This ongoing project was set up to consider extension to supply, administration and prescribing responsibilities for AHPs and to date the following has been achieved:
Independent prescribing by therapeutic radiographers
These are in addition to the previous existing AHP medicines mechanisms;
For the latest update on ongoing research into the effectiveness of therapeutic radiographer independent prescribing, please see the information here, including a newsletter of latest activity.
Medicines include contrast agents as well as medicines that might be given before, during or after a diagnostic imaging procedure or during the treatment period for radiotherapy patients.
The law currently states that radiographers are allowed to supply and/or administer medicines using patient specific directions (PSDs) or patient group directions (PGDs). Both diagnostic and therapeutic radiographers can train to become supplementary prescribers and therapeutic radiographers can train to become independent prescribers.
A Patient Specific Direction (PSD) is the traditional written instruction, signed by a doctor, dentist, or non-medical prescriber for medicines to be supplied and/or administered to a named patient after the prescriber has assessed the patient on an individual basis.
Patient group directions (PGDs) are written instructions to help supply or administer medicines to patients, usually in planned circumstances. They take a significant amount of time and resource to develop and implement.
You can only supply and or administer medicines under PGDs if there is an advantage for the patient without compromising their safety.
PGDs should be put together by a multi-disciplinary group including a doctor, a pharmacist and a representative of any professional group expected to supply the medicines under the PGD. It’s good practice to involve local drug and therapeutics committees, area prescribing committees and similar advisory bodies. Radiographers are listed within the group of health care professionals who are legally entitled to use PGDs .
Guidance on the use of PGDs continues to evolve and develop. Before developing new, or updating old PGDs current information and resources should be reviewed. All information and links can be found on the Specialist Pharmacy Services website .
A statement on the continued use of PGDs for contrast agentsis available (updated in 2018).
Supplementary prescribing is defined as a voluntary prescribing partnership between an independent prescriber and a supplementary prescriber to implement an agreed patient-specific clinical management plan (CMP) with the patient's agreement. Diagnostic and therapeutic radiographers can be supplementary prescribers.
Independent prescribers are responsible and accountable for the assessment of patients with undiagnosed and diagnosed conditions and for decisions about the clinical management required, including prescribing. They assume full accountability for the prescribing decisions they make. They may instruct another person to administer the medicines under the terms of a PSD. An independent prescriber may be a medical prescriber (doctor/dentist only) or a non-medical independent prescriber (nurse, pharmacist, optometrist, physiotherapist, podiatrist or therapeutic radiographer).
Therapeutic radiographer independent prescribers may NOT prescribe controlled drugs. Additional legislation will be changed in 2019 to permit prescribing from a list of controlled drugs.
For a searchable list of HCPC approved supplementary and independent prescribing courses (including conversion courses) please check the HCPC website.
Radiographers who are registered with the Health and Care Professions Council (HCPC) and have undergone and passed a validated course of education and training in either supplementary or independent prescribing are eligible to have their HCPC entry annotated to describe their status as a supplementary and/or independent prescriber. The HCPC sets Standards of Practice for Prescribers.
SCoR provides practice guidance for radiographer prescribers: Practice Guidance for Radiographer Independent and/or Supplementary Prescribers (2016)on the policy and guidance document library
To qualify as a supplementary or independent prescriber, radiographers have to successfully complete a course approved by HCPC, see the standards for education providers seeking HCPC programme approval and also The Outline Curriculum Framework for Education Programmes to Prepare Physiotherapists, Podiatrists and Therapeutic Radiographers as Independent/Supplementary Prescribers and to Prepare Dietitians and Diagnostic Radiographers as Supplementary Prescribers.
This document defines the skills and knowledge for all prescribers including nurses, allied health professionals and doctors. Hazel Boyce is an advanced therapeutic radiographer and supplementary prescriber at Bristol Cancer Institute, working mainly in On Treatment Review. Hazel worked on the recent review and update of the 'Prescribing Competency Framework'.
See document download box below for examples of clinical management plans. which are used in supplementary prescribing
Only certain named registered and regulated health care professionals, such as radiographers, are allowed to use patient group directions. Non-registered practitioners are not allowed BY LAW to use patient group directions and so must not administer prescription only medicines (POM). Generally IV saline IS a POM although prefilled, single use syringes specifically intended for mechanical flushing of ports and catheters are classified as medical devices under the law and, in this case, assistant practitioners and other non-registered health care staff can use them. SCoR obviously expects all members to work competently and lawfully within their scope of practice and hence would not support an illegal practice and so flushing (which is, of course, administration) would not be covered by professional indemnity insurance unless the prefilled syringes (as described above) were in use.
