The Allied Health Professions (AHP) Medicines Programme aims to enable certain allied health professionals, including radiographers, to better support patient care through improved access to medicines, including independent prescribing by diagnostic radiographers.
This initiative is crucial for improving patient access to care, increasing radiographers' autonomy, reducing operational bottlenecks, addressing workforce needs, and fostering collaboration within healthcare teams.
Timeline
2014 - 2015
- Development of the case for independent prescribing by the Society of Radiographers (SoR) and National Health Service England (NHSE) in collaboration with other involved professional bodies.
2015 - 2016
- UK wide Consultation on independent prescribing proposals led by the Department of Health.
- Recommendation made by the Commission for Human Medicines (CHM) resulting in legislative changes for therapeutic radiographers to become independent prescribers.
- Diagnostic radiographers not supported due to concerns over training and patient safety.
2017
- Update to CHM with new evidence supporting diagnostic radiographers' need for independent prescribing from a full formulary.
- Not recommended at that point.
2017 - 2021
- SoR and NHSE work with stakeholders on new submissions to the Commission for Human Medicines to advocate for independent prescribing for diagnostic radiographers.
2021
- CHM recommended ministers consider a change to the Human Medicines Regulations 20212 to allow diagnostic radiographers to become independent prescribers.
- The Medicines and Medical Devices Act (MMDA) became law in February 2021. The MMDA has specific requirements, set out in section 45(1), for consulting publicly on proposed changes to the HMRs, requiring DHSC to reconsult on proposals that were already consulted on publicly prior to the MMDA coming into force.
August 2025
- DHSC announce and launches the required further consultation to make the required legislative changes – access the consultation here
Get Involved
Stay informed about and influence changes in regulations related to radiographic practice by:
Take part and be active by:
- encouraging colleagues to respond to the consultation
- taking up education opportunities
- embracing the legislative changes that enable radiographers to prescribe
- seeking service improvements that come from the legislative changes
Respond to the Consultation
Use your voice! The consultation is open for 12 weeks and will close at 11:59pm on 28 October 2025. Individual respondents must live or work in the UK to take part in this survey.
Frequently Asked Questions
What is independent prescribing?
Independent prescribing is prescribing [of prescription-only medicines POMs] by a practitioner who is responsible and accountable for the assessment of service users with undiagnosed or diagnosed conditions and for decisions about the clinical management required. (HCPC Independent prescribing annotation)
What will diagnostic radiographers prescribe?
Diagnostic radiographers will prescribe within their own area of expertise within the primary scope of practice of radiography, in the field of clinical imaging. i.e., their individual scope of practice, as authorised by their employer and supported by relevant governance processes.
The examples that were discussed with the CHM included:
- Prescribing decisions about contrast media for those patients who do not meet the criteria for a Patient Group Direction decision
- laxatives and Buscopan for CT Colonography with contrast agents for patients requiring staging
- local anaesthetics and corticosteroids by radiographer sonographers for joint injections
- local anaesthetics, pain relief and contrast agents for radiographers performing line insertions or exchanges
- Antibiotics for radiographers performing urodynamics
- Advice/prescription for pain relief by a see, report and discharge radiographer for Emergency Department patients
- Prescribing of treatment for osteoporosis by a DXA reporting radiographer working as part of the multidisciplinary team in a Frailty service for osteoporosis patients.
Guidance on scope of practice for advanced practitioners and consultant practitioners supports those advanced and consultant-level radiographers who might prescribe in ‘non-traditional’ roles, which are undertaken by professionals from a range of regulated professions.
Do diagnostic radiographers have the required clinical assessment skills to prescribe?
The HCPC standards of proficiency for radiographers (12.14, 13.4, 13.5, 13.7) require diagnostic radiographers to demonstrate a range of patient assessment skills as part of their undergraduate education programme and to maintain and develop those skills relevant to their role once qualified.
In addition, a radiographer must achieve an annotation on the HCPC register as an Independent Prescriber. This requires completion of an HCPC-approved Higher Education programme with demonstration of prescribing competency against the Competency Framework for all Prescribers, which includes skills in undertaking and documenting an appropriate clinical assessment. These required clinical assessment skills will be assessed as part of their prescribing competence assessment.
What is the AHP Medicines Programme?
The AHP Medicines Programme is an initiative that allows allied health professionals, including radiographers, to take on a more active role in patient care through changing the legal mechanisms for the supply, administration, and prescribing of medicines appropriate for their profession.
What significant developments occurred between 2014 and 2015 regarding the AHP Medicines Programme?
The Society of Radiographers collaborated with other professional bodies to create the case for independent prescribing, delivering a series of public roadshows and developing professional guidance with a draft curriculum in preparation for legislative changes.
This work was led by the NHS England AHP Medicines team providing expertise, support and ensuring a consistent approach across the professions. This led to therapeutic radiographers being entitled to train as independent prescribers in 2016.
The same change was recommended for diagnostic radiographers in 2021 although as of July 2025 the legislation has not been updated.
Why is the AHP Medicines Programme important for radiographers?
The programme enhances patient care by seeking the legislative change that enables radiographers to independently prescribe Prescription Only Medicines, increases their professional autonomy, reduces operational bottlenecks, addresses workforce needs, and fosters collaboration among healthcare professionals.
Independent prescribing can also enable new ways of working to deliver safe, effective services focussed on the patient experience.
When was the proposal for independent prescribing by therapeutic radiographers presented, and what was the outcome?
The proposal was presented to the Commission for Human Medicines (CHM) in October 2015, resulting in a recommendation for independent prescribing by therapeutic radiographers and subsequent legislative changes in February 2016.
Why was independent prescribing not recommended for diagnostic radiographers in 2015?
