will allow the following information to be recorded for audit and security:
• Non Medical Prescribers prescribing code number
• Base
• Contact telephone number
• Sample signature of non medical prescriber
• Date and number of prescription pads ordered
• Name of person ordering
• Date prescription pads received
• Quantity of pads received
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• To/from serial numbers of prescriptions received
• Date prescriptions taken for use
• To/from serial numbers of prescriptions taken for use
• Signature and name of person removing from file
• Signature of non medical prescriber collecting prescriptions.
The to/from serial numbers of all prescriptions returned for destruction must also be entered on the sheet as ‘returned for destruction’ and signed by the Locality managers PA when securely shredded.
12.4 Ordering Prescription Pads
Requests for a supply of prescription pads should be submitted directly to the appropriate locality managers PA. This is done by completing a prescription order form (appendix I). Orders can be sent by post, email or fax, but MUST go via the Locality Manager’s PA.
The nominated PA will record the order details on the prescription record sheet (see appendix J) This will be placed in the named individual’s folder and the order forwarded to WYCSA. This may be done electronically, fax or by post.
No more than 2 pads should be ordered for each non medical prescriber. Requests for quantities which exceed this amount should be addressed to the Non Medical Prescribing Lead by the PA before the order is placed.
WYCSA will order the prescription pads from the supplier using the details supplied on the submitted prescription order form.
When the ordered prescription pads are received by WYCSA they will:
• Check the order against the delivery note and record the prescription pad details and serial numbers.
• Log out the prescription pads to the non medical prescriber at the relevant Locality Base. The prescription pads will be placed in a sealed envelope along with a copy of the delivery note, and addressed for the attention of the named Locality Managers PA. The envelopes must be stored securely until collected by the authorised transport driver.
• Ensure the authorised transport driver checks and agrees the number of envelopes against the acknowledgement slip. An acceptance signature will be provided by the driver prior to leaving WYCSA with the envelopes.
When delivering to Locality Bases the authorised transport driver will:
• Hand the appropriate envelope to the named individual (or delegated deputy). If neither is available, the receptionist on duty can accept the envelope and hand to the Locality Managers PA/service secretary (or deputy) in person. A signature must be provided to the transport driver against the acknowledgement slip as proof of delivery.
• Return the signed log sheet to WYCSA to complete the audit trail.
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The Locality Managers PA/service secretary will:
• Accept the relevant envelope and sign against the appropriate entry on the drivers acknowledgement slip. If the PA is unavailable to personally accept delivery of the envelope, a designated named deputy should be available to accept delivery on behalf of the PA.
• The prescription pads should be checked against the copy delivery note and the ‘to /from’ serial numbers annotated onto the individual non medical prescribers prescription record form. The delivery note should be retained for 2 years.
• The prescription pads MUST be securely stored in the designated file until the non medical prescriber collects the pads in person.
• The non medical prescriber MUST bring evidence of identity with them and sign for the prescription pads when collecting.
• It is not possible to collect another prescriber’s prescriptions on their behalf.
12.5 Loss or Suspected Theft of Prescriptions
Community Nurse Prescribers
In the event of loss or suspected theft, the nurse must report this immediately to:
Relevant Locality Manager – who will inform:
• WYCSA Support Services (Broad Lea House) – 01484 464415
• The police on 0845 606 0606 or Huddersfield 01484 436659
• The nurse should inform the GP (where appropriate) as soon as he/she is aware of missing prescriptions.
• The prescriber must complete a PCT incident reporting form.
Information required will be the prescribers NMC number and the serial numbers for the prescriptions which have been lost/stolen (from/to). The serial numbers will have been recorded in either the back of the diary or on the WYCSA prescription record form.
Other Non-Medical Prescribers
In the event of loss or suspected theft, the non medical prescriber must report this immediately to their line manager who will inform WYCSA Support Services, details as above, and complete the relevant documentation.