NHS Evidence (including access to BNF) has a search facility for authoritative, evidence-based information from hundreds of trustworthy and accredited sources.
electronic Medicines Compendium (eMC) contains up to date, easily accessible information about most of the licensed medicines available for use in the UK. Includes patient information leaflets (PILs) and Summaries of Product Characteristics (SPCs). These include SPCs for contrast media.
Medicines & Healthcare products Regulatory Agency (MHRA) provides SPCs and PILs not on eMC and information about Yellow Card.
Sue Johnson is the professional lead on the safe use of medicines for the Society and College of Radiographers and will be able to answer your questions.
Radiotherapy, controlled drugs, independent and supplementary prescribing
Q: There is an ongoing debate among therapeutic radiographer independent Non Medical Prescribers as to whether we are allowed to prescribe codeine or Oramorph without a clinical management plan? Some say that we can as it's a schedule 5 drug, others say that we can't as it's a schedule 2 class B drug and nobody seems clear as to whether it's a controlled drug or not. Does it depend on the strength? Or does it depend on the Trust?
A: Codeine and morphine can only be prescribed by a radiographer using supplementary prescribing under a clinical management plan (CMP)
When the legislation was changed to allow for therapeutic radiographer independent prescribing the first piece of legislation (Human Medicines Regulations 2012) was changed to allow a limited list of controlled drugs to be prescribed. However, another piece of legislation called the Misuse of Drugs Regulations 2001 also needs to be amended. Until this change happens therapeutic radiographer independent prescribers cannot independently prescribe controlled drugs from any schedule.
The legislation around controlled drugs is complex. When a medicine is classified as a controlled drug it is then placed into a schedule. For therapeutic purposes these will be schedule 2, 3, 4 or 5. Sometimes the schedule is due to the drug, sometimes the strength or the formulation. This means for example that morphine injection 1mg per 1 ml is a schedule 2 controlled drug but that morphine oral solution 10mg in 5ml is in schedule 5.
The schedules are important because there are different legal requirements associated with them. However, for this particular question it is that fact that the drugs in question are classified as controlled drugs in any schedule that is important. You can find out which drugs are classified as controlled drugs here.
Nevertheless, if there is a clinical management plan (CMP) in place and the medicines are being prescribed under supplementary prescribing then controlled drugs from schedules 2-5 can be prescribed (but not for treating addiction).
The Society and College of Radiographers are actively working with stakeholders to try to get the amendments to the Misuse of Drugs Regulations 2001 agreed.
Independent sector, NHS referrals, medicines governance, PGDs
Q: I am an independent sector (IS) employer providing additional capacity for CT and MR scans. We are accepting NHS referrals from an NHS radiology department for IS employed radiographers to scan in IS facilities. Can the radiographers use the referring Trust Patient Group Directions (PGDs) or Patient Specific Direction (PSD) to administer medicines such as contrast agents?
A: You will need to discuss with the referring Trust what is required and accordingly put in place a Memorandum of Understanding (MOU) or similar with regards to how this will be managed. It is possible for the independent sector radiographers to work under a Patient Specific Direction (PSD) from a referring Trust. You will need to be clear on lines of accountability. The radiographers must be confident that they understand their professional and legal responsibilities for the patient including where and how to escalate concerns or queries. It should be clear about who is taking clinical responsibility for the patient should there be any issues.
Alternatively they may be able to use the Trust’s PGDs but would need honorary contracts in place with the Trust and also a MOU detailing the issues around where they were working as possibly far wider accountability in terms of equipment, who owns the contrast etc. The IS radiographers will need to complete any PGD training that NHS radiographers complete and policies updated to reflect the addition of IS radiographers to the authorised user of the PGDs. Radiographers should know who is taking clinical responsibility should the patient fall outside of the PGD or there be other queries.
Chief Pharmacists from the involved organisations should be able to advise what constitutes a legal and safe process. Good governance requires both employers recognise any agreement and that this is supported at senior or Board level.
Further information is available here: Patient Group Directions in Complex Commissioning Scenarios
With thanks to Jo Jenkins, Specialist Pharmacist (Patient Group Directions), Medicines Use and Safety Division, Specialist Pharmacy Services in developing this answer.