CHM cited insufficient evidence of benefits alongside concerns about the training of diagnostic radiographers in assessment and diagnosis. They decided that without further clarification, independent prescribing posed potential risks to patient safety.
These issues have since been addressed in further information and a risk assessment provided to CHM.
What legislative changes took place in 2016?
The Human Medicines Regulations 2012 were changed to enable therapeutic radiographers to pursue HCPC-approved education and training to become independent prescribers with an associated annotation on the HCPC register.
Why are enhanced practitioners now included in the guidance when the original consultation only mentioned advanced practitioners?
Since 2015 when the original consultation document was written, the definition of advanced practice has changed from that defined by the Society of Radiographers to a comprehensive definition published by NHS England (and similarly in the devolved nations) as part of a strategy to build a recognised and visible advanced practitioner workforce.
The intention for independent prescribing was always to concentrate on experienced, specialist radiographers holding relevant post registration qualifications for their scope of practice. Experienced enhanced practitioners now meet the original criteria, alongside advanced and consultant practitioners.
What are some benefits of empowering experienced enhanced, advanced and consultant radiographers to prescribe medicines?
Benefits include improved patient flow and diagnosis, enhanced clinical decision-making, reduced delays in imaging and treatment plans, efficient management of medicine use, and better teamwork within healthcare settings.
The development also ensures that radiographers have access to wider roles in healthcare such as roles in frailty teams or palliative care that require prescribing responsibilities allowing them to use their skills and will contribute to keeping our highly skilled staff.
What efforts were made between 2015 and 2021 concerning diagnostic radiographer prescribing?
During this period, there were ongoing efforts to review and update information shared with CHM about the need for diagnostic radiographers to become independent prescribers and to address the limitations caused by current medicines restrictions such as delays when managing a patient who doesn't meet the inclusion criteria within a PGD.
Efforts to explore issues with RCR were made, and discussions around the legal authorisation for the administration of POMs processes progressed.
The Specialist Pharmacy Service was commissioned by NHSE to develop some Patient Group Direction templates and conversations continued around their appropriateness for radiographer use.
What was the outcome of the submission made to CHM in 2017?
The CHM did not accept there was need for Diagnostic radiographers to train as independent prescribers at that time.
What happened in 2017 to improve safe and effective medicines administration by radiographers?
NHSE commissioned the Specialist Pharmacy Service to develop Patient Group Direction (PGD) templates to improve the governance, quality and consistency of PGDs used by radiographers across the UK.
What was the outcome of the new submission made to CHM in December 2021?
Representatives from the Society and College of Radiographers, NHS England, and the Welsh Assembly presented evidence to CHM, which was approved and a recommendation made that government ministers be asked to update the HMRs 2012 to allow diagnostic radiographers to train as independent prescribers.
What will diagnostic radiographers be able to prescribe when the legislation changes?
Independent prescribing for any condition from a full formulary.
The original consultation offered 4 options:
- No change
- Independent prescribing for any condition from a full formulary
- Independent prescribing for specified conditions from a specified formulary
- Independent prescribing for any condition from a specified formulary
Option 2 provides the fewest limitations and supports the widest approach to ongoing patient care by radiographers in a changing healthcare environment. Option 2 was taken forwards. All other options require further legislative change to increase or alter the prescribing responsibilities, which does not support changes to patient pathways, innovation in medicines or professional role development.
This option is consistent with all other non-medical independent prescribers, including therapeutic radiographer independent prescribers.
The responsibility for prescribing within competence sits with the eligible radiographer, i.e. a radiographer that meets all of the requirements in the practice guidance for radiographer prescribers themselves supported by the governance processes of their employer; prescribing within an individual scope of practice typically means that the radiographer may have approximately 3 or 4 medicines defined within their personal formulary that they would be thoroughly familiar with and these would be the medicines which they would prescribe. E.g. contrast media, saline, local anaesthesia.
Where expertise is needed for a particular condition or health pathway, the diagnostic radiographer will need knowledge of relevant medicines to inform their decisions even if not prescribing them.
It is not expected that the scope of practice for most diagnostic radiographer prescribers will change beyond prescribing in diagnostic imaging pathways with the legislative change.
What has been happening since 2021?
SoR has often sought an update on progress for the legislative change and developed new draft guidance documents in anticipation. As of early 2025, Suzanne Rastrick, the CAHPO, has indicated to SoR and others that the DHSC medicines team was about to restart the required work to amend legislation for diagnostic radiographers and the other outstanding AHP recommendations. SoR is working closely with DHSC colleagues to support the process.
Further review and updating of the PGD templates continues with all UK countries encouraged to adopt them to improve consistency and the quality of medicines administration.
Radiographers have been directed to ensure they have legal authorisation in the shape of an in date and appropriately signed and authorised PGS, a PSD, which is a type of prescription or a protocol as part of the IR(ME)R 2018 amendment exemption for those working in Nuclear Medicine for administration of all POMs since an HCPC case which identified this wasn’t always the case and feedback from members with concerns.
Work continues with medical colleagues, external organisations and RCR to ensure there is a collective understanding of the required adherence to legislative requirements for medicines administration.
What needs to happen now for diagnostic radiographers to be able to train as independent prescribers?
A further public consultation led by DHSC is needed as the primary legislation has changed since the original consultation in 2015 due to Brexit.
This consultation should confirm the recommendation made by CHM that ministers support a change in the Human Medicines Regulations 2012 that gives diagnostic radiographers the legal right to train as independent prescribers within the same regulatory scope as that of therapeutic radiographers.
The SoR will publish revised implementation and practice guidance to encompass the legal change, which supports safe practice and ensures the legal entitlement can be used appropriately.
If you have any additional questions, please contact Sue Johnson, Professional Officer for Clinical Imaging.
.jpg?width=600&height=300&ext=.jpg&width=1200&resizemode=force)