WYCSA will require the prescriber’s details and the serial numbers for the prescriptions which have been lost / stolen (from/to).
Following loss / theft of prescription forms the prescriber will be requested by WYCSA Support Services to prescribe and sign all scripts in red for a period of 1 month. This information will also be provided to pharmacists within 24 hours, where possible. The NHS Business Services Authority (NHS BSA) is also notified.
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13. Equality Impact Assessment
This policy has been assessed for the potential adverse impact as set out in Appendix C. On initial screening the policy has not identified an impact.
14. Training Needs Analysis
In order to ensure that policies, guidelines and protocols are introduced and work effectively, there is a need to provide adequate training and instruction. As a result the author of this document has carried out a training needs analysis which has identified the staff who require training, the methodology of training delivery and the frequency that the training will be provided. The policy author must ensure that the details of this training is passed to the Training and Education Team and where necessary, this will then be included in the Trust Training Prospectus.
15. Monitoring Compliance with this Policy
To be monitored by the Medicines Management Team.
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16. References
Department of Health (2006) Improving Patients Access To Medicines: A Guide to Implementing Nurse and Pharmacist Independent Prescribing within the NHS in England. London: DH
Department of Health (2005) Supplementary Prescribing by Nurses, Pharmacists, Chiropodists/Podiatrists, Physiotherapists and Radiographers within the NHS in England: a guide for implementation. London: DH
Nursing and Midwifery Council (2006) Standards of Proficiency for Nurse and Midwife Prescribers. London: NMC http://www.nmc-uk.org/aFrameDisplay.aspx?DocumentID=1645
Royal Pharmaceutical Society of Great Britain (2006) Outline Curriculum for Training Programmes to prepare Pharmacist Prescribers. London: RPSGB http://www.rpsgb.org/pdfs/indprescoutlcurric.pdf
Health Professions Council (2005) Standards for Education and Training. London: HPC http://www.hpc-uk.org/assets/documents/10000BCF46345Educ-Train-SOPA5_v2.pdf
National Prescribing Centre (2005) Training Non-Medical Prescribers in Practice: A guide to help doctors prepare for and carry out the role of designated medical practitioner. Liverpool: National Prescribing Centre
Bramley, I (2006) Continuing Professional Development: what is it and how do I get it? Nurse Prescribing, Volume 4, Number 3, Pages 117 -121
The Medicines (Exemptions and Miscellaneous Amendments) Order 2009 SI 3062: www.opsi.gov.uk/si/si2009/uksi_20093062_en_1
The British National Formulary
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Appendix A
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17 APPENDICES
A – Definitions
Community Practitioner Nurse Prescribers Health visitors, district nurses and specialist practitioner/specialist community public health nurses holding the NMC V100 qualification and registered nurses holding the V150 qualification may prescribe independently from a limited formulary; the Community Nurse Prescribers Formulary (NPF). This consists of dressings, appliances and some medicines, including a small number of prescription only medicines. Training for prescribing from this formulary is now incorporated into the Specialist Practice training for all specialist practitioners with a proviso that there is a clinical need. Independent Prescribing
Independent prescribing is prescribing by a practitioner responsible and accountable for the assessment of patients with undiagnosed and diagnosed conditions, and for decisions about the clinical management required, including prescribing. These practitioners are not restricted by a separate formulary but can prescribe any licensed medication for any condition, including some controlled drugs. The limit for any prescribing is the scope of the prescriber’s professional practice as defined by their professional registering body; the registered prescriber may only prescribe within their own level of experience, knowledge and competence; within the scope of their professional role.
