Useful information for prescribers
Answering your questions on prescribing standards and qualifications
When did the new prescribing standards come into effect?
We began approving all prescribing programmes against the new Standards for prescribing programmes from 28 January 2019.
Can I use my V300 nurse/midwife independent prescriber qualification to prescribe whilst working as a physician associate?
The physician associate role is not a regulated profession, but other health and care professionals, such as registered nurses or midwives, can work in that role. Physician associates in the UK are unable to prescribe medication by virtue of working as a physician associates.
However, a registered nurse or midwife with prescribing rights working as a physician associate is able to prescribe medication by relying on their nursing or midwifery knowledge, skills or experience in that role. In this case, you would be working within your scope of practice as a registered nurse or midwife and would therefore be subject to regulation by us.
You would need to maintain your nursing or midwifery registration and continue to meet our requirements for registration for this to apply.
There is currently only a voluntary register for the physician associate role. If this role were to become regulated on a statutory basis in the future, your work may then fall outside the scope of your registered nursing or midwifery practice, and we will review this position.
What do I need to consider as a nurse, midwife or nursing associate when medicines are prescribed remotely?
We don’t issue guidance for specific areas of practice or for individual named medicines. However, the information set out below needs to be considered by any nurse, midwife or nursing associate working in any setting.
This includes those working in a cosmetic or aesthetic practice setting.
If you’re a prescriber
If you hold prescribing qualifications, you must prescribe in line with the requirements of the Code and your individual scope of practice. This means you must prescribe in line with best available evidence and the requirements of all relevant legislation, as well as any policies, standards and guidance that underpin the Code.
This applies to all forms of prescribing, including remote prescribing; and to all medicinal products, including non-surgical medicinal products being used for cosmetic and aesthetic purposes, such as Botox.
The Code states at section 18.1 that those suitably qualified must only prescribe, advise on, or provide medicines or treatment, including repeat prescriptions if you have enough knowledge of that person’s health and are satisfied that the medicines or treatment serve that person’s health needs.
In March 2018, our Council agreed to adopt the ‘Royal Pharmaceutical Society (RPS) Competency Framework for all Prescribers’ as our standards of competency for prescribing practice. Nurse and midwife prescribers should use the framework as the benchmark for safe and effective prescribing practice.
The RPS competency framework sets out a list of steps a prescriber must undertake prior to issuing a prescription. This includes:
- taking an appropriate history (competency 1.1),
- undertaking an appropriate clinical assessment (competency 1.2), and
- having a full understanding of the conditions to be treated by way of prescribing medication (competency 1.6).
It also states that:
- prescribers should identify the potential risks associated with prescribing remotely, and take steps to minimise them (competency 7.3); and
- minimise risk to patients by using processes that support safe prescribing in areas of high risk (competency 7.4).
We would expect all nurse and midwife prescribers to adhere to the RPS competency framework as the standards for safe and effective practice in prescribing in order to ensure patient safety and public protection.
All prescribers must take individual responsibility for their prescribing decisions and should recognise that there are certain areas of practice where remote prescribing is unlikely to be suitable, for example when prescribing medicines likely to be subject to misuse or abuse, or injectable cosmetic treatments.
We recommend that it is good practice for face to face consultations to take place before prescriptions are issued in the cosmetic context.
If you’re involved in administration of medicines
If you’re administering medicines which have been prescribed by another person (including when the prescribing has been done remotely), you have a responsibility under the Code to ensure that you’re satisfied that the RPS competency framework has been followed and patient safety is not at risk.
This means you should say no if asked to supply or administer any medicinal product if you have concerns that the prescribing has not been carried out appropriately and in line with the requirements of the Code, the Royal Pharmaceutical Society (RPS) Competency Framework or other applicable standards and guidance.
If you feel that patient or public safety is being put at risk or if you’re being asked to work outside of the requirements of the Code or any other national standards, you’re empowered under the Code to raise your concerns (see section 16.1 of the Code for more details).
High level principles for good practice in remote consultations and prescribing
In November 2019 healthcare organisations including regulators, royal colleges and faculties, issued a set of principles to help protect patient safety and welfare when accessing potentially-harmful medications online or over the phone.
The jointly-agreed High level principles for good practice in remote consultations and prescribing sets out the good practice expected of healthcare professionals when prescribing medication online.
The ten principles underpinned by existing standards and guidance, include that healthcare professionals are expected to:
- Understand how to identify vulnerable patients and take appropriate steps to protect them
- Carry out clinical assessments and medical record checks to ensure medication is safe and appropriate
- Raise concerns when adequate patient safeguards aren’t in place.