Supplementary Prescribing Supplementary prescribing is a voluntary partnership between an independent prescriber, (who must be a doctor or a dentist), and a supplementary prescriber, who has completed necessary training, to implement an agreed patient specific clinical management plan (CMP), with the patient’s agreement. It is a legal requirement for a CMP to be in place before supplementary prescribing can begin. The Department of Health has published guidance in creating a CMP: www.dh.go.uk/assetRoot/04/11/00/04110033.pdf Supplementary prescribers can prescribe any medicine, including controlled drugs, as long as this is in line with the CMP agreed with the patient and the doctor. The supplementary prescriber will provide ongoing clinical management of patient care through review and revision of medication management within an agreed clinical plan. A supplementary prescriber is not an independent prescriber and cannot initiate a treatment plan.
WYCSA
West Yorkshire Central Services Agency
Appendix B
39
Appendix B
Key Stakeholders Consulted/involved in the development of the document
Stakeholders name and designation
Date feedback requested
Detail of feedback received
Date feedback received
Action taken
Lucianne Ricketts – Non Medical Prescribing Lead
Medicines Management Committee
19/3/10
Section 25 – prescribing of unlicensed medicines and liabilities attached to this are unclear
6/5/10 Actioned
Non Medical Prescribing Committee
1/4/10 & 22/6/10
Clinical Executive Committee
18/6/10 Various minor comments 5/7/10 Actioned
Catherine Smyth – Professional Development Lead (Nursing)
July 2010
Gwen Ruddlesdin – Head of Integrated Governance and Quality
22/6/10
.
Appendix C
40
Equality Impact Assessment Tool
To be completed and attached to any procedural document when submitted to the appropriate committee for consideration and approval.
Insert Name of Policy / Procedure Yes/No Comments
1. Does the policy/guidance affect one group less or more favourably than another on the basis of:
• Race No
• Ethnic origins (including gypsies and travellers)
No
• Nationality No
• Gender No
• Culture No
• Religion or belief No
• Sexual orientation including lesbian, gay and bisexual people
No
• Age No
• Disability - learning disabilities, physical disability, sensory impairment and mental health problems
No
2. Is there any evidence that some groups are affected differently?
No
3. If you have identified potential discrimination, are any exceptions valid, legal and/or justifiable?
NA
4. Is the impact of the policy/guidance likely to be negative?
No
5. If so can the impact be avoided? NA
6. What alternatives are there to achieving the policy/guidance without the impact?
NA
7. Can we reduce the impact by taking different action?
NA
Appendix D
41
Sign Off Sheet regarding Dissemination of Procedural Documents
To be completed and attached to any document which guides practice when submitted to the appropriate committee for consideration and approval.
Title of Document:
Lead Director:
Date Approved:
Where approved:
Dissemination Lead:
Placed on Website:
Review Date:
Appendix E
42
CPNP INTENTION TO PRESCRIBE FORM
FULL NAME (print): …………………………………………………………………………..
JOB TITLE: …………………………………………………………………………………….
PROFESSION: ………………………………………………………………………………..
APPROVED TO PRACTICE AS (Independent/Supplementary/Community Practitioner Nurse Prescriber): ……………………………………………………………………………..
PROFESSIONAL REGISTRATION NUMBER: ……………………………………………
DATE OF BIRTH: ………………………………………………………………………………
TITLE (Mr/Miss/Ms/Mrs): ………………………………………………………………………
SERVICE BASE/GP PRACTICE: ……………………………………………………………..
CONTACT DETAILS (Mobile/base number): ………………………………………………
USUAL SIGNATURE:
LINE MANAGER/TEAM LEADER: …………………………………………………………………………………………………….
HEAD OF SERVICE/MANAGER (Locality Manager/Service Lead/Practice Manager): …………………………………………………………………………………………………….
TO BE COMPLETED BY APPROPRIATE SERVICE LEAD
I confirm that (insert name):……………………………… is employed in their role as (insert):…………………….. and that they are required to prescribe in this role.
APPROVED BY HEAD OF SERVICE/MANAGER (Locality Manager/Service Lead/Practice Manager): ……………………………………………………….(Signature)…………………(Date)
Return to:
Specialist Technician, Community Services, Medicines Management Team, Broad Lea House,
Dyson Wood Way, Huddersfield. HD2 1GZ
Date:…………….
Appendix F
43
INDEPENDENT PRESCRIBING PROFORMA
INTENTION TO PRACTICE AS AN INDEPENDENT NURSE OR PHARMACIST PRESCRIBER
Please complete this form electronically, then print, sign and arrange for manager and lead clinician to sign.
Name: Title (Ms/Miss/Mrs/Mr): Base:
Role: Phone No:
Professional Reg Number: Date of Birth:
Disease Area Evidence of Competence
to prescribe for this disease area
CPD undertaken supporting prescribing within this area
State items to be prescribed and guidelines worked to, or attach protocols.
E.g. Asthma E.g. Asthma Diploma or 10 years experience (whatever is applicable)
E.g. Formal updates, courses attended (whatever is applicable) Please give as much information as possible including dates attended etc.
You may list individual items or make reference to guidelines or sections of BNF. Prescribing intentions must be clear and the evidence base identified.
Continued overleaf
Appendix F
44
Have you received a prescribing related appraisal in last 12 months?
If so, when and with whom.
If not, identify when and with whom this will take place.
Do you receive clinical supervision for your prescribing role?
If so please give brief description
If not identify how you will receive clinical supervision for your prescribing role.
What plans do you have to audit your prescribing?
Please provide a brief description
Have you identified any CPD needs related to prescribing?
If so how do you plan to address these needs?
Independent Prescribers Signature: …………………………………………………. Date: …………………………………
My intended scope of prescribing practice has been discussed and agreed with my manager and lead clinician.
Managers Name: ………………………………………………….
Managers Signature: ……………………………………………. Date: ……………………………
Lead Clinicians Name: ……………………………………………
Lead Clinicians Signature: ………………………………….. Date: ……………………………..
Please send the completed and signed form to:
Non Medical Prescribing Lead, Medicines Management Team, NHS Kirklees, Broad Lea House, Bradley Business Park, Dyson Wood Way, Huddersfield. HD2 1GZ
A copy should be retained by the Non Medical Prescriber and Manager.
Appendix G
45
INDEPENDENT PRESCRIBING PROFORMA ADDITIONS FORM
ADDITIONS TO PRACTICE AS AN INDEPENDENT NURSE OR PHARMACIST PRESCRIBER
Please complete this form electronically, then print, sign and arrange for manager and lead clinician to sign.
Name: Title (Ms/Miss/Mrs/Mr): Base:
Role: Phone No:
Professional Reg Number: Date of Birth:
Disease Area Evidence of Competence
to prescribe for this disease area
CPD undertaken supporting prescribing within this area
State items to be prescribed and guidelines worked to, or attach protocols.
E.g. Asthma E.g. Asthma Diploma or 10 years experience (whatever is applicable)
E.g. Formal updates, courses attended (whatever is applicable) Please give as much information as possible including dates attended etc.
You may list individual items or make reference to guidelines or sections of BNF. Prescribing intentions must be clear and the evidence base identified.
Continued overleaf
Appendix G
46
Independent Prescribers Signature: …………………………………………………. Date: …………………………………
My intended scope of prescribing practice has been discussed and agreed with my manager and lead clinician.
Managers Name: ………………………………………………….
Managers Signature: ……………………………………………. Date: ……………………………
Lead Clinicians Name: …………………………………………….
Lead Clinicians Signature: ………………………………….. Date: ……………………………..
Please send the completed and signed form to:
Non Medical Prescribing Lead, Medicines Management Team, NHS Kirklees, Broad Lea House, Bradley Business Park, Dyson Wood Way, Huddersfield. HD2 1GZ
A copy should be retained by the Non Medical Prescriber and Manager.
Appendix H
47
SUPPLEMENTARY PRESCRIBING CLINICAL MANAGEMENT PLAN (CMP)
Patient Label / Details
Allergies / Sensitivities
Existing Patient Medication Not Covered Under CMP
Independent Prescriber(s)
Supplementary Prescriber(s)
Condition(s) to be Treated
Aim of Treatment
Treatment Plan
Indication Preparation &
Dosage
Dose Schedule Referral back to the
Independent
Prescriber
Appendix H
48
Review & Monitoring:
Supplementary Prescriber
Independent Prescriber
Process for reporting Adverse Drug Reactions
Yellow Card Scheme
IR1 if applicable
Documentation & Record Keeping
Guidelines supporting Supplementary Prescriber’s Treatment Plan
Names of Independent
Prescriber(s) Managing
this Patient’s CMP
Date
Name(s)of Supplementary
Prescriber(s) Prescribing
from this CMP
Date Date Agreed with
Patient / Carer
Appendix I
Tel: 01484 464000 Broad Lea House
Ext: 4415 Bradley Business Park
Fax: 01484 464417 Dyson Wood Way
Huddersfield HD2 1GZ
49
Community Nurse Prescribers and Nurse/Pharmacist Independent Prescribers Hand Held Prescription Pad
Order Form (Pads of 50)
PCT CODE 5N200
Locality Base Details:
Prescriber to complete details in boxes below and forward to Locality Managers PA
Prescriber Name Prescriber
Registration No
No of Pads Required
Please State:
Community Nurse or Nurse/Pharmacist
Independent Prescriber
Locality Manager: ……………………………………………………………………………
PA Name and Contact: ……………………………………………………………………...
Orders can be sent by fax, post or e-mail:
Fax No: 01484 464417
Post to: Support Services, Broad Lea House, Bradley Business Park, Dyson Wood Way. Huddersfield. HD2 1GZ
E-mail: [email protected]
FURTHER COPIES OF THIS ORDER FORM OR PRACTICE STOCK SHEETS CAN BE REQUESTED BELOW
FORM NUMBER PLEASE SUPPLY THE FOLLOWING QUANTITY REQ
FP10/C Request for Prescription Forms
CN/SCS Stock Control Sheet for Prescriptions
Appendix J
50
PRESCRIPTION RECORD SHEET FOR NON MEDICAL PRESCRIBERS
ORDER AND RECEIPT OF PRESCRIPTION PADS
Name: Pin Number: Base: NMP Sample signature:
Date and Quantity of Pads Ordered
Date and Quantity of Pads Received
Serial Numbers From:
Serial Numbers to: Signature of PA
Continued Overleaf
Appendix J
51
COLLECTION OF PRESCRIPTION PADS
Date Quantity of Pads Collected
Serial Numbers
From:
Serial Numbers to: Signature of NMP and PA’s initials
DESTRUCTION OF PRESCRIPTION PADS
Date Quantity of pads returned
Serial Numbers
From:
Serial Numbers to: Reason for Return:
Signature of NMP Returning:
Signature of PA when Shredded
Appendix K
52
APPLICATION FOR APPROVAL TO UNDERTAKE NON-MEDICAL PRESCRIBING COURSE
FULL NAME (print): ………………………………………………….. JOB TITLE: ……………………………………………………………. BASE OF WORK: …………………………………………………….. LINE MANAGER: ……………………………………………………… What do you intend to prescribe? (Please give a brief description of disease areas you intend to prescribe for, or state ‘formulary’ if applying for the nurse v150 course ): ……………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………… Do you have a (please tick): Medical Mentor Non Medical Mentor Name of mentor: ……………………………………………………………………………………………. Designation and place of work: ……………………………………………………………………………. Mentor contact details: …………………………………………………………………………………………….
Will prescribing only take place within the boundaries of NHS Kirklees? Y/N …………………………. If No, please state where:………………………………………………………………………………………… Signature:……………………………………………………. Date: ……………………………………………. Please return completed form WITH university application to: Non Medical Prescribing Lead, Medicines Management Team, Broad Lea House, Dyson Wood Way, Huddersfield. HD2 1GZ
Appendix L
53
NON-MEDICAL PRESCRIBING PROVISION AND CONTACTS
University Contact/Course Leader
Who do they train?
Taught (T)
Distance Learning
(D)
Approximate Course
Start Dates *
How long is the course run over?
The University of Bradford
Jenny Adams
01274 236 472
Justine Raynsford
Tel 01274 236300 [email protected]
Nurse
V150
V300
AHPs
Pharmacists
T
T
February
October
4 or 9 months
Leeds Metropolitan University
Andrew McEwan
0113 2832600 ex 24413
Nurse
V300
V150 (2010)
AHPs
T
February
September
6 months
The University of Leeds
Catherine Gill
0113 343 1297
(Nurses and Midwives)
Dr Barry Strickland-Hodge
0113 343 1346 (Pharmacists)
Nurse
V300
Pharmacists
T
T/D
January
September
(Enquire separately for D)
3 or 6 months
The University of Huddersfield
Val Ely
01484 473450
Nurse
V150
V300
AHPs
T January September
6 months
Appendix L
54
NON-MEDICAL PRESCRIBING PROVISION AND CONTACTS
University Contact/Course Leader
Who do they train?
Taught (T)
Distance Learning
(D)
Approximate Course
Start Dates *
How long is the course run over?
The University of Hull
Sandra Burley
01482 464515
Dr Andrea Hilton
01482 463347
Nurse
V150 (2010)
V300
AHPs
Pharmacist
T
T
T
January September
6 months
Sheffield Hallam University
Jan Denton
0114 225 2549
Nurse
V150
V300
AHPs
Pharmacists
T February
September
6 months
The University of Sheffield
Derek Darling
0114 2269848
Nurse
V150 V300
T March
September
6 months
The University of York
Gerri Kaufman
01904 3211629
Nurse
V150
V300
AHPs
Pharmacists
T September 6 months
Appendix M
55
GOOD PRACTICE GUIDELINES FOR THE SAFE AND
SECURE HANDLING OF PRESCRIPTION FORMS FOR NON-MEDICAL PRESCRIBERS
1. Responsibility of the Individual Prescriber
Treat the prescription pad as you would a cheque book:
DO
• Keep the pad with you in your bag or on your person whilst out of the office.
• Consider only taking one or two prescriptions out with you.
• Secure the pad in a locked drawer in your place of practice when not in use.
• Record the number of the first and last prescription in each pad, and the date on which they were used. This can be done in your work diary.
• Notify your manager immediately if any forms or the pad go astray.
• Return all unused prescriptions to your manager if leaving the Trust.
• Only use your own prescription pad, and check it’s yours before writing on it.
DON’T
• Pre-sign blank prescription forms.
• Leave the prescription pad in your car - 80% of GP pads that go missing get stolen from cars
• Leave the pad unattended on your desk.
• Have more than one prescription pad in use at any one time.
• Let any other practitioner use your prescription pad.
• Use any other pad except your own - if you run out of prescriptions you will not be able to prescribe until you get another pad!
2. Responsibility of the Trust or Practice Base
• Provide secure, lockable storage for prescription pads.
• Ensure the provision of new prescription pads as required.
• Minimise the risk of fraud by recording the numbers of the first and last prescription in each pad at the central and local distribution centres.
• Inform the Specialist Technician, Community and Support Services of details of practitioners leaving the Trust.
• Retrieve unused prescription pads from non-medical prescribers leaving the Trust, or when prescription pads are no longer required (ie. moving to a non-prescribing role). ALL prescription pads MUST be returned to the Locality Managers PA for secure destruction. They should be annotated as returned on the individual non medical prescriber’ prescription record log and signed out of the log when shredded.
Appendix N
56
SLA for Cross Boundary Non- Medical Prescribing between NHS organisations within South West Yorkshire area.
Introduction
The practice of some Non Medical Prescribers necessitates prescribing across the boundaries of local NHS organisations. Examples of this are where a non medical prescriber is employed by one organisation (e.g SWYMHT) but seconded to a different organization (e.g.Lifeline) to provide services which would include prescribing. Or it may occur through an honorarium contract between two organizations e.g Tissue Viability nurses employed by a Secondary Care Trust who during the course of their duties are required to prescribe for patients in primary care using the local Primary Care Trusts’ prescription pads.
This agreement has been drawn up to ensure that the proper elements and commitment are in place to provide optimal services and addresses risk management issues from an accountability, responsibility, quality and resource perspective for the prescribing practice of these non-medical prescribers.
Policy/Framework
The non medical prescriber will work to the employer organisation’s non-medical prescribing policy/framework, (whilst paying due regard to the receiver organisation’s own non medical prescribing policy/framework).
Where the employer organisation does not have an approved policy/framework for non-medical prescribing the non-medical prescriber must work within the receiver organisation’s Non-Medical Prescribing Policy/Framework.
All prescribers are expected to work within the remit of the employer organisation’s Medicines Code, (whilst paying due regard to the receiver organisation’s medicines code).
All relevant policies must be shared between organisations and Non-Medical prescribers to minimise risk.
Vicarious Liability
The employer organisation will accept vicarious liability prescribing by their employee i.e Vicarious liability sits with the service provider.
Individual liability is bound by the Non-Medical Prescribing policy of the employer organisation.
Formulary/Prescribing Guidance
The non-medical prescriber must follow BNF guidelines and work within approved national prescribing guidelines e.g NICE, etc relevant to their area of expertise/competence. It is expected that the non-medical prescriber will work to any formulary/prescribing guidance of the service receiver and in the case of supplementary prescribers, within the agreed Clinical Management Plans.
Current BNFs, Drug Tariffs, etc, are to be supplied to the non medical prescriber by the employer organisation.
All relevant prescribing guidelines and procedures must be shared between organisations to minimise risk.
Appendix N
57
Budget
It is the responsibility of the receiver organisation to
• issue prescription pads
• allocate the prescribing budget with relevant budget codes.
The prescription pads issued can only be used for the work carried out for that organisation. It is important/essential that all prescribing is charged to the appropriate budget. Non medical prescribers must ensure that the correct budget/prescriber code is entered on each prescription form.
Supply and Receipt of Prescription Pads
It is the responsibility of the receiver organisation to
• register each non-medical prescriber
• supply the appropriate prescribing stationery
• provide any necessary information/training and education required to fulfil the role (e.g relevant prescriber codes).
The non-medical prescriber must comply with any terms and conditions relating to ordering and/or receipt of prescription pads as outlined in the service receivers non medical prescribing policy/framework.
Any resources required specifically for the prescribing setting should be provided by the receiver organization, for whom the individual is undertaking prescribing duties.
Communication
It is the responsibility of the employer organisation to provide information about the non-medical prescribers scope of competence and area of practice to the non medical prescribing lead of the receiver organisation by completing Proforma A - attached.
The employer organisation must liaise with the proposed receiver organisation, prior to initiation of non medical prescribing training to ensure a prescribing budget will be available and that the proposed service is supported by the receiver organization.
Where prescribing is taking place in primary care, it is the responsibility of the non medical prescriber to communicate effectively, any prescribing interventions, to the registered GP practice of the patient within 48 hours,
Continuing Professional Development / Monitoring
Continuing Professional Development (CPD) is the responsibility of the individual prescriber. Evidence of CPD must be made available to both the receiver and employer organisations.
The employer organisation must have facilities available for CPD events. The receiver organisation must allow reasonable study leave to attend CPD events.
CPD undertaken should be relevant to the individual’s scope/area of practice, agreed in the personal development plan and approved by the Line Manager.
Monitoring of prescribing is the responsibility of the employer organisation, however the receiver organization is at liberty to share any prescribing monitoring carried out themselves with both the prescriber and non-medical prescribing lead of the employing organization.Any issues/concerns raised are to be addressed by the employing organization.
The receiver organization should report to the Employer organisation any prescribing incident
Appendix N
58
pertaining to the non medical prescriber, including any incident that did not cause harm to the patient.
Termination of Prescribing Arrangement
It is the responsibility of the employer organisation to inform the receiver organisation via the non medical prescribing lead, when a prescriber stops prescribing and therefore requires deregistration from the prescriber list.
The non-medical prescriber must comply with the terms and conditions pertaining to termination of prescribing as outlined in the non medical prescribing policy/framework of the receiver organisation.
Glossary of Terms
• Non medical prescribing - is the term used to describe prescribing by health care professionals other than doctors and dentists. Non medical prescribers must comply with the current legislation for prescribing and be accountable for that practice.
• Non Medical Prescribers include:
Community nurse practitioners
Supplementary prescribers
Nurse Independent Prescribers
Pharmacist Independent Prescribers
• SLA - NHS bodies do not enter into legally enforceable contracts with each other where both are subject to powers of direction by the Secretary of State for Health. However, a Service Level Agreement (SLA) performs the same function as a contract between NHS bodies. The purpose of a SLA is to ensure that the proper elements and commitment are in place to provide optimal services and in the context of risk management raise issues from an accountability, responsibility, quality and resource perspective.
One party acts as the service provider and the other party acts as the service receiver (or a party that acts on behalf of a service receiver).
• Employer Organisation OR service provider – the organisation employing the non medical prescriber.
• Receiver organisation OR service receiver – the organisation that the non medical prescriber is prescribing within but is not employed by that organisation.
• Vicarious Liability - An employer is vicariously liable for negligent acts or omissions by his employee in the course of employment whether or not such act or omission was specifically authorised by the employer. To avoid vicarious liability, an employer must demonstrate either that the employee was not negligent in that the employee was reasonably careful or that the employee was acting in his own right rather than on the employer's business.
Proforma A
Notification and Agreement for a Non-Medical Prescriber to Practise across
Appendix N
59
Organisational Boundaries
(Completed proforma to be retained by non medical prescribing leads of both employer and receiver organizations)
Name of Non Medical Prescriber ………………………………………………….
Job Title ………………………………………………………………………………
Current Work Base ………………………………………………………………….
Profession and Registration number ………………………………………………
Prescribing Qualification (please tick as appropriate)
Community nurse Practitioner
Supplementary Prescriber
Independent Prescriber
Scope/areas of competence of non medical prescriber
………………………………………………………………………………………………
………………………………………………………………………………………………
………………………………………………………………………………………………
Description of role to be undertaken by non medical prescriber in Receiver organisation:
…………………………………………….…………………………………………………..
…………………………………………………………………………………………………
…………………………………………………………………………………………………
Proposed Locality/Base of prescribing activity …………………………………………..
Name ………………………………………………………………………
Signature ………………………………………………………………………
Date ……………………………………………
Appendix N
60
Name of Employer organisation (i.e employer of non medical prescriber)
…………………………………………………………….……………………
Non-Medical Prescribing Lead of Employer organisation
Name …………………………………………………………………
Signature …………………………………….. Date ………….….
Line manager of Non Medical Prescriber
Name …………………………………………………………………
Signature …………………………………….. Date ………….….
……………………………………………………………………………………………….
The above named non-medical prescriber can prescribe within the organisation named below in accordance with the terms of this cross boundary agreement.
………………………………………………………………………………………………..
Name of Receiver organisation (i.e. organisation receiving the services of the non medical prescriber)
……………………………………………………………………………………………….…
Non-Medical Prescribing Lead of Receiver organisation
Name …………………………………………………………………
Signature …………………………………….. Date ……………….
Commissioner/Manager of Service Area within Receiver organisation
Name …………………………………………………………………
Signature …………………………………….. Date ……